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EPA peer review: Evaluating risks to Bristol Bay cultures

Carey RestinoThe Arctic Sounder
Eric Adams photo

In the contentious debate over the prospect of developing a massive gold, copper and molybdenum mine in the Bristol Bay Region, few opportunities are available to hear objective voices about the science being presented by those both for and against the proposed Pebble Mine.

The Pebble Prospect has yet to submit a permit for review by either state or federal agencies. But in 2011, the Environmental Protection Agency began an assessment of the area's watershed and the impacts a large-scale mine could have on the area's people, environment and especially on the world-class salmon run in Bristol Bay.

This winter, the EPA released the Peer Review Report to its Draft Bristol Bay Watershed Assessment. The report lists the 14 questions posed to the 12 peer reviewers, who encompass a variety of expertise, and who all volunteered their time to review the EPA's science. Here's a selection:

Does the assessment appropriately characterize risks to wildlife and human cultures due to risks to fish? If not, what suggestions do you have for improving this part of the assessment? Are significant literature, reports, or data not referenced that would be useful to characterize these risks, and if so what are they?

As with other sections of the EPA's draft assessment, scientists wanted more information about the potential risks to wildlife and human cultures due to risks to fish. The impacts to Alaska subsistence users was one of the main areas of testimony at EPA's public hearings last summer, and defining the fact that loss of subsistence goes beyond loss of a food source was a concern for at least one of the scientists.

"Clearly the impacts to subsistence are not just lost food sources, but loss of healthy subsistence lifeways, loss of practices, loss of cultural connections to the past, loss of connection to specific places, loss of teaching and learning, loss of sharing networks, loss of individual, community, and cultural identity, among others as detailed in Appendix D," Courtney Carothers, assistant professor in the School of Fisheries and Ocean Sciences at University of Alaska Fairbanks, wrote. "This point could be made more forcefully. As noted above and detailed in the specific comments below, subsistence is framed at times in the report as primarily important for physical health and economic necessity. The cultural, social, psychological, and spiritual aspects of subsistence livelihoods should also be consistently highlighted."

Roy Stein, professor emeritus at The Ohio State University in Columbus, Ohio, asked for information about other times in the history of Native cultures when salmon were reduced. He also asked why the only risks reviewed came via salmon-mediated impacts. What about the impacts of the mine through jobs, he asked.

"Surely, there exist situations where salmon have declined or have been reduced by development/ exploitation (the Fraser River, perhaps?) where subsistence by Native Alaskans was historically paramount," Stein writes, asking for information about how they responded to those impacts.

Others noted that there was little text in the assessment regarding recreational anglers, commercial fishermen or subsistence users other than Native Alaskans. Paul Whitney suggested that the assessment revise its question, deleting the words "due to risks of fish" and separating the risk analysis of wildlife and human culture.

11) Does the assessment appropriately describe the potential for cumulative risks from multiple mines? If not, what suggestions do you have for improving this part of the assessment?

While several scientists expressed satisfaction with the reports analysis of cumulative risks from multiple mines, David Atkins, principal hydrologist and owner of Watershed Environmental, LLC, said the scenario needed more information about the extensive road network that would be required to support mines in the area, as well as camps associated with the project, and invasive species that follow this scale of development.

Carothers noted that while the report suggests the impact of multiple mines would increase the cumulative impact on various areas of the environment, the cultural assessment's conclusion is that the effect on humans would be primarily "direct and indirect loss of food sources."

"As the number of large-scale mines increases in this region, the entire subsistence way of life would come under threat," Carothers writes. "This would be a much larger impact than lost food sources."

Others, including Dirk van Zyl, professor and chair of Mining and the Environment at the Norman B. Keevil Institute of Mining Engineering, University of British Columbia, opined that the assessment cannot describe the potential for cumulative risk without more information about other proposals for developing potential resources in the area.

Are there reasonable mitigation measures that would reduce or minimize the mining risks and impacts beyond those already described in the assessment? What are those measures and how should they be integrated into the assessment? Realizing that there are practical issues associated with implementation, what is the likelihood of success of those measures?

Many of the reviewers noted that mitigation measures described only consider "good" mining practice, and that any mine in the Bristol Bay watershed would almost certainly require innovative and state-of-the-art approaches to construction and mitigation measures.

"It is highly likely that for mines located in the Bristol Bay watershed, conventional engineering practices would not be sufficient," wrote Atkins.

Others said examination of the measures was outside the scope of the assessment.

"The purpose of this assessment is not to identify mitigation measures," wrote John Stednick. "This suggests that things can be fixed by mitigation. Risks were identified for a variety of situations, and preventative measures would better address the mining."

Stein wrote that in some cases, failures are underestimated in his opinion and mitigation measures would quickly become limited in situations such as a complete tailings storage facility failure, which is reviewed at length.

"Mitigation under these circumstances is impossible in my view," Stein wrote. "Given this scenario, I was surprised that the impacts were only assessed 30 km downstream of the (tailings storage facility) failure; is this realistic? I think not, given what we know of other mines."

Does the assessment identify and evaluate the uncertainties associated with the identified risks?

The issue of mine scenarios being hypothetical came up again in this area of the review. Dennis Dauble, adjunct professor at Washington State University, Tri-City branch campus in Richland, noted that the long list of uncertainties identified in the report leads one to speculate, "so what do we know?"

"Not being familiar with the formal risk assessment process, it appears this 'assessment' (which is loosely based on a risk assessment framework), falls short of providing something with any degree of certainty," he writes.

Others said they found the section disconcerting.

"Certainly, the authors have worked hard to present an accurate portrayal of the impact of a large-scale open pit mine in the watershed of Bristol Bay," Stein said. "Even so, upon review of the list of uncertainties with regard to this effort (pages 8-10 to 8-13), I conclude that we know little of what the impact of this mine will be in any quantitative sense."

Are there any other comments concerning the assessment, which have not yet been addressed by the charge questions, which panel members would like to provide?

Scientists again turned their sights on the hypothetical nature of the mine presented, as well as the intent of the assessment as major issues that needed more work. Others called for more emphasis on the impacts of climate change, road creation, and potential impacts to species beyond salmon.

The last comment in the analysis, submitted by Paul Whitney, is a semi-retired consultant in Portland, Ore., highlighted the difficulty of reviewing complicated information about a place as unique as the Bristol Bay watershed.

"My only regret in this review is that I could not visit the proposed mine site and watersheds during the summer and the winter," Whitney said. "I have flown over the Bristol Bay watersheds while working for other mines in Alaska, but I have never been on the ground in these watersheds. I am concerned that if I did visit the proposed sites my assessment points above might change and even change dramatically. It is hoped that all the EPA staff and biologists working on the assessment are able to visit the watersheds in the summer and winter."

The preceding article was first published by The Bristol Bay Times-Dutch Harbor Fisherman. Contact the editor at editor(at)thedutchharborfisherman.com. Republished with permission.