June 6: Pebble Mine meeting

This is a report on the meeting I attended in the Naknek school auditorium yesterday with a hundred or so other interested people. I should start with a disclaimer that I'm not an expert on this issue - and that doesn't stop me from having a few strong opinions about it.

Some years ago, Lake Iliamna was found to have gold and copper deposits which a Canadian mining company, Northern Dynasty, wants to mine. They call it the Pebble Mine Project.

This was alarming to us because Lake Iliamna is the destination of the largest red salmon run in the world, and one of the two runs our family fishes from. Of course, this was just our small family concern. Most of the other fishermen, and even more so, most of the residents of the region were also alarmed. They moved into action, along with others who are not directly related to the region or the fishery but who know how to organize and believe in the importance of preserving such a magnificent natural, healthy, and sustainable resource. If you want to learn more about this effort, check out savebristolbay.org.

But not everyone agreed. This all happened at the same time as we suffered low fish prices, frighteningly low fish returns, and corresponding low permit values. With the high cost of living in Alaska, some residents have given up on the recently non-lucrative fishery and sold their permits, reducing their investment in the fishery. Without being supported by the fishing industry - whether they still have a permit or not - residents are looking for other ways to sustain their communities, which are struggling. South Naknek, the village across the Naknek river, had to close its school in the past few years because another family moved away, reducing the number of children attending that school to 9, when 10 is the threshold for keeping a school open. Those 9 children have to fly to Naknek every day or board with friends or relatives on the Naknek side of the river to attend school. (This might apply only during freeze-up in the fall and break-up in the spring. It could be that the children commute by skiff when the river isn't frozen or by vehicle when it is.)

So especially when income from fishing has shrunk, some people consider Pebble Mine a possible way of supporting their families and keeping their communities alive, thinking it would provide good-paying local jobs at least for the next 25-100 years. On the other side, those who opposed the Pebble Mine say that that enterprise will threaten, and probably destroy, the fishery that has sustained the culture for 1000s of years and will do so for 1000s of years into the future, as long as we continue to protect it. And it doesn't much matter who is fishing from it commercially; it is the foundation of the culture and the diet of the local residents and has been since there have been local residents - and that is enough reason to protect it. That is the prevailing view in many -- and I think most -- of the villages in the Bristol Bay watershed. That is also my view. The stakes are extremely high, and so are the risks of damage. To me, it is so sad that in addition to the threat to the environment and the consequential threat to the way of life and 1000s year old culture, this controversy is also tearing communities apart, making enemies out of neighbors who have always pulled together for everyone's mutual benefit and survival.

These communities' leaders have been petitioning the State of Alaska to take action to protect this region from the Pebble Mine and they strongly feel that the state has been unresponsive. So they appealed to the federal EPA for help, under its responsibility for water quality under the Clean Water Act. So the EPA came to the area and conducted a Watershed Assessment under two scenarios involving a large scale mine (assuming current mining technology, scale, and infrastructure): one assuming no failures in perpetuity and another assuming possible common failures. The draft report with appendices (reputed to be 2800 pages long) is available for download from www.epa.gov/bristolbay .

Having just recently released this draft assessment, the EPA representatives are traveling around the state presenting key findings and asking for comments with the goal of improving the quality of the report. They are also preparing to submit it to a peer review process.

They were in Naknek yesterday, asking for feedback on the accuracy of the assessment, suggestions on what, if any, information should be added for completeness, and what conclusions the audience draws from this assessment. Most of the testimony - 2 minutes per person - went to conclusions.

Before I summarize the testimonies, I want to give a little information. The first map is of the Bristol Bay region. The inset shows where it is situated within the state: right at the top of the Aleutian chain.

