. . . then I should tell you what is in the Watershed Assessment.
Here is my summary of the 2nd Draft EPA Assessment.
In its revised watershed assessment, EPA clarifies risks to Bristol Bay’s watershed from proposed large-scale mining, especially the Pebble Deposit. Not only did EPA clearly respond to concerns of the peer review, but they also took seriously the comments from independent experts who commented on the first draft of the watershed assessment. In this second draft, EPA draws from a range of resources – from independent peer reviewed science to Environmental Baseline Data released by the Pebble Limited Partnership – to characterize the potential impacts of large-scale mining development on the Kvichak and Nushagak watersheds creating a document that seems to have a more balanced approach to considering the full range of potential stressors; i.e., there’s less emphasis on the “catastrophic” failure mode and more on the sorts of “routine” failures that are more likely to occur.
The EPA’s a comprehensive risk assessment that underscores that large scale mining, would “at a minimum cause the loss of spawning and rearing habitat for multiple salmonids” (ES-i). Even with no incidents of catastrophic failure, large scale mining would – block streams with roads and development, reduce water flow in the region, directly eliminate up to 4800 acres of wetlands, and directly eliminate up to 90 miles of streams, and dewater an additional 33 miles of stream.
With as many as 5 new chapters, EPA clearly responds to peer review questions and concerns on issues relative to the mine scenario, risk assessment, understanding the hydrologic nature of the watershed, cumulative impacts for other mines and development, and long term impact of climate change. By doing so, EPA provides a more thorough understanding of Bristol Bay’s complex water system and notes that impacts from water use and water treatment could have dramatic impacts on wetlands, fish spawning, and fish rearing habitat. Finally, EPA clearly shows that in short and long term, climate change will magnify these impacts, particularly when considering water and waste management in perpetuity post-mine closure.
In this draft, EPA expanded their assessment of potential large-scale mining to include scenarios as small as .25 billion tons as well as scenarios that evaluate up to 6 additional mines in the watershed, with increases of habitat losses by up to 84%, a total footprint of 13,000 acres and with up to 39 miles of streams eliminated (Table 13-8, page 13-21).
Regarding the Watershed Assessment as assessment of risk, EPA underscores that
“Like all risk assessments, this assessment is based on scenarios that define a set of possible future activities. To assess mining-related stressors that could affect ecological resources in the watershed, we developed realistic mine scenarios that include a range of mine sizes and operating conditions. These mine scenarios are based on the Pebble deposit because it is the best-characterized mineral resource and the most likely to be developed in the near term” (ES-10).
During the peer review process, EPA was criticized for its use of a ‘hypothetical mine plan,’ based on published documents from the Pebble Partnership. However, EPA rightly notes that “if the resource is mined in the future, actual events will undoubtedly deviate from this scenario. This is not a source of uncertainty, but rather an inherent aspect of a predictive assessment. Even an environmental assessment of a proposed plan by a mining company would be an assessment of a scenario that undoubtedly would differ from the ultimate development” (ES – 24, emphasis added).
EPA not only clarified and deepened its discussion of Bristol Bay’s complex hydrology essential to its productive salmon habitat, it elucidated potential risks from potential failures during mining and post closure. Even with the most advanced technology for water collection and treatment, EPA underscores the high probability of failure and that failure could result in the release of untreated leachates for hours to months. And that in perpetuity, water collection and treatment failures post-closure could lead to indefinite release of leachates into Bristol Bay’s waters, impacting Bristol Bay’s rivers and salmon habitat for generations, if not permanently.
Beyond water treatment, the assessment conservatively details potential impacts from possible failures – pipeline, road, culvert, and even tailings dams. In Chapter 13, responding to peer review concerns, however, EPA also gives greater attention the many impacts that do not come from catastrophic events or failures of mitigation, or what they refer to as “induced impacts,” from associated development, increased population and community infrastructure, regional use of resources, access to resources from roads for ATVs and snowmachines, and added hunting and fishing pressure along any transportation corridor.
In addition to impacts from development, the peer review panel strongly urged EPA to more fully consider the broad range of impacts from climate change, particularly in light of post-mine-closure management in perpetuity. Climate change projection show an average temperature increase of 4 degrees C by the end of the century, with precipitation increasing by 30% annually and a total of nearly 270mm of precipitation (3-44). On their own these changes will impact the salmon fishery and populations. Without development impacts salmon might adapt to changing conditions. However, adding climate change to mine assessment scenarios raises critical questions concerning water management and treatment, tailings storage risks, pipeline and road or culvert failures beyond the life of the mine post closure in perpetuity.
By examining these additional impacts, EPA’s report paints a dire picture for the future of the watershed, one that mirrors the history of salmon habitat throughout the Pacific Northwest that has led to the “near complete loss of wild salmon” and utter dependence on hatcheries to supplement salmon runs (13-35). Leaving a startling future for Bristol Bay’s vibrant commercial fishing economy and Alaska Native populations, whose culture and livelihood depend on healthy and intact wild salmon ecosystems.