Action Alert • Public Comment Period Extended

The Draft Environmental Impact Statement on the Pebble Project

RDC Testimony

The U.S. Army Corps of Engineers (USACE) has released the Draft Environmental Impact Statement (DEIS) for the Pebble Project and has extended the public comment period to Monday, July 1, 2019.

RDC firmly supports due process and the rule of law. Alaska utilizes a well-established permitting and review process, with multiple opportunities for public input, and review by local, state, and federal agencies. RDC believes the permitting process is the best place to make decisions about the merits of development projects in Alaska. 

Alaska has enjoyed the benefits of mining for well over 100 years, with the last several decades seeing new innovations and advancements for protecting the environment. Alaska has stringent regulations to protect its lands and waters. As the Alaskan economy is dependent on natural resource development, including mining, it is vital to have predictable and efficient federal and state permitting processes that are based on sound science. 

Project proponents have incorporated a number of alternatives to the newly-proposed mine plan. The footprint of the facilities has been reduced to minimize the impact to areas of known subsistence use, waterbodies, wildlife, and areas of cultural significance. The project plan has eliminated the need for a permanent waste rock storage facility, a key consideration for the EIS to include. 

The DEIS is an early step in a very long process, which will also include multiple and ongoing opportunities for public input. 

Action Requested:

The public comment process is an important step and your voice is needed. Please make your support of responsible development, the diversification of Alaska’s economy, and the permitting process for all projects heard. 

Submit onlinehttps://pebbleprojecteis.com/or https://pebbleprojecteis.com/publiccomments/neweiscomment

Send an email to:[email protected]

Mail to:
Program Manager
U.S. Army Corps of Engineers
645 G Street, Suite 100-921
Anchorage, AK 99501

Points to consider in your comments:

  • Project proponents have greatly reduced the projected footprint of the proposed mine, and have mitigated potential impacts in a way that will allow the mine to be responsibly developed. Further, there will be no major mine facilities in the Upper Talarik/Kvichak Rivers drainage.
  • The project is in a region of Alaska where few other economic opportunities exist. In addition to jobs and economic benefits, the project is expected to provide an estimated $1 billion to the State over 20 years.
  • Project proponents have responded to public concerns surrounding the mining process and have committed to no use of cyanide for gold recovery.
  • Every project, no matter the size or location, should have an opportunity to be reviewed under existing legal processes. In the case of mining, there are more than 60 major permits and hundreds more from local, state, and federal agencies that must be successfully obtained. If the process determines a project as designed cannot protect the environment and other resources, it will not advance. The process will not permit one industry or resource to advance at the expense of another.
  • The Pebble deposit is not located on federal land, nor inside a refuge or park. It is located on state land specifically designated for mineral exploration. 
  • The State of Alaska depends on the responsible development of natural resources on its lands to diversify and support its economy. As our resource revenues continue to decline and our state faces serious budget challenges, Pebble could be the first step to turn the state around – letting investors worldwide know Alaska is open for business.
  • The project will create much needed job opportunities which will likely lead to reduced out-migration, helping to maintain rural schools and culture, including traditional ways of life. Further, the DEIS highlights that project development could help the Lake and Peninsula Borough through revenue going to the borough and help maintain population numbers to avoid school closures.
  • Development in Alaska, both community and resource, have long occurred while responsibly protecting the environment. In Alaska, we do it right.
  • The plan describes how Pebble will use two water treatment plants to ensure discharge meets Alaska’s criteria for water prior to release and will use a sophisticated water management plan that will strategically discharge water in all three nearby streams to benefit fish habitat.
  • The fate of a project, including Pebble, cannot be rationally decided without consideration of the full social, economic and environmental impacts of the project. This information will be developed through the rigorous NEPA process. 
  • Project proponents have studied the environment to design a plan that best coexists with the surrounding elements. These studies have placed significant emphasis on analyzing the fish and water resources in and around the proposed project. These studies must be fairly evaluated and considered via the EIS review process.
  • Modern mining techniques are constantly improving and technology will only improve, and best management practices will be applied. Alaska has a good environmental track record with mining that coexists with fish and wildlife resources.
  • The resources from this project would likely be used for the growing worldwide demand for the products and technology related to renewables and the green economy.
  • The mineral deposit at Pebble could be a vital resource for increasing Alaska, and America’s, technology and energy resources. 
  • With the growing worldwide consumption and dependence upon technical products powered by critical minerals such as copper, the expanding demand for renewable energy technologies, and the development of projects with strategic national significance, the Pebble deposit has the potential to generate hundreds of millions of dollars in annual economic activity for Alaska, as well as significant revenues for state and local governments.
  • The tailings storage facility design has enhanced safeguards including a flow through design to prevent the buildup of water in the facility and added structural stability to the embankments. Additionally, pyritic tailings will be lined for storage during operations and returned to the pit for subaqueous storage at closure.
  • The project is expected to employ up to 2,000 people during the construction phase, and 850 people full time and all year during the 20 years of operations.

Specific points from the DEIS to consider:

  • The DEIS highlights the long success and Alaska’s experience with co-existence between Alaska’s resource projects and fishing.
  • The DEIS states the proposed project would not reduce returning adult salmon to the Kvichak and Nushagak river systems.
  • The DEIS states a catastrophic failure of the tailings facility is extremely unlikely and that there would be no population impacts for fish from the tailings release scenarios evaluated.
  • The DEIS found there would be no downstream impacts to flows from the pit during operations and post closure. 
  • The DEIS describes that project benefits would be more apparent in the small, rural communities closest to the mine site where even small changes in their economies could have a measurable impact on their overall health and well-being.
  • The DEIS notes that overall economic and health benefits will be substantial.

 Comment Deadline Extended to Monday, July 1, 2019