I've circled Naknek in orange. Following the peninsula northeast, you can see Pilot Point, then Egegik (a really rich fishing area), then South Naknek, then Naknek, the last village before the coastline turns southwest. King Salmon (the airport we fly into) is situated east and a little south of Naknek. The road between Naknek and King Salmon is pretty much the only road around here, except for the beach access road from Naknek, across the tundra, to about a mile from our cabins. The road between Naknek and King Salmon follows the Naknek River to which millions of salmon return every year to spawn in Naknek Lake, just east of King Salmon, and part of the Katmai National Park and Bear Preserve.

Going back to Naknek, you can head north and a little east, up the Kvichak river, past Levelock and Igiugig to Lake Iliamna to which more millions of salmon return every year to spawn. As an aside, if you travel east along the coast of Lake Iliamna, you'll find Kokhanok - that was the village where my parents built a homestead and where we lived until 1959 when we all piled into the fishing boat and came downriver to live in Naknek. Naknek is a particularly rich fishing area, located between these two very healthy and productive river systems. One of the things this map shows well is how porous the land is. Looking at the map, I think of a piece of bread soaking in water - where does the water end and the bread begin? It's hard to tell. The land here is saturated.

This is a photo taken from yesterday's EPA Powerpoint. You may have heard me say that ours is the largest red salmon (aka sockeye salmon) run in the world. Here is that statement in a pie chart. The pie is the world's salmon supply. Bristol Bay provides almost half of the world's salmon!! This chart probably doesn't take farmed salmon into consideration (but then, neither do I, really).

Together, East and West Kamchatka and Russia provide about 12%. Canada and Washington, another 18% and the rest of Alaska, maybe another 22% or so.

I don't know about the other half of the pie (though the presenters said that 29% of the U.S. salmon population is extinct and 33% is endangered) - but I know our half of the pie is very carefully managed, with a strong "resource first" ethic, an ethic shared by all the fishermen I know.

Fish and Game monitors the return by actually counting the individual salmon that comprise the escapement (those that make it up the river to spawn). They have established their escapement goals (in the Naknek system, it's been a pretty consistent 800K to 1.2M salmon. In the Kvichak, it has varied from 2 million to 10 million) to optimize future returns and avoid wasting a precious resource for a hungry world. Fish and Game balances the catch between subsistence (first priority), sports, and commercial fishing efforts.

They have been wise in having us dip our nets in throughout the season so we fish off many different strains of the returning salmon instead of hitting the last strains hard. The area's climate, topography, and geology have produced a strong diversity of salmon; the management strategies protect that diversity and that diversity helps ensure a consistently strong return.

From the perspective of the commercial fishing fleet, our reason for being here is to harvest as much of this resource as we can (trusting to Fish and Game to rein us back as necessary for future generations). From the perspective of Fish and Game, I think we are one more management tool: one that helps prevent over-escapement and whatever negative consequences come of that (if any).

I knew we produced a lot; I didn't know it was this much - half the world's supply. I'm astonished to think that we're willing to put this much of the world's salmon at risk - and I think, pretty high risk - for some copper and gold.

This figure is also from the EPA Powerpoint. It's the same region as in the first map above, but zoomed in to the area that would be most directly affected by a large scale mine in the Pebble location. I've used a Paint program to put a red star about where Naknek is and to draw a yellow outline around Lake Iliamna, Lake Clark above it, and Naknek Lake to the south. The blue area on this map is the area that would be open to mining.

I've been focusing only on my area of the fishery. The entire Nushagak system to the west would also be affected. Look at all those miles and miles of stream beds. If the salmon aren't spawning there, they're swimming through to spawn upriver.

Now, jump back to the map of the region. All these villages, where people have lived for 1000s of years - they live on the salmon, the moose, caribou, berries - all of it depends on the health of the ecosystem, and most of it depends on the health of the salmon run.

The testimonies:
I counted 60 speakers and all but a few strongly and passionately urged the EPA to stop the mine, with several specifically calling on the EPA to use its authority to invoke 404c to protect the area and the resource.

