Bristol Bay’s unimpaired watersheds and wild, sustainable, commercial, recreational, and subsistence fisheries represent an extraordinarily rare resource of national and global importance. The best available science must be considered in all levels of environmental review and permitting for Pebble Mine, a project whose potential scope is so vast that would forever alter the watershed and the fisheries resources that rely on it, including the extraordinarily prolific, sustainable, all-wild Bristol Bay salmon fisheries.
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AFS Commends EPA Veto of Pebble Mine Project to Protect Bristol Bay Salmon Fisheries
FOR IMMEDIATE RELEASE January 31, 2023 Contact: Drue Winters [email protected] AFS Commends EPA Veto of Pebble Mine Project to Protect Bristol Bay Salmon Fisheries The American Fisheries Society commends the EPA’s use of its authority under section 404(c) of the Clean Water Act to safeguard Bristol Bay’s, sustainable wild salmon and the pristine habitat they thrive in from the irreversible effects of Pebble Mine, a project whose impacts to fisheries and the watershed cannot be adequately reduced or mitigated. Bristol Bay supplies 57 percent of the world’s wild Sockeye Salmon, generating $2.2 billion annually, supporting 15,000 American jobs, and sustaining Indigenous communities since time immemorial. Incredibly, more than 78 million salmon returned to Bristol Bay in 2022. In addition to Sockeye Salmon, Bristol Bay and the watershed support one of the world’s largest remaining wild Chinook Salmon runs and healthy Coho, Chum, and Pink Salmon runs. These salmon, as well as resident trout, sustain lucrative commercial and recreational fisheries and provide jobs and food security to 25 rural Alaska Native villages and thousands of people. The high salmon production fuels an entire ecosystem including grizzly bears, moose, and estuarine birds. The indigenous Yup’ik and Dena’ina, two of the planet’s last salmon-based subsistence cultures, rely on these fisheries for food and these salmon runs are integral to their culture. Pacific salmon are already facing very real threats from climate change throughout their ranges. Protecting the productive waters of Bristol Bay is critical for maintaining their unique populations and their resilience to climate change as temperatures rise and hydrology changes. The habitat disturbance created by the Pebble Mine would erode that resilience, threatening the salmon populations and everyone who depends on them. AFS has long expressed concerns about the development of a mine in Bristol Bay. Today’s veto closes a chapter in the long-struggle to preserve an extraordinary fishery of global significance. “Salmon across the nation are sliding towards extinction due to pollution, habitat loss, and warming waters, yet Bristol Bay is one of the few places where salmon continue to thrive,” said AFS Executive Director, Douglas Austen, Ph.D. “EPA’s decision to use its Clean Water Act authority to preserve the last healthy wild salmon runs in the country and their untouched habitat is the right decision.” ### Editor’s Notes: Founded in 1870, the American Fisheries Society (AFS) is the world’s oldest and largest fisheries science society. The mission of AFS is to improve the conservation and sustainability of fishery resources and aquatic ecosystems by advancing fisheries and aquatic science and promoting the development of fisheries professionals. With five journals and numerous books and conferences, AFS is the leading source of fisheries science and management information in North America and around the world.

