If you've been living under a rock over the past few years, you've missed that EPA has been undergoing one of the most rigorous and greatest book report projects on the planet: An Assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay, Alaska. Well after one round of public listening sessions, two rounds of peer review, two rounds of public comment, in which nearly 1 million comments were submitted to EPA asking them to use their authority under the Clean Water Act to protect Bristol Bay, EPA is due to release the final version of this Assessment any day now.
For inquiring minds, I figured I would throw up a few highlights of the second draft. I'm also likely to blog up a history of the Assesment, how it came to be, and what the ask of EPA is from those concerned about Pebble Mine.
Keep in mind, the Assessment is not a regulatory document, it is simply a summation of the best available data out there on Bristol Bay, salmon ecosystems of Alaska, the proposed Pebble Mine, and a risk assessment of potential impacts.
Overview of EPA Assessment of Ecological Impacts of Large Scale Mining in the Kvichak and Nushagak Watersheds, Bristol Bay, Alaska (Draft Two).
Summary On Assessment: EPA’s second draft Watershed Assessment is reorganized substantially with necessary data moved from the appendices to the main document. They more thoroughly explain the purposes of the assessment and more clearly define the endpoints, particularly as they pertain to the fishery. Overall the subjects of greatest concern from peer review and response by EPA are summarized below.
Characterization of the Fishery: Overall, EPA’s characterization of Bristol Bay’s salmon fishery did not change. With an annual return of 37.5 million sockeye Bristol Bay represents 46% of the world’s sockeye salmon. With an annual harvest of 25.7 million fish, Bristol Bay sockeye provide 51% of global sockeye catch – providing nearly 14,000 jobs and an economy of nearly $1.5 billion a year.
EPA gave greater attention to non-salmon fish, which make this the most diverse fishery on the planet. They highlight the complexity of Bristol Bay and explain that “these findings suggest that even the loss of a small stock within an entire watershed’s population may have more significant effects than expected due to decreases in overall biological complexity.” (5-26)
Overall Impact: The EPA explains 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.
Mine Scenario: The EPA based its mining scenario on the Pebble Limited Partnership’s (PLP) own documents and PLP’s fillings with the Securities and Exchange Commission. The mining scenarios detailed in the Wardrop Report, released in 2011, are described by PLP as “economically viable, technically feasible, and permittable.” These scenarios show a total deposit of over 11 billion tons.
Range and Cumulative Impacts of Mines: EPA added a substantially smaller mine scenario with only 0.25 billion (250 million) tons of ore (previous sizes were 2.0 and 6.5 billion tons mined). The different sizes represent “different stages in the potential process of mining the Pebble deposit.” EPA took the new smaller mine scenario through a complete evaluation that included: mine footprint; miles of affected streams; acres of wetlands lost; effect of mine leachate on streams; and extent of effects from tailings dam failure. This allowed them to also evaluate the impacts of six (of fifteen possible) additional mines in the watershed.
Cumulative Impacts: EPA describes in detail the potential effects to water quality from non-catastrophic, routine operation of the mine. Even if the wastewater treatment system operates perfectly for the rest of time, water quality would be adversely affected by copper and other metals that leach from tailings and waste rock, escape capture, and move to shallow groundwater and surface water.
Induced Impacts: EPA gives greater attention to associated development, increased population and community infrastructure, regional use of resources, access to resources from roads and added hunting and fishing pressure along any transportation corridor. They explain that“it is reasonable to assume that loss of genetic and life-history diversity would occur as a part of this development” (13-33).
Climate Change: EPA greatly expanded their discussion of climate change. Projections 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.
Conclusion: By expanding the scope and directly addressing peer review concerns, 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.