Many of those 60 speakers were elected officials or other community leaders, speaking for their constituencies. (I counted seven speaking as directors of the Bristol Bay Native Corporation, one representing the village of Togiak (village farthest west on the first map above), three from the Alaska Independent Fishermen's Marketing Association, and another from the Bristol Bay Drift Net Association.) In addition, a number of individuals testified who not only had a personal interest, but who also advanced professionally qualified opinions: one with a law degree and a MS in Environmental Studies; another is a fisherman/lawyer/adviser to Gov Hickle on fisheries and the environment; and another is the former director of the Bristol Bay Coastal Management Program, currently working with stream flow restoration. Most of the other speakers were very committed and experienced local residents. The points they emphasized were:

* The importance of the salmon resource
- Locally, it is the foundation of the culture, the primary protein source
- It has provided for the local communities for 1000s of years
- Destruction of the salmon resource would be the destruction of 37 communities that depend on it
- Locally and across the country, this salmon resource is economically important. The assessment estimated an annual value in the neighborhood of $400 Million. One speaker suggested that as the world supply of salmon declines and the demand continues to increase, that may well be an under estimate into the future.

* The impact of a large scale mine
- Even without failure, the infrastructure alone would compromise the health and abundance of the resource
- speakers commented that when man-made structures are built, wildlife around them suffers
- even without a failure, mining would mean roads, landfills, chemicals, stream crossings (and streams frequently change channels, causing washouts)
- with the changing climate, can we really expect the water table to support the water demands of the mine without taking another resource away from the salmon?
- Failure is almost a certainty, considering the history of all other mines, that the waste produced by the mines will need to be contained forever, that this area is one of the most geologically active zones in Alaska (think earthquake), that mistakes happen (why does Homer Simpson keep popping into my head?), that streams change their courses regularly and in doing so, will overwhelm even the most well thought out protections
- Lessons from underestimating other human/environment disasters. Some speakers talked about the Exxon Valdez disaster, the recent gulf oil spill, and the more recent tsunami in Japan. These were disasters that we all thought could never happen and the speakers believe these lessons should make us conservative and humble.
- There is no fix to acid mine leakage. Speakers said that all mines leak.
- The impact of any failure would be enormous considering the interconnectedness of the systems, the interconnectedness of the surface and groundwater (part of what makes this area so rich for salmon also magnifies the risk in the event of a failure), and the sensitivity of the ecosystem
- The risk to the reputation of the fishery was mentioned by several speakers. Much of the marketing of Alaska wild caught salmon refers to the "pristine" habitat. A mine, especially if any failure were to occur, would severely compromise that reputation and therefore the market. Thus, in the case of an accident, even in the unlikely event that the resource itself were not damaged, the market value of Alaskan salmon would be.

* The relative low value of the mine and weakness of reasons to support it
- It will produce only low grade ore
- It can be expected to provide jobs and minerals for only 25-100 years (except for those who will have to guard the toxics in perpetuity)
- Those who want jobs, have them. Many job vacancies are unfilled.

- One of the issues this raises is who gets the jobs. As fishing permits have been leaving Alaska, the direct economic value of fishing has also been leaving Alaska. That is part of why some people are willing to trade away their salmon for the promises of a mine. However, the economic value from fish taxes and business that support the fishing industry remains local. I know I spend 10s of thousands of dollars locally to support my fishing operation. And it isn't clear who would get jobs from a mine, and who would want those jobs. How much talent would be imported? Are there local engineers? Would job vacancies as miners and mine support staff go unfilled by local residents as some of the speakers said other job vacancies do?

* The appeal for help from the Federal Government, given the apparent lack of protection from State government
- Though the Governor and State Senator promise they will not trade salmon for minerals, those testifying see the Alaskan State government as moving forward in cooperation with the mining interests, not with a "Salmon First" policy
- The State has failed to take earlier opportunities to get ahead and in control of the mine efforts, and have generally failed to show support for maintaining the health of salmon streams
- Many speakers asked the EPA to take action on 404C to protect the region. Dick Russell, former fish and game biologist many of us remember as successfully managing the fishery for years urged that the federal government establish the Iliamna Drainage as an International Fish Preserve.