AFS Supports EPA Restrictions on Pebble Mine
September 6, 2022 Mr. Michael S. Regan Administrator Environmental Protection Agency Mail Code 2822T, 1200 Pennsylvania Avenue NW Washington, D.C. 20460 via regulations.gov Re: Proposed determination to restrict the use of certain waters in Alaska’s Bristol Bay watershed as disposal sites for discharge of dredged or fill material in association with mining the Pebble deposit; Docket No. EPA-R10-OW-2022-0418-0001 (Proposed Determination) Dear Administrator Regan: On behalf of the members of the American Fisheries Society (AFS) and the Alaska Chapter of AFS, we respectfully submit the following comments regarding the Proposed Determination to restrict the use of certain waters in the North Fork Koktuli River (NFK), South Fork Koktuli River (SFK), and Upper Talarik Creek (UTC) watersheds in southwest Alaska as disposal sites for dredged or fill material in connection with mining of the Pebble deposit; Docket ID No. EPA-R10-OW-2022-0418-0001. The American Fisheries Society and the Alaska Chapter of AFS fully support the EPA’s use of its authority under section 404(c) of the Clean Water Act to restrict the use of certain waters in the NFK, SFK, and UTC watersheds in southwest Alaska as disposal sites for dredged or fill material in connection with mining the Pebble deposit due to unacceptable adverse effects on anadromous fish. Large-scale mining in the watershed would cause irreversible impacts to this pristine habitat and the valuable fisheries it supports. We have long-standing concerns about the development of a mine in Bristol Bay, a project whose impacts to fisheries and the watershed cannot be adequately reduced or mitigated. The American Fisheries Society represents over 7,500 professional fishery scientists and resource managers who work in the private sector, in academic institutions, and in tribal, state, and federal agencies. The Alaska Chapter of AFS has more than 400 members. Our common mission is to improve the conservation and sustainability of fishery resources and aquatic ecosystems by advancing fisheries and aquatic science and promoting the development of fisheries professionals. Bristol Bay is a global treasure (Woody 2018). The high diversity and connectivity of aquatic habitats in the Bristol Bay watershed make it one of the most productive regions for Pacific salmon in the world (Bjornn and Reiser 1991; Wobus et al. 2015). Bristol Bay is home to the world’s largest wild Sockeye Salmon fishery, supporting half the global catch (Cline et al. 2019; Tiernan et al. 2021). Along with Sockeye Salmon, Bristol Bay supports one of the largest wild Chinook Salmon runs as well as healthy runs of Coho Salmon, Chum Salmon, and Pink Salmon (Johnson and Blossom 2018). These salmon support major commercial, subsistence, and sport fisheries, providing jobs and food security to rural communities and thousands of people, and are a vital cultural element for Alaska Native peoples (Halas and Neufeld 2018; Tiernan et al. 2021). High salmon production also brings marine-derived nutrients to the Bristol Bay watershed, providing crucial food sources through eggs and carcasses to a variety of aquatic and terrestrial wildlife (Cederholm et al. 2011; EPA 2014). Due to the cyclical nature of salmon life histories, it could take years before harm from a mine to salmon populations becomes detectable. Within that time, undetected irreparable harm could affect generations of salmon populations and have significant impacts on the people and wildlife that depend on them. The EPA makes four independent unacceptability findings that support restricting the use of certain waters in the NFK, SFK, and UTC watersheds in southwest Alaska as disposal sites for dredged or fill material in connection with mining of the Pebble deposit. They are (1) the pristine condition and productivity of anadromous habitat throughout the SFK, NFK, and UTC watersheds; (2) the large amount of permanent loss of anadromous fish habitat; (3) the degradation of additional downstream spawning and rearing habitat for Coho, Chinook, and Sockeye salmon resulting from the loss of ecological subsidies provided by the eliminated streams, wetlands, and other waters; (4) and the resulting erosion of both habitat complexity and biocomplexity within the SFK, NFK, and UTC watersheds, which are key to the abundance and stability of salmon populations within those watersheds. These findings are consistent with the best-available science and our prior comments to the agency on the significant harm that would result to Bristol Bay’s anadromous and resident fish and fisheries from large-scale mining activities. In 2014, AFS objected to the agency’s withdrawal of the 404(c) Proposed Determination for many of these reasons and others. In addition to the EPA’s unacceptability findings, Pacific salmon are already facing very real threats from climate change throughout their ranges (Muñoz et al. 2019). Protecting the pristine waters of Bristol Bay is critical for maintaining their unique populations and their resilience to climate change (Cline et al. 2019). As temperatures continue to rise, it is likely that the hydrological conditions of the Bristol Bay watershed will change. Uncertainty in how they would change, and what that would mean for salmon, increases the magnitude of risks associated with the development of the Pebble Mine (Wobus et al. 2015). The high diversity of aquatic habitats and high quality of hydrological conditions in the Bristol Bay watershed has resulted in high degrees of phenotypic and genotypic diversity across the region’s salmon populations (Hilborn et al. 2003; Schindler et al. 2010). The introduction of the mine would erode that resilience, threatening the salmon populations and everyone who depends on them (Muñoz et al. 2019) We appreciate the opportunity to provide comment on the Proposed Determination and the opportunity to voice our support for Bristol Bay’s prolific, sustainable, all-wild salmon fisheries. We encourage the EPA to move quickly to finalize this process to ensure that these valuable resources are protected. Sincerely, Douglas J. Austen, Ph.D. Executive Director American Fisheries Society REFERENCES Bjornn, T. C., and D. W. Reiser. 1991. Habitat requirements of salmonids in streams. Pages 83–138 in W. R. Meehan, editor. Influences of forest and rangeland management on salmonid fishes and their habitats. American Fisheries Society, Special Publication 19, Bethesda, Maryland. Cederholm, C. J., M. D. Kunze, T. Murota, and A. Sibatani. 2011.

