The Environmental Impact Statement, or EIS, process and the document for Pebble mine by the Corps of Engineers are deeply and fatally flawed. I spent my entire professional career of 42 years working for the Corps, Alaska Department of Fish and Game, U.S. Fish and Wildlife Service and, as a consultant, on review and regulation of large and small development projects in Alaska. I worked on roads, oil and gas drilling and development, pipelines, refineries, utility lines, ports, boat harbors, hydroelectric projects, military projects, and many large and small mines.
During my career I was directly involved with preparation of several dozen EIS’s and I reviewed dozens more. Pebble is the largest and potentially most destructive project I have ever been involved with. The environmental resources at risk in Bristol Bay from Pebble’s development and operations are the most precious, unique and susceptible to long-term and irreversible damage of any project in my experience. I have not seen an EIS as poorly written and inadequate as the Pebble draft EIS.
Although there are many issues to be concerned about, I want to focus on Pebble’s environmental baseline studies, which were begun and completed years before Pebble applied for a Corps permit. Environmental baseline studies are intended to show the current state of the environment in a project area so that potential project effects can be predicted and measures to mitigate the harm can be proposed. They also serve to guide long-term monitoring during and following operations. Pebble’s study designs for baseline studies were inadequate and not based on best-available scientific methods.
This was because Pebble did not want to know or to ultimately divulge to the public the actual scope, importance of and risk to fish, wildlife, water and subsistence resources. I call their studies the “illusion of good science.” Others have called it “junk science.” If they had conducted proper studies, the results could have been used to oppose the project. Scientific fact would have undermined Pebble’s hollow claims of “no harm.” Pebble repeatedly said its studies were “state of the art” and cost millions of dollars. However, state and federal agencies said over and over that Pebble’s study objectives and methods were not statistically defensible or repeatable, and their financial cost was irrelevant.
Pebble’s baseline environmental studies were not designed to or intended by Pebble to tease out the differences between natural, long-term environmental change and long-term acute or chronic effects of a mine, as recommended by the agencies. Pebble artificially limited the scope, time and geographic extent of their studies. State and federal agencies repeatedly suggested ways for Pebble to design scientifically defensible studies. Those suggestions were largely ignored. If the baseline environmental science is bad, Pebble cannot be held accountable for the damage it will do. Independent science clearly shows Pebble mine will result in disastrous long-term and irreversible effects on fish, wildlife, air, water and, most importantly, local people and their subsistence way of life. This may not happen in my lifetime, but it will happen.
This then is the first major flaw of the Corps’ EIS process. The Corps has not independently evaluated the inadequate baseline environmental information they were presented by Pebble. Rather, they accepted it and used it to develop their flawed draft EIS. The remedy for this fatal flaw is for the Corps to begin again. First, by conducting an expert and independent review of the Pebble baseline environmental studies, and then requiring Pebble to complete scientifically meaningful studies. This may take years, but only then should the Corps accept an application and begin an open and transparent EIS process.
Agencies like the U.S. Fish and Wildlife Service, the Department of Interior, and the Environmental Protection Agency have noted numerous EIS deficiencies. For instance, the Department of Interior said the draft EIS “does not fully discuss the potential impacts of the proposed mining activity” and “lacks a number of important analyses that are necessary to adequately assess the project.” The Interior Department also said the draft EIS “was so inadequate that it precludes meaningful analysis.” The Corps has no responsible choice except to begin the Pebble EIS again.
Phil Brna is a retired wildlife biologist living in Anchorage.
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