* The testifiers are Pro Development, but anti-Pebble
- Several commented that even though they are pro development and would not normally welcome the EPA, they support the EPA in this effort because the potential gain from the proposed development does not justify the risk to this renewable resource
- Speakers emphasized the distinction between responsible development (both renewable and non renewable) and "malignant" development or development not conducted responsibly. They see the proposed mine as not responsible.

* Lessons from other parts of the country
- Many speakers from across the country here for the summer spoke about the destruction of the salmon (and other) river habitats in California, Oregon, Florida - some directly involved in efforts to restore water quality in those locations. They emphasized the importance of protection instead of restoration. They point out that after 100s of millions of restoration dollars, those systems still are not restored.

*Politics - extension of the comment period
- Some speakers were asking for an extension of the comment period. It seemed that those supporting the mine wanted the extension; those opposing it did not. I think those opposing said that the purpose of extending the comment period was just to give the proponents more opportunity to stop this momentum.
- I don't really understand this issue. Some speakers asked for the extension out of respect for the elders who need time to mull over the findings.
- Other speakers, many of them elders, said they had plenty of time and they wanted the EPA to take action now.

Some quotes or near-quotes I managed to scribble down (I think).
* BBNC Board member: We do not need to trade this resource for a non renewable resource.

* BBNC Board member: Whenever humans touch spawning grounds, the result is fewer salmon... why kill a renewable economy for one that will last only a limited number of years?

* Naknek elder: Waters are very particular

* Processor: Elsewhere, hundreds of millions of dollars be being spent to restore fisheries. This one is ours to protect.

* Cannery worker: [The choice is between] precious metals vs. the basics of life: pure water, pure land. Yupiks don't have the option of turning to farming [if their subsistence resource is destroyed].

* Naknek elder: The State of Alaska is acting like a development partner of Pebble.

* FL water quality expert: [To the EPA reps] You were created in the past to stop this now.

* Naknek elder: I grew up around open pit and underground mines. They have not built a containment pond that doesn't leak.

* Naknek resident: I'm the last guy who would be glad to see the EPA here. You guys are good at one thing: analyzing, investigating, reporting and for that I will stand next to you. This mine, in this location, is bad news. I'm a pro development guy - I believe in lumber and mining. But this mine is wrong.

* Fisherman: Salmon are robust, but their environment is sensitive

* Fisherman: This is an extraordinary treasure on the par of the Grand Canyon... if we let this be threatened by a mine, I believe we have totally lost our way as a human species.

* MS in Environmental Science: Only 404C will stop this mine. There is a temporal element: how will this decision impact future generations? You have the opportunity to stand up for future generations. 404C was drafted just for this project.

* Naknek resident: I would rather melt down the Statue of Liberty for the copper than get it from the Pebble Mine (that one is mangled worse than the others since I didn't get it written down, so it's just from memory)

* Naknek resident: The bottom line is clear: a sustainable fishery in perpetuity or water pollution in perpetuity.

The EPA is taking comments until July 23 (unless the comment period is extended). They can be written and mailed to:
Office of Environmental Information Docket (Mail Code: 2822T)
Docket # EPA-HQ-ORD-2012-0276
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., N.W.
Washington, DC 20460

Or faxed to 202 566 1753 (include docket # EPA-HQ-ORD-2012-0276 on the subject line)

Or provided through written comments online at www.regulations.gov, following the online instructions for submitting comments to Docket # EPA-HQ-ORD-2012-0276 (that's the preferred electronic method) or

Send an email to ORD.Docket@epa.gov including docket # EPA-HQ-ORD-2012-0276 in the subject line.

Some of the additional considerations that occurred to me were whether the economic valuation took into consideration the economic activity that goes into supporting the fishery (like the merchants who supplied the gold rush participants), or somehow, the impact on the world of losing half its salmon supply - the healthy half.

Looking at the pie chart, I'd say this decision will affect anyone who is in any way connected with salmon - like, for instance, you like to eat it.