AFS, Western Division, and the Alaska Chapter Submit Joint Pebble Mine Comments
The American Fisheries Society, the Western Division of AFS, and the AFS Alaska Chapter submitted a joint comment letter this week to the U.S. Army Corps of Engineers on the Pebble Mine Draft Environmental Impact Statement (DEIS). The comments note that impacts and risks to fish and their habitats are underestimated and are not supported by the data or analysis provided, and that critical information is missing. PDF of joint comment letter June 13, 2019 Program Manager US Army Corps of Engineers 645 G Street, Suite 100-921 Anchorage, AK 99501 Via [email protected] Re: Pebble Mine Draft Environmental Impact Statement Dear Sir or Madam: On behalf of the members of the American Fisheries Society (AFS), the Western Division of AFS, and the Alaska Chapter of AFS, we respectfully submit the following comments in response to the Pebble Mine Draft Environmental Impact Statement (DEIS) released by the U.S. Army Corps of Engineers (USACE) for public comment on March 1, 2019. AFS represents over 7,500 professional fishery scientists and resource managers who work in the private sector, in academic institutions, and in Tribal, state, and federal agencies. Our common mission is to improve the conservation and sustainability of fishery resources and aquatic ecosystems by advancing fisheries and aquatic science and promoting the development of fisheries professionals. The American Fisheries Society, the Western Division, and Alaska Chapter seek to ensure the best available science is considered throughout the environmental review and permitting for Pebble Mine. Because of the scope of the proposed Pebble Mine, its probable expansion into a larger mine and mining district (Chambers et al. 2012), and the uniqueness of the Bristol Bay region (Woody 2018), AFS and the Western Division of AFS provided comments in 20141 and do so again with the Alaska Chapter of AFS. Bristol Bay is extraordinary because it produces about half of the world’s wild Sockeye Salmon supply with runs averaging 37.5 million fish per year (Chambers et al. 2012; USEPA 2014; Woody 2018). The wild salmon fishery in Bristol Bay has been managed in a sustainable manner since 1884 and was valued at $1.5 billion in 2010. In addition to Sockeye Salmon, Bristol Bay and the watershed support one of the world’s largest remaining wild Chinook Salmon runs and healthy Coho, Chum, and Pink Salmon runs (Johnson and Blossom 2018). These salmon, as well as resident trout, sustain lucrative commercial and recreational fisheries and provide jobs and food security to 25 rural Alaska Native villages and thousands of people. The high salmon production brings huge levels of marine-derived nutrients to the watersheds in which salmon spawn, fueling sustainable populations of grizzly bears, moose, estuarine birds, and indigenous Yup’ik and Dena’ina peoples. The latter peoples represent two of the planet’s last salmon-based subsistence cultures, which were once widespread along the entire North American Pacific Coast. These wilderness-compatible economic sectors support 14,000 workers, including 11,500 in commercial fisheries, 850 in sport fisheries, and 1,800 in sport hunting and recreation (Chambers et al. 2012; USEPA 2014; Woody 2018). Based on our review of the DEIS, we find it fails to meet basic standards of scientific rigor in a region that clearly demands the highest level of scrutiny and thoroughness. The DEIS is an inadequate assessment of the potential impacts of the project. Specifically, as described below, we find the DEIS is deficient because 1) impacts and risks to fish and their habitats are underestimated; 2) many conclusions are not supported by the data or analysis provided; and 3) critical information is missing. 