U.S. Army Corps of Engineers – Alaska District
To Whom It May Concern:
The Draft Environmental Impact Statement released by the Army Corps of Engineers for the proposed Pebble Mine is inadequate. This document fails to address the mine that is actually proposed. It fails to address the reasonably-foreseeable impacts of the Pebble Mine on Bristol Bay fisheries, communities, public lands, and cultures. Finally, it proposes an insufficient duration of public comment.
The mine as currently proposed is significantly altered from the one discussed under the scoping process that took place in 2018. The Pebble Limited Partnership, according to its own press releases, has already increased the projected amount it intends to mine, and consequently the amount of tailings and other mine waste the project will generate. It is not possible to adequately evaluate the reasonably-foreseeable impacts of a mine unless the actual scope of the mine is known and studied.
The Corps of Engineers has a statutory obligation to take a hard look at the reasonably-foreseeable impacts of a proposed mine. This not only includes the likely impacts, but also the potential for unlikely but foreseeable catastrophic events. Among the most foreseeable impacts of an open pit mine is failure of the tailings dam holding back massive amounts of toxic mine waste. Pebble proposes an earthen tailings dam. Over ten percent of earthen tailings dams have failed worldwide. A catastrophic failure of a tailings dam in Bristol Bay would permanently alter the landscape and lifeways of the region. However, the Army Corps has declined to study this issue at all. This is an inexcusable oversight the Army Corps must correct before it considers any decision on a permit for the Pebble Mine.
Finally, this comment period is woefully insufficient to allow all stakeholders to digest the enormous amount of information in the draft EIS and meaningfully comment on the proposed alternatives. The timing could not be worse. Bristol Bay contains a web of towns and villages arrayed around the coast, lakes, and rivers. Communities are connected by air and water in this roadless region. As a result, it takes longer to get together and share information in Bristol Bay than elsewhere in the United States. This comment period is scheduled to occur primarily during breakup, when the rivers are difficult to impossible to travel.
Residents of Bristol Bay tend to congregate and communicate as the seasons dictate. The peak of social life in Bristol Bay is the summer fishing season. This is when people are the most mobile, traveling up and down rivers, from villages to fish camps. This is when people have a chance to congregate and discuss issues of importance. Instead of terminating the public comment period in June, before the region has even really come back to life after winter, it would make sense to leave public comment open through the end of the year. This would allow Bristol Bay residents a chance to read the documents, discuss them with each other, and complete their subsistence activities before synthesizing and submitting their comments on the mine.