Thursday, May 26, 2022

EPA ACTION PROVIDES HOPE FOR BRISTOL BAY WATERSHED

 Yesterday, the U.S. Environmental Protection Agency issued a press release announcing a revised Proposed Determination under the Clean Water Act, which would restrict, and in some areas, completely prohibit, the discharge of dredged or fill material from the so-called “Pebble Mine” into the Bristol Bay watershed

The Proposed Determination is a comprehensive document.  More than 300 pages long, it includes scientific and other information collected over the course of nearly twenty years.  The potential impact of the Proposed Determination is spelled out in its very first paragraph:

“The U.S. Environmental Protection Agency (EPA) Region 10 is publishing for public comment this proposed determination (2022 Proposed Determination) to prohibit and restrict the use of certain waters in the Bristol Bay watershed as a disposal site for the discharge of dredged or fill material associated with mining at the Pebble deposit, a large ore body in southwest Alaska.  EPA Region 10 is exercising its authority under Section 404(c) of the Clean Water Act (CWA)…and its implementing regulations at 40 Code of Federal Regulations (CFR) Part 231 because of the unacceptable adverse effects on anadromous fishery areas in the Bristol Bay watershed that could result from discharges of dredged or fill material associated with such mining.  Development of a mine at the Pebble deposit and such a mine’s potential effects on aquatic resources have been the subject of study for nearly two decades; the 2022 Proposed Determination is based on this extensive record of scientific and technical information.  The scope of the 2022 Proposed Determination applies only to specified discharges of dredged or fill material associated with mining in the Pebble deposit.”

If a Final Determination substantially similar to the Proposed Determination is eventually issued, the long-debated Pebble Mine might finally die a well-deserved death, and the health of the Bristol Bay watershed might be maintained.

And that would be a good thing for, as the Proposed Determination notes,

“Alaska’s Bristol Bay watershed…is an area of unparalleled ecological value, hosting salmon diversity and productivity unrivaled anywhere in North America…The Bristol Bay watershed provides intact, connected habitats—from headwaters to ocean—that support abundant, genetically diverse wild Pacific salmon populations.  These salmon populations, in turn, help to maintain the productivity of the entire ecosystem, including numerous other fish and wildlife species.

“The Bristol Bay watershed’s streams, wetlands, and other aquatic resources support a more than 4,000-year-old subsistence-based way of life for Alaska natives, as well as world-class, economically important commercial and sport fisheries for salmon and other fishes.  The Bristol Bay watershed supports the world’s largest run of Sockeye Salmon, producing approximately half of the world’s Sockeye Salmon…Bristol Bay’s Chinook Salmon runs are also at or near the world’s largest, and the region also supports significant Coho, Chum, and Pink salmon populations.  Because no hatchery fishes are raised or released in the watershed, Bristol Bay’s salmon populations are entirely wild and self-sustaining…

“…The total economic value of the Bristol Bay watershed’s salmon resources, including subsistence uses, was estimated at more than $2.2 billion in 2019…The Bristol Bay commercial salmon fishery generates the largest component of this economic activity, resulting in 15,000 jobs and an economic benefit of $2.0 billion in 2019, $990 million of which was in Alaska…”

Of course, determining what is “good” often turns out to be a matter of perspective, and from the perspective of the Pebble Limited Partnership, the entity hoping to develop the Pebble Mine, the Proposed Determination doesn’t look good at all.  The Washington Post reported that

“the company behind the mine, Pebble Limited Partnership, said Wednesday that it will still work to secure a permit to dig up ore bearing gold, copper and molybdenum, used as an alloy in steel.

“John Shively, the company’s chief executive, said it is ‘ironic’ that the Biden administration would block a domestic source of copper, a crucial material for renewable energy, when it has set a goal of eliminating the nation’s contribution to global warming by the middle of the century…

“Pebble Limited Partnership argues that its hamstrung project would have created 850 direct jobs and generated more than $150 million in state and local taxes a year.

“Shively, the chief executive, pointed to a U.S. Army Corps of Engineers conclusion in 2020 that the mine would have no ‘measurable effect’ on fish populations, noting that foreign miners ‘simply do not have the same environmental standards as we do.’”

Such comments make it clear that the Pebble Limited Partnership has not given up its fight to develop the mine.  As The Washington Post also reported,

“Alannah Hurley, executive director of United Tribes of Bristol Bay, a consortium of tribal governments, called the EPA’s announcement a ‘monumental step.’

“’Our tribes have been asking for this for the last 12 years,’ added Hurley, who is Yup’ik.  But she warned that the federal government has come close to protecting these waters in the past, only to fall short.

“’We’ve been here before,’ she said.”