1. Impacts and risks to fish and their habitats are underestimated. Mine Footprint: We have serious concerns about the limited scope of the DEIS. An environmental impact statement is expected to fully disclose the risks and options for safely advancing or altering a proposed project. The limited scope considered for the mine footprint in the DEIS vastly underestimates the threats to fish, fisheries, and the human populations that rely on them. It is misleading to constrain the DEIS to a mining plan that only extracts 12% of the known resource and to ignore Pebble Limited Partnership’s planned expansion and stated purpose to make the mine commercially viable (Chambers et al. 2012). The DEIS acknowledges that the Pebble Project Expansion—a 55% of known resource mine, which would need additional tailings storage, additional water storage, new waste rock storage facilities, a concentrate pipeline, and a deep-water loading facility—is reasonably foreseeable (Table 4.1-1). This profitable mining plan appears to be a 78 to 98-year mine prior to closure as opposed to the 20-year mine prior to closure covered in the DEIS (Chambers et al. 2012). Further, it is reasonably foreseeable that the Pebble Project Expansion would begin within the timeframe of the proposed 20-year mine. The DEIS relegates the expansion to “possible future action” status rather than considering it a practicable alternative. As a consequence, this more likely profitable scenario with its much larger mining footprint is not evaluated for direct or indirect effects but more narrowly for cumulative effects only, thus underestimating the impacts on fish, fish habitat, and humans. Since the Pebble Project Expansion would be 1) dependent on the approval of this initial permit, 2) could not proceed unless this permit is approved previously, and 3) is classified as an “expansion” or an interdependent part of the larger Pebble Mine action and thus depends on the larger action for its justification; it should be evaluated as a potential connected action in the indirect impacts analysis (40 CFR 1508.25 (a)(1)(i-iii).) Diversity of Life History Strategies: The Bristol Bay watershed is pristine with exceptionally high-water quality and habitat diversity, closely connected surface-ground water systems, and an absence of channel fragmentation by roads, pipelines, or dams (Woody 2018). These factors lead to extremely high levels of genetic diversity among hundreds of locally adapted unique salmonid populations, which in turn support high levels of salmon production and system-wide stability. Because of this portfolio effect, there is remarkable annual productivity regionally despite considerable fluctuation in any single river system or any

Army Corps Extends Pebble Comment Period
The Army Corps of Engineers has extended the public comment period on its pending environmental analysis for the proposed Pebble mine. The comment deadline is now July 1, offering an additional 30 days.

Pebble Mine Draft Environmental Impact Statement Open for Comment March 1
The US Army Corps of Engineers (USACE) has completed the Draft Environmental Impact Statement (EIS) for the proposed Pebble Project. The Draft EIS is intended to disclose the likely impacts from the proposed project and to offer the public, tribes, and governmental agencies a chance to review and comment. The Draft EIS is available for download here. The U.S. Army Corps of Engineers will collect comments on the Draft EIS in multiple ways including public hearings. The public hearing schedule can be found here. A 90-day public comment period will open March 1, 2019 and end May 30, 2019. The Final EIS will address all substantive comments on the Draft EIS and is estimated to be released in early 2020.
