The U.S. Army Corps of Engineers is reviewing Pebble’s key, federal mining application. The Agency is scheduled to release its decision this fall. This means Pebble could have its most important permit in hand this year.
The Environmental Impact Statement we commented on last spring will inform that decision. To state the obvious, it is critical that sound science informs this document.
Unfortunately, we continue to be disappointed and frightened with what we see. The Executive Summary of the preliminary Final Environmental Impact Statement was released to the public and we’ve had a chance to take a look. What we see shows a plan empirically different than what was available for public comment in 2019. This is a huge problem.
Let’s say the Army Corps of Engineers is the student. Last year, they turned in a draft. It was rough. Like a teacher giving feedback on a paper, we wrote comments on it and asked them to go back and fix key problems. Now, we are waiting for the final paper that will be published and graded. But, earlier this month, the “student” showed us a peek of their final paper. Mysteriously, the outline and a number of its key components have completely changed.
This is incredibly telling of what we’ve seen from this student throughout – cherry-picking edits to accept and ignore, changing the paper, and rushing to get it done. It’s concerning because once the student turns in the final, there’s no way to change it.
Once the Army Corps of Engineers releases the Final Environmental Impact Statement for Pebble, there’s no place for the public to comment, and it doesn’t look like Pebble has fixed a many of the very serious issues we commented on last year.
Here’s a list of the biggest unresolved issues with the EIS:
The final EIS is based on an incomplete and constantly changing proposal. The overall project description has changed four times, including at least once since the close of public comment on the draft EIS. PLP’s parent company, Northern Dynasty Minerals, has stated that it “cautions that the current Project Description may not be the ultimate development plan for the Pebble Project and that a final project design has not been selected.” In responses to many important questions from federal and state agencies and the public, PLP responds with “concept-level” information rather than details. To date, there is no mine construction plan, no plan of operations, no economic feasibility study, and no mitigation or mine closure plan. None of these key documents will be available until well after the Corps intends to make its decision on PLP’s permit application.
The final EIS lacks essential scientific studies and background data. The Corps has sent 259 requests for information to PLP, many of which remain unfulfilled and incomplete. Nearly all (252) of these requests were made after the final opportunity for public comment to the Corps. Neither PLP nor the Corps have plans to undertake the missing studies or acquire the missing information before completing the final EIS. Additional studies and data are needed on:
Salmon and resident fishes abundance, distribution, and migration timing;
Wetland and vegetation mapping;
Groundwater hydrology;
Cultural and subsistence resources;
Economic impacts to recreational fishing and businesses, and commercial fisheries;
Air quality; and
Mitigation and reclamation
As currently proposed, 105.4 miles of streams and 2,226 acres of wetlands will be destroyed. Because these figures are based on existing maps of wetlands and streams that are notoriously incomplete, and the project design keeps changing, the Corps is underestimating the full extent of the impacts to the Bristol Bay region’s world-class fisheries. Although the Corps arrives at these figures by analyzing impacts from developing just 1/8th of the deposit, PLP continues to tout the entire deposit to its potential investors, which will destroy more than 300 stream miles and 10,000 acres of wetlands.
There has been no tailings dam failure analysis to evaluate the likelihood and consequence of a breach to the tailings facility despite PLP’s assurances it would do one. Following the tailings dam failure at Mount Polley in British Colombia, PLP stated its CEO, Tom Collier, “has committed to submit the engineering design for the project’s tailing storage facility to an independent review prior to initiating permitting.” AECOM, the consulting group hired by the Corps to lead review of the project, raised serious concern about the potential for dam failure, emphasizing “concern that some and perhaps all of the entire centerline part of the [tailings dam] main embankment…could slide into potentially undrained tailings and have consequent effects in a downstream direction.” Although the Corps intends to conclude its review of PLP’s permit application within months, there has been no analysis of the potential for a tailings dam failure.
Many impacts will be permanent and water treatment and remediation will be perpetual, even after the mine closes. The draft EIS indicated mining the first 1/8th of the deposit will generate 4 times more wastewater of any other large mine in Alaska and 3 times more than any other large mine in the U.S. Wastewater will require perpetual treatment to prevent the mine pit from overflowing after operations cease. New project updates, only available after the close of public comment, show the volume of potentially acid-generating waste rock that will need to be stored at the mine site has nearly doubled, from 50 million tons to 93 million tons.
There is no viable transportation corridor or gas pipeline for the proposed mine. Each alternative the Corps evaluated is not feasible due to objections from nearby landowners that oppose the project. If the project is built, it will require a new transportation network and/or gas pipeline that has not been evaluated in the EIS.
Our position will always be that the Bristol Bay region is too special for the Pebble mine. But all sides of this issue agree that Pebble should undergo rigorous scientific review to backup Pebble’s claims that their mine won’t harm the fishery in Bristol Bay. The data shows that this is simply not happening.
With a decision on Pebble’s permit looming in the next 6 months, we need to tell the Army Corps of Engineers and President Trump that Pebble’s permit must be denied, for this reason, and many others. Join us in telling the President to deny Pebble’s permit today.