NPCA submitted the following position to members of the House Committee on Transportation & Infrastructure Subcommittee on Water Resources & Environment ahead of a hearing scheduled for October 23, 2019.
The long-proposed Pebble Mine project sits adjacent to two iconic pieces of Bristol Bay’s intricate natural and cultural fabric—Lake Clark and Katmai National Parks and Preserves. These park sites are fundamental pieces of Bristol Bay, and key parts of the solution to achieve permanent, landscape‐level protection of our most robust wild salmon fishery. Congress recognized the importance of Lake Clark and Katmai’s contribution to Bristol Bay’s ecosystem integrity and productivity by detailing in each of their enabling language a specific role in protecting wild salmon habitat and natural and cultural values associated with salmon.
The Environmental Protection Agency’s (EPA) Clean Water Act 404 Proposed Determination and Bristol Bay Watershed Assessment of 2014 indicated that the Pebble Mine project could cause dramatic and unacceptable impacts on the aquatic environment of Bristol Bay. Based on that assessment, there should have been no dispute that the Pebble Project required extreme scrutiny. However, the weakening and eventual reversal of the proposed determination has led to a rapid and risky environmental review of the Pebble Project.
NPCA believes the Environmental Impact Statement (EIS) process undertaken by the Army Corps of Engineers is woefully inadequate in analyzing the full and complete impacts of the proposed project. During the public comment period, NPCA strongly urged the Army Corps to halt the EIS process until gaps in analysis had been filled, or if failing to do so, select the No Action Alternative for the Proposed Pebble Mine Project. NPCA is concerned with the following impacts that went unanalyzed in the EIS process.
The Pebble Project, if allowed to move forward, will have significant direct and indirect impacts on its two neighboring national parks. This includes potential negative effects of the mine and transportation corridor like diminished water quality and quantity, extensive elimination or degradation of fish habitat, increased pressures upon and competition for wildlife and fish, and loss of subsistence opportunities for the local residents whose traditional ways‐of‐life are intimately tied to Bristol Bay’s natural bounties and park sites.
Roughly 500,000 sockeye salmon pass through Lake Iliamna and into Lake Clark National Park and Preserve to spawn every year. As in the rest of Bristol Bay, salmon are the backbone of the Lake Clark ecosystem, providing crucial nutrients for wildlife and vegetation. The potential impacts of Pebble Mine on Lake Clark salmon range from catastrophic dam or tailings, pond failures to the long-term poisoning of Bristol Bay waters with trace amounts of copper. Barging facilities on Lake Iliamna could result in low-level but constant oil spills, or even a loaded ore barge suffering a catastrophic accident. These must be examined in the EIS given the congressional mandate to protect Lake Clark wildlife and the region’s subsistence lifestyles.
The EIS must also consider potential impacts to Lake Clark and Katmai brown bears. One of the highest densities of brown bears in the world can be found on the Alaska Peninsula. In 2012, an estimated 2,000-2,500 brown bears occupied the combined protected areas of McNeil River, Katmai, and Lake Clark. These bears draw tourists from around the world to Brooks Camp in Katmai, and to the coastal lands of both Katmai and Lake Clark. They are a unique national treasure and are often individually identifiable by park visitors and by bear viewers, including people from all around the world who view via the NPS Brooks Falls webcam that shows bears fishing at the falls.
As outlined above, the mine and an accompanying mining district threaten one of brown bears’ primary food sources - salmon. Even a localized loss of salmon could lead to reductions in brown bear densities within the national parks, running counter to the congressional mandate for the parks. The proposed Pebble Mine site itself sees use from Lake Clark bears and would destroy habitat used by park bears. The port, proposed for a very treacherous portion of the Alaskan coast, will directly take habitat that may be used by Katmai bears, threaten long-term contamination of the Katmai coast, and pose the risk of an oil or chemical spill that could have immediate and significant impacts on the Katmai coast and its bears.
A decrease in the bear population will have a very real effect on the local economy. A 2019 study from the University of Alaska Fairbanks indicates that bear-viewing provides $34.5 million a year to the economy of Southcentral Alaska. Seventy-four percent of local business expenditures related to bear viewing stay within Southcentral Alaska. This sustainable regional industry relies on wild, pristine and remote locations for world-renowned bear-viewing experiences. A road that cuts through the landscape and disturbs bear behavior would directly threaten not only the bears, but the viewing experience and the Southcentral Alaskan bear-viewing industry brand.
Beyond the challenges to wildlife posed by the Pebble Project, visitor activities such as camping, hiking, backpacking, hunting, fishing, birding and night sky viewing will likely be degraded and have not been adequately addressed in the EIS process. Lake Clark and Katmai National Parks and Preserves offer a rare wilderness experience that could be significantly impacted by the visual effects of the mine and associated infrastructure.
The EPA’s 2014 peer-reviewed Bristol Bay Watershed Assessment demonstrated that development of a large‐scale mining district, anchored by the proposed Pebble Mine, is likely to change the environmental integrity of waters and lands surrounding Lake Clark and Katmai National Parks and Preserves. There are unresolved and substantial conflicts to resource use in and around the parks and preserves of concern and the Corps has so far failed to consider the full impacts of a long-term Pebble Mine. EPA’s removal of the proposed determination has allowed this inadequate process to move forward.
Lake Clark and Katmai National Parks and Preserves, the habitat they were created to protect, and the subsistence, cultural and economic values they provide to the region would all be put at risk by the development of Pebble Mine and an accompanying mining district enabled by Pebble Mine’s road, port and energy infrastructure.