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. The 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 and it proposes an insufficient duration of public comment. It should be withdrawn and dramatically improved before being reintroduced to the public for review and comment.
The mine as currently proposed is different form 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.
Legally, the Corps of Engineers must take a hard look at the reasonably-foreseeable impacts of proposed mine. This hard look must include the likely impacts of a complete mine and infrastructure buildout as well as potential 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, the proposed 90-day comment period is woefully insufficient to allow all stakeholders to digest the information in the draft EIS and meaningfully comment on the proposed mine.