USACE Extends Pebble Mine EIS Scoping Period through June 29
The U.S. Army Corps of Engineers is seeking input on the appropriate contents of an Environmental Impact Statement (EIS) for the Pebble Mine project and has extended the deadline to submit comments to June 29, 2018. The objective of the scoping is to identify specific elements of the environment that might be affected by the Pebble Limited Partnership’s (Pebble) proposal to operate a copper and gold mine in Alaska’s Bristol Bay. In December 2017, Pebble submitted its first Clean Water Act 404 permit application to the U.S. Army Corps of Engineers which triggered the federal permitting and environmental review process. Pebble seeks to develop the first 1.2 billion tons of its nearly 11 billion-ton deposit and set the stage for future expansion and the construction of an industrial mining district in Bristol Bay. The Corps of Engineers determined that an Environmental Impact Statement (EIS) will be needed for the proposed mine development. The EIS provides the basis for the U.S. Army Corps of Engineers and other federal agencies to evaluate federal permit applications and it analyzes the various environmental, social and economic impacts of a project. The Corps conducted public hearings throughout April and is accepting written comments on the following topics: Issues and concerns that should be addressed in the EIS The way in which land and resources might be affected by the project Ideas on alternatives and ways to minimize impacts Written comments may be submitted directly into the project website at www.pebbleprojecteis.com, at a public meeting, or by mail to: U.S. Army Corps of Engineers, Alaska District ATTN: DA Permit Application 2017-271, Pebble Limited Partnership P.O. Box 6898 Joint Base Elmendorf-Richardson, Alaska, 99506-0898

Pebble Mine: Stakeholder Concerns over Fisheries Impacts Sway EPA
After hearing directly from stakeholders and the people of Alaska, Environmental Protection Agency (EPA) is suspending its process to withdraw the proposed restrictions on Pebble Mine. This decision would leave the restrictions in place while the agency receives more information on the potential mine’s impact. In a statement released on January 26, the agency said, “EPA has serious concerns about the impacts of mining activity in the Bristol Bay Watershed. From public comments to community meetings, stakeholders stressed the importance of balancing a singular mine venture with the risk to one of the world’s largest commercial fisheries.” In September, the EPA took steps to withdraw a July 2014 Clean Water Act 404(c) Proposed Determination that would have, if finalized, imposed restrictions on the discharge of dredged or fill material associated with mining the Pebble Deposit in Alaska’s Bristol Bay watershed. Last summer, as part of a settlement with the proposed mine developer, Pebble Limited Partnership, the agency initiated the process for withdrawing the Proposed Determination. The agency sought comment on this action and has since reviewed the comments and the feedback from stakeholders. During the subsequent public comment period, more than one million comments supporting protections for Bristol Bay were submitted to the EPA with 26,000 from Alaskan citizens and business owners. Administrator Pruitt stated, “Based on that review, it is my judgment at this time that any mining projects in the region likely pose a risk to the abundant natural resources that exist there. Until we know the full extent of that risk, those natural resources and world-class fisheries deserve the utmost protection. Today’s action allows EPA to get the information needed to determine what specific impacts the proposed mining project will have on those critical resources.” Section 404(c) of the Clean Water Act allows the EPA to restrict, prohibit, deny or withdraw the use of an area as a disposal site for dredged or fill material. In the case of Pebble Mine, the restrictions would have made it nearly impossible for the project to move forward due to the restrictions on the amount of mine waste that could be disposed of in the Bristol Bay area. Recently, Pebble Limited Partnership applied for the first of the many permits it will need to develop the mining project, initiating a multi-year NEPA review and EIS process. The Army Corps of Engineers cannot issue a final 404 permit for the Pebble Mine while a Section 404(c) review is ongoing. While this bit of good news is encouraging, stakeholders must continue to inform decision-makers about the potential impacts of the mine to Bristol Bay’s unimpaired watersheds and wild, sustainable, commercial, recreational, and subsistence fisheries as the permit process unfolds.

AFS Objects to EPA’s Withdrawal of Pebble Mine Determination
UPDATE: The Pebble Limited Partnership has filed its permit application with the Corps of Engineers which has determined that it will conduct an Environmental Impact Statement (EIS) to comply with its NEPA review of the project. The lengthy process requires that a comprehensive “alternatives assessment” be undertaken to consider a broad range of development alternatives and an opportunity for public comment. The American Fisheries Society (AFS) submitted a letter in response to the Environmental Protection Agency’s proposal to withdraw its July 2014 Clean Water Act 404(c) Proposed Determination to restrict the use of certain waters as disposal sites for dredged or fill material associated with mining the Pebble deposit in Alaska’s Bristol Bay watershed. AFS objected to the withdrawal of the proposed determination and recommended that the EPA use its authority to prevent the elimination and/or impairment of waters and wetlands supporting the extraordinarily prolific, sustainable, all-wild Bristol Bay salmon fisheries. AFS expressed concern that EPA’s settlement agreement with the Pebble Limited Partnership would clear the way for a project whose impacts to fisheries and the watershed cannot be adequately reduced or mitigated. Bristol Bay’s unimpaired watersheds and wild, sustainable, commercial, recreational, and subsistence fisheries represent an extraordinarily rare resource of national and global importance. The area boasts the world’s largest and most valuable wild salmon fisheries. AFS seeks to ensure the best available science is considered in a decision such as this that removes protections for the watershed and the fisheries resource that rely on it and asked the EPA to consider its own report, “An Assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay, Alaska.” AFS believes the report is an “indispensable resource to inform decision-makers of the costs, benefits, and risks to public salmon resources from proposed mining activities in Bristol Bay.” Read AFS’s letter to the EPA here. The public comment period closes October 17. Stand up for Bristol Bay, submit your comments here.