In fact, the fight to protect the Bristol Bay watershed from the impacts of mining has been a long, harrowing roller coaster ride, which has seen the fortunes of both the fishermen, natives, and conservationists, as well as the Pebble Limited Partnership, wax and wane.  

In 2014, the Obama administration acted to restrict mining in the watershed, but didn’t complete such action before President Obama left the White House.  Pebble Limited Partnership had sued to protect its interests, and one of the Trump administration’s first significant acts was to settle such lawsuit by agreeing to let the Partnership apply for the needed permits.  However, conservationists responded by bringing a lawsuit of their own, arguing that the Trump administration’s settlement violated both the Clean Water Act and the Administrative Procedures Act, which governs federal rulemaking.  After significant legal debate, the trial court agreed that the Trump administration’s actions violated the applicable statutes.

While that was a win for the watershed, it came after two seemingly contradictory decisions by the Army Corps of Engineers.  In July 2020, the Corps released the final environmental impact statement for the permits.  Despite finding that the Pebble Mine would

“permanently remove approximately 99 miles of streambed habitat,”

that

“Direct effects on fish, including displacement, injury, and mortality, would occur with the permanent removal of stream habitat,”

and that

“Stream productivity…would be reduced to some degree with the loss of physical and biological inputs.  These impacts would be permanent, and certain to occur,”

the final environmental impact statement found that “under normal operations,” the activities of the Pebble Mine

“would not be expected to have a measurable effect on fish numbers and result in long-term changes to the health of the commercial fisheries in Bristol Bay.”

It looked as if Pebble Limited Partnership was certain to receive the permits needed to begin operations.  But that was before the Partnership found itself publicly embarrassed after environmental advocates, posing as potential investors in the Pebble Mine, recorded company representatives admitting that they were planning a much larger operation than the one described to the Corps of Engineers, which might continue for 160 years, instead of the publicly claimed 20, and double the mine output originally claimed.

It also turned out that a lot of important Republicans, including Donald Trump, Jr. and Trump apologist and media personality Tucker Carlson, liked to fish for salmon in the Bristol Bay watershed, and weren’t in favor of the Pebble Mine.

Whether or not such factors came into play, the Army Corps of Engineers ultimately denied the needed permits, saying that the Pebble Mine

“does not comply with Clean Water Act guidelines.”

The Pebble Limited Partnership appealed that decision to the Corps’ Pacific Ocean Division, which is headquartered in Hawaii.  Such appeal is still pending.

Thus, the Proposed Determination, while encouraging, does not guarantee that the Pebble Mine will be defeated.  The pendulum, which has already swung so many times, could still swing again.

The Marine Fish Conservation Network recently released a “Waterside Chat,” in which Tom Sadler, its deputy director, interviewed Sam Snyder of the Wild Salmon Center and Scott Hed of Businesses for Bristol Bay, and solicited their views on the Proposed Determination and what comes next for Bristol Bay.

As one might expect, both Mr. Snyder and Mr. Hed were cautiously optimistic about the future, with the emphasis on “cautiously.”  Both recognized that, with the issuance of the Proposed Determination, the Bristol Bay watershed is in about the same place as it was in the closing days of the Obama administration, which didn’t finalize the protections in time to prevent the Trump administration from undoing them.  

While the 2022 Proposed Determination is somewhat more comprehensive than its 2014 counterpart, right now, it’s just as unfinished.

As Mr. Hed observed,

“We’re happy that we’re back on track, but we can’t be satisfied with being back on track.  We’ve got to push, push, push until we reach our goal.”

He also noted that, if conservation efforts fall short of their goal once again, the consequences for the watershed could be dire.  While Pebble Mine is getting all of the media attention, about 800 square miles of mining claims have been filed for Bristol Bay region; should the Pebble Mine be approved, and the related infrastructure, including roads and a power plant large enough to supply the electrical needs of the city of Fairbanks, be built, such development will encourage others to develop other mines, which collectively will have a catastrophic impact on the watershed.

Fortunately, the conservation goals are now within sight.  The EPA will be accepting comments on the Proposed Determination through July 5, and will be holding three public hearings, including one Zoom hearing on June 16, which will give the public plenty of opportunity to show their support.

Once the public comment period is over, the EPA will draft and, eventually, issue a Final Determination regarding the discharge of dredged and fill materials into the Bristol Bay watershed.  It is critical that such Final Determination be issued well in advance of the 2024 election, to prevent it being blocked by the next administration, and to prevent Congress from overriding the regulatory action pursuant to the Congressional Review Act.

But assuming that the EPA can act with the needed dispatch, and also assuming that the courts do not intervene, there may finally be a real chance that meaningful protections for the Bristol Bay watershed will be put in place.  The Pebble Mine may, at long last, be defeated.

 

 

 

 

 

 

 

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