by Lindsey Bloom
Next week, the Pebble Partnership’s hired firm known as Keystone will hold meetings in Anchorage to present Pebble’s selected scientific baseline studies to panels of scientists and those stakeholders who can afford a plane ticket to Anchorage. Neither Pebble nor Keystone will disclose how much Pebble is paying for this “process.” What they’re also not telling you is that the presentation is a superficial PR stunt that continues Pebble's perpetual pattern of hiding information from stakeholders while publicly touting their transparency and willingness to share information, a sentiment that is disingenuous at best.

In the last year, through a high-profile media campaign, Pebble has been pushing its Environmental Baseline Document (EBD). They claim that this document portrays “one of the most extensive environmental studies programs ever conducted for a natural resource project in Alaska.” Pebble’s EBD amounts to thousands of pages of data in locked PDFs that is not replicable by independent scientists and therefore cannot be peer reviewed.
However, a team of independent scientists with a variety of backgrounds and funding sources has read and analyzed the tens of thousands of pages. Below are highlights of their findings and links to their full critiques. In summary, what we see with Pebble’s EBD looks to be another expensive Dog and Pony show put on for the Alaskan public and decision makers as a political and public relations tactic rather than a product of scientific integrity.

1. Assessing reliability of Pebble Limited Partnership’s salmon escapement studies, Dr. Carol Ann Woody
http://pebblescience.org/pdfs/Woody_EBD_EscapementFINAL27June2012.pdf

Bottom line: PLP cannot tell us how many total salmon spawn in streams draining the deposit after nine years of study, $120 million dollars, and 27,000+ pages of data.

• Studies are not transparent violating a basic tenet of science; PLP refuses to release their data in a downloadable, analyzable format  
• Alaskan consultants initially hired by Pebble estimated hundreds of thousands of salmon spawn in streams draining the deposit; the Outside consulting firm PLP later hired to replace them, however, estimates only hundreds of spawning salmon  
• PLP did not estimate the total number of spawning salmon, an essential estimate of salmon production  
• “Average” numbers of spawning salmon relied on flawed methods which underestimated numbers of spawning salmon

2. Critique of Pebble Limited Partnership’s seismic hazard assessment, Dr. Bretwood Higman

http://pebblescience.org/pdfs/Higman%20Pebble%20Seismic%20Critique.pdf

Bottom line: PLP’s seismic hazard assessment may greatly underestimate the risk of large earthquakes.

• PLP omitted important data from the assessment and misrepresented research that was included  
• PLP failed to establish the location of faults near the deposit and their potential to generate earthquakes

3. A review of Pebble Limited Partnership’s Environmental Baseline Documents:  Water quality, Dr. Kendra Zamzow

http://pebblescience.org/pdfs/Zamzow%20-%20Review%20of%20PLP%20EBD%20-%2...

Bottom line: Waters around the Pebble deposit are exceptionally pure and are particularly vulnerable to contamination from mining that could harm fish.

• Waters surrounding Pebble are of high quality, but have little ability to buffer or mitigate aquatic life toxicity resulting from mining (i.e., low alkalinity, low hardness, and low concentrations of dissolved organic carbon are likely to result in a decrease in pH and an increase in toxic metals as a result of mining activities)  
• Methods for some data analysis are not repeatable or consistent  
• PLP’s data interpretation implies water quality is poorer than their data supports  
• Sampling methods described in the EBD were acceptable and laboratory analytical results were of high quality

4. A review of Pebble Limited Partnership’s Environmental Baseline Documents:  Resident fish and juvenile salmon habitat, distribution and assemblage, Sarah O’Neal

http://pebblescience.org/pdfs/FINAL_Fish_Assemblage_Review_15_May_2012.pdf

Bottom line: PLP insufficiently characterized resident fish populations important to subsistence, and mischaracterized juvenile salmon populations, making data impossible to use for measuring impacts to fish most vulnerable to effects of mining.

• Accurate, reliable estimates of numbers resident fish and juvenile salmon are lacking  
• PLP’s current understanding of the numbers and distribution of juvenile salmon and resident fish distribution and abundance is inadequate to determine impacts of large scale mining to those populations  
• Data presented in the EBD are both incomplete and cumbersome—if not impossible—to interpret  
• Methods were inconsistent and therefore results are unrepeatable

5. A review of Pebble Limited Partnership’s Environmental Baseline Documents:  Aquatic macroinvertebrates (Bristol Bay drainages), Sarah O’Neal

http://pebblescience.org/pdfs/FINAL_Macroinvertebrate_Review_11_May_2012...

Bottom line: PLP incorrectly identified over 10% of important freshwater insect species, which are indicators of water quality; consequently those data cannot be relied upon to measure impacts to streams from mining.

• Aquatic insects (or macroinvertebrates) are a critical baseline monitoring parameter due to their ecological importance and utility for providing an accurate indication of the health of the water.  
• Aquatic macroinvertebrate sampling site selection and sample sizes are insufficient to characterize spatial and temporal variability  
• Over 10% of certain types of sensitive insect groups were misidentified, making the data unreliable for measuring impacts of mine development

6. Additional reviews are available regarding:

• Hydrology:  http://pebblescience.org/pdfs/2012.05.25.EBD.Hydro.pdf, and   
• Geochemistry:  http://pebblescience.org/pdfs/EBD.Review_Geochem_Maest_18May2012.pdf

A lifelong Alaskan and second-generation fisherman, Lindsey Bloom has been fishing Bristol Bay since 1997. When the salmon aren’t running, Lindsey works with businesses, fishing associations, and conservation groups on salmon habitat conservation issues. Lindsey is a former at-large board member of United Fishermen of Alaska and current board member of Alaska Independent Fishermen’s Marketing Association.