EPA Seeking Public Comment on Withdrawal of Clean Water Act Determination for Pebble Mine
The Environmental Protection Agency (EPA) is proposing to withdraw a July 2014 Clean Water Act 404(c) Proposed Determination that would have, if finalized, imposed restrictions on the discharge of dredged or fill material associated with mining the Pebble Deposit in Alaska’s Bristol Bay watershed. Section 404(c) of the Clean Water Act allows the EPA to restrict, prohibit, deny or withdraw the use of an area as a disposal site for dredged or fill material if the discharge will have unacceptable adverse effects on municipal water supplies, shellfish beds and fishery areas, wildlife, or recreational areas. The Bristol Bay watershed in Alaska is a pristine 40,000 square mile area crisscrossed by rivers and dotted with lakes. Its waterways support subsistence hunters, fishing tourism, and a diverse array of wildlife. The area boasts the world’s most productive salmon run, where millions of fish return to spawn every summer. Bristol Bay supplies half of all Sockeye Salmon sold on the global market. Massive gold and copper deposits worth an estimated $350 billion are present in the Bristol Bay watershed. In 2002, Northern Dynasty Minerals proposed the Pebble Mine project on 186 square miles of state-owned land for which it held the mineral rights. The company teamed up with three mining companies to form the Pebble Limited Partnership (PLP) in hopes of developing the mining project. The mine, if constructed, would be the largest open pit mine in North America. In 2010, fishermen, seafood businesses, and Alaska Native tribes petitioned EPA to use its authority to preemptively block PLP’s 404 permit. Over the next few years, EPA developed the Bristol Bay Watershed Assessment which described the Bristol Bay ecosystem and its human uses and evaluated the likely effects that the project would have on the ecosystem’s structure and function. The assessment concluded that healthy, unperturbed habitat is one of the primary reasons that Bristol Bay salmon runs have remained strong and that the potential adverse impacts of mining would be difficult to mitigate given the size and remote location of the deposit. In July 2014, EPA exercised its 404(c) authority and issued a Proposed Determination that specified the conditions under which a mine could proceed without doing irreparable environmental harm. The conditions made it unlikely that the mine could operate profitably. In response, PLP filed suit against the EPA to prevent the determination from becoming final. In May 2017, EPA Administrator Scott Pruitt announced a settlement between the EPA and the PLP. The terms of the settlement required the PLP to drop its suit and in return EPA agreed not to finalize the determination for 48 months from the effective date of the settlement agreement or until issuance of a final environmental impact statement on PLP’s permit application, whichever comes first. PLP would have to file a permit application within 30 months to take advantage of this forbearance. The settlement agreement does not require or guarantee that PLP will submit a permit application, nor does it guarantee or prejudge a particular outcome of that permitting process or EPA’s decision-making under section 404(c). Comments can be submitted here. The comment period will close October 17, 2017.
AFS Policy Letters and Statements Related to Pebble Mine
AFS Policy Letter 2014 on Pebble Mine and Failure of Mount Polley Dam – Comments to USEPA Region X AFS Policy Statement on Mining and Fossil Fuel Extraction Revised 2016
BRISTOL BAY: Watchdog clears EPA of bias in Pebble study
Kevin Bogardus, E&E reporter Published: Wednesday, January 13, 2016 U.S. EPA’s internal watchdog has cleared the agency of harboring any bias when conducting its controversial assessment of potential large-scale mining in Alaska’s Bristol Bay watershed. The report, approved by EPA Inspector General Arthur Elkins and released today, said the agency went by the book, following the appropriate policies and procedures when crafting the assessment. In addition, the report said EPA met the requirements for peer review, involved the public in the process, and reviewed and verified information in the assessment before finalizing it. “Based on available information, we found no evidence of bias in how the EPA conducted its assessment of the Bristol Bay watershed, or that the EPA predetermined the assessment outcome,” said the IG. Read more CREDIT: EENews.net