To Whom It May Concern:
I offer these comments in response to the Bristol Bay Watershed Assessment and the proposed Pebble Mine. I want to first thank the Environmental Protection Agency for listening to the voice of the people in the region, for undertaking this watershed assessment and for utilizing peer-reviewed science in their assessment.
I encourage the EPA to uphold the considerations of the National Environmental Policy Act (NEPA) in their decision-making process. And there is a decision to be made – whether to sit by idly and allow this thing to come into existence, ultimately wiping out our world-famous sustainable sockeye and Chinook salmon runs, or whether to exercise their 404(c) veto power and exempt the highly productive Bristol Bay watershed area from mining. The fate our region and future generations of Bristol Bay residents, commercial and subsistence fishermen are counting on you to make the right decision.
NEPA requires federal agencies to “use all practicable means” to do the following:
1. Fulfill the responsibilities of each generation as trustee of the environment for succeeding generations;
2. Assure for all Americans safe, healthful, productive, and aesthetically and culturally pleasing surroundings;
3. Attain the widest range of beneficial uses of the environment without degradation, risk to health or safety, or other undesirable and unintended consequences;
4. Preserve important historic, cultural, and natural aspects of our national heritage, and maintain, wherever possible, an environment which supports diversity, and variety of individual choice;
5. Achieve a balance between population and resource use which will permit high standards of living and a wide sharing of life’s amenities; and
6. Enhance the quality of renewable resources and approach the maximum attainable recycling of depletable resources.
If EPA does not exercise their 404(c) authority, and allows the Pebble Mine (and subsequent future mines) to be developed, it will be in breach of its duty to future generations, because subsequent generations of residents and commercial fishermen will be deprived of the privilege of harvesting our life-giving salmon from the rich Bristol Bay waters. The Watershed Assessment indicated that there is an inherent risk with mining operations, and with the introduction of culverts, roads, oil spills (some of which have already happened), and other such disturbances to the watershed, there WILL be an impact that will be measurable, and likely irreversible. The Pacific Northwest has been struggling to rebuild their salmon stocks after the introduction of hydroelectric dams in the region and other such disturbances, such as logging, population growth, mining, and roads. It is practically impossible to rebuild stocks once they are damaged beyond a certain point. Studies on runoff originating from copper from brake pads on roads in Oregon indicate that salmon are extremely susceptible to minute quantities of copper. Because this is a copper mine being proposed, this should be a huge red flag to the EPA that this is an unsustainable project that will result in depletion of our salmon resources for future generations.
Allowing Pebble Mine to be permitted by the State of Alaska (who has never denied a large mine permit to date), would violate NEPA’s second requirement, as it would result in an unsafe and unproductive area. The mining executives have touted the term “no net loss” in their propaganda, but I find it completely disingenuous that they can simply “create” wetlands. There is no such thing as “no net loss” as the loss will be to the 22 square miles of disturbed area that the mine would create. Once it is disturbed, it will never be restored to its original natural productive state. It will be not only “unaesthetic”, but downright ugly. The tens of thousands of visitors who come to these river systems, paying thousands of dollars for the vacation of a lifetime will not appreciate a 2 mile wide open pit mine. Additionally, the dust and other disturbances will disturb the migrating caribou and moose, and will translate to dust particles of toxic heavy metals blowing onto our pristine tundra areas where people currently pick berries and do their hunting.
The Bristol Bay watershed area has been providing wild salmon for the people, and for thousands of commercial fishermen who come to the region to harvest the catch for hundreds of years. The use of this area for productive salmon rearing habitat is the highest beneficial use possible. Mining is one of the riskiest occupations in the world. Based on past predictions of water quality, 75% of the time, the mining companies have gotten their water quality predictions wrong. For instance, the Pebble Partnership has touted highly that salmon and mining can co-exist, but 3 out of 4 past mines tell us a very different story. There are literally dozens of instances where mining operations have either harmed or completely destroyed fisheries around the world. I would hope that EPA would learn from the mistakes of other mines that have failed and not go down that road. Bristol Bay is too precious to simply throw away to mining.
The Bristol Bay subsistence way of life is a historic and cultural stronghold for the indigenous people of the region. Throughout the past several hundred years of genocide, introduced disease, forced assimilation, and cultural change, one constant binds the indigenous people to the land – the subsistence resources that bring families together to share in the harvesting, processing, and preserving of the catch. Our salmon resources are a tremendous opportunity for our families to work together, from elders to pass on the knowledge of this important food, and for us to laugh and work together. Some of my most memorable moments with my grandmother and great-grandmother are around the smokehouse, and splitting fish. Those traditions cannot simply be replaced or compensated for. They are priceless, and once lost, will be lost forever.
As trustees of this land for future generations, the people of the region have overwhelmingly voiced their opposition to the proposed Pebble Mine. The Pebble Partnership’s own website has indicated that the mine would only provide some 153 local jobs. Many of these would not be the high-paying jobs that are so highly touted by the State of Alaska and the mining executives. The proposed Pebble Mine would not enhance the quality of life for people of the region. The mining executives have indicated that it would be “camp style” living – 2 weeks on and two weeks off. As somebody who has had to travel for work, I can tell you that it does not result in a harmonious family life or routine to have one parent absent half of the time. The social implications of this type of system would be detrimental to the already struggling families in the region, and would result in higher rates of domestic violence, and likely, drug and alcohol abuse. Several of my close friends are single parents and I see how they struggle to keep their families intact. I would not want to see this type of social system being imposed on local mine workers in the region.
Finally, the 6th consideration of NEPA would not be met with this project. Rather than “enhancing the renewable resources,” it would put them at great risk. Until our landfills become mines and we have harvested all of the usable metals out of existing cells, perhaps then we should consider opening up new lands to mining. Over 80% of gold goes directly into jewelry. Jewelry for self-adornment seems like a very frivolous way to put our precious salmon resources at risk.
For the sake of my family, for the people of the Bristol Bay region, and for future generations of Bristol Bay fishing families, I implore the Environmental Protection Agency to exercise their 404(c) permitting authority and permanently protect the Bristol Bay headwaters and watershed area.
Thank you for your consideration.
Founder, Naknek Family Fisheries
4th generation commercial fishing family member
Mother of a 5th generation commercial fisherman
Wife of a Bristol Bay commercial fisherman
Tribally enrolled member, Naknek Native Village