Key components of science include that it be objective, transparent, and reproducible, as well as passing external review and critique by a panel of experts or peers. As potential impacts of Pebble Mine on Bristol Bay's fishery resources are revealed and discussed, Alaskans should insist on full disclosure of scientific methods, data, and results in addition to critical assessments of related science by a jury of peers.
The EPA recently released a draft watershed assessment examining potential impacts of mining on salmon ecosystems of Bristol Bay. The assessment, undertaken in response to requests from tribal governments, Native and village corporations, and fishing groups, provides the first objective, transparent public framework from which Alaskans can define and evaluate mining risks to Bristol Bay fisheries.
Experts who wrote the assessment relied on the best available science, including peer-reviewed publications, agency reports, industry reports and non-governmental research. The geographic scope is appropriate because mine leases encompass over one-half million acres in the Kvichak and Nushagak drainages and the scale of mining could exceed ten billion metric tons. Mine development scenarios used to estimate risks are conservative and based on industry scenarios for Pebble filed with the Canadian Securities and Exchange Commission. This week, an expert peer review panel will scrutinize and critique EPA's draft assessment in an ongoing transparent public process.
Compare EPA's objective scientific approach to that of Pebble Limited Partnership, which in January released 30,000 pages of "science" in their Environmental Baseline Document. While the select information released created a good public relations moment, the scientific community was not impressed. Scientific methods, data, and results were not fully disclosed and therefore study results cannot be reproduced and verified. Because Pebble's studies fail to follow central tenets of science, they could not pass external scrutiny and criticism by a jury of peers. In fact, Pebble considers their data on our fish proprietary and will not submit their "science" to external peer review.
Deeper analysis of Pebble's science is crucial when considering large-scale, metallic sulfide mining in headwaters of the world's largest sockeye salmon fishery. Pebble claims their leases support few salmon and a glossy "science" summary sent to Alaskans early this year show an "index" of less than 35,000 spawning sockeye salmon in the study area. However, review of their baseline studies indicates Pebble never determined the total number of spawners in their claims. In fact, the "index" used by Pebble is a gross underestimate of the total number of spawning salmon there and is based on imprecise science that, as presented in the environmental baseline, would not pass peer review.
Despite the fact that the Alaska Department of Fish and Game has obtained scientifically accurate and precise salmon counts to Bristol Bay rivers for more than 50 years, it appears that the Pebble Partnership chose a "cost-effective" method to count spawning salmon in their claims. Their method, Mean Index Count, applied once to remote Canadian coho streams, averages intermittent aerial counts of salmon. Pebble's aerial counts are biased in that salmon abundance is underestimated due to vegetation, glare, deep water etc. and because most tributaries were not surveyed although salmon spawn in tributaries. These sources of bias cause aerial counts to underestimate (potentially severely) salmon spawning at Pebble.
Averaging aerial counts for the "index" further reduces the apparent number of spawning salmon giving the false impression few salmon spawn in the study area. These "index" numbers contrast sharply with total abundance estimates made by Pebble's first fishery consultant (who was replaced by an Outside firm) indicating hundreds of thousands of salmon spawn there.
When evaluating projects like Pebble in watersheds like Bristol Bay, it is essential that the science is rigorous and peer reviewed. Pebble's work appears to be neither. I am grateful to EPA for their objectivity, transparency, use of best available science, and for subjecting their scientific assessment to external review. They are inviting discussion and evaluation of their assessment amidst an open jury of peers. As Alaskans, we deserve nothing less.
Carol Ann Woody, an 18-year federal fisheries scientist, now is a fisheries consultant for tribes and nonprofit organizations. She is a past president of the American Fisheries Society Alaska Chapter and current member of the society's environmental concerns committee. She provided critical review of the EPA's Bristol Bay watershed assessment, and is scheduled to testify at this week's peer review hearings.