Comment Letter on Scoping for the Pebble Project EIS

June 29, 2018

Program Manager, Regulatory Division
U.S. Army Corps of Engineers
P.O. Box 6898
JBER, AK 99506-0898

Submitted via

To Whom It May Concern:

The Resource Development Council for Alaska, Inc. (RDC) is writing to comment on the U.S. Army Corps of Engineers (Corps) Public Scoping for the Pebble Project Environmental Impact Statement (EIS).

RDC is a statewide business association comprised of individuals and companies from Alaska’s oil and gas, mining, forest products, tourism and fisheries industries. RDC’s membership includes Alaska Native Corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.

RDC’s priorities include promoting and defending the integrity of the permitting process and advocating for predictable, timely, and efficient state and federal permitting processes based on sound science and economic feasibility. It is vital Alaska’s rigorous permitting process is predictable and stable as our resources compete for investment around the globe.

RDC urges the Corps to include the following in the EIS scoping of the proposed project: the social and economic benefits to the region, state, and nation; the demand for the resources at the deposit, including their use in renewable technology and energy; Alaska’s constitutional requirements; Alaska’s extensive and thorough permitting process; and the alternatives to a newly-proposed mine plan put forward by project proponents.

Social and economic benefits to the region, state, and nation

RDC urges the Corps to consider the family-wage jobs and economic benefits to the region, Alaska, and the nation. The project is expected to employ up to 2,000 people during the four-year construction phase, and 850 people during the 20 years of operations. 

The Pebble deposit is located in Southwest Alaska, approximately 200 miles west of Anchorage, nearest to the communities of Iliamna, Newhalen, and Nondalton. The project is located in a region of Alaska that experiences higher unemployment rates and has few other opportunities. A project like this is a rare opportunity to positively impact the local economy where the option for meaningful employment is scarce.

These new job opportunities could reduce out-migration, which could help maintain rural schools and allow people in the region to participate in subsistence activities.

Further, RDC urges the Corps to consider the benefits of the jobs not only in Alaska, but across the nation, that will likely come from development of Pebble. The prospect is one of the most significant mineral deposits in the United States, with the potential for billions in economic activity and thousands of jobs.

The demand for the resources at the deposit

RDC urges the Corps to fully weigh the benefits as well as the need for the mineral resources at Pebble. These minerals would likely be used for the growing worldwide demand for the products and technology related to renewables and energy.

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 in annual economic activity for Alaska, as well as significant revenues for state and local governments.

Alaska’s Constitution

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. Article VIII, Section I of the Alaska Constitution mandates “the settlement of Alaska’s land and the development of its resources by making them available for maximum use consistent with the public interest,” to encourage economic prosperity for Alaskans. RDC urges the Corps to fully consider Alaska’s sovereignty and constitutional requirement to responsibly develop Alaska’s natural resources.

Moreover, the State of Alaska selected this land specifically for its mineral resource potential. The deposit is not located on federal land, nor inside a refuge or park – it is located on state land 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.

Alaskans have the greatest stake in seeing that any and all development is done in a way that protects resources, including the environment. RDC believes it can be done, because it’s already being done.

Alaska’s extensive and thorough permitting process 

RDC members firmly believe in 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.

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.

RDC urges the Corps to consider and acknowledge Alaska’s stringent permitting process and a track record built upon modern technology, regulations, and laws to protect the environment. In fact, the Corps should consider the project proponents record of environmental safety. According to public records, the project has been inspected by the State 57 times since 2003, and regulators have found the project to be in compliance.

The activities at the Pebble deposit are no different than exploration activities at other sites throughout Alaska and no different from previous activities undertaken at the Pebble site. 

The alternatives to a newly-proposed mine plan

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. 

Project proponents have studied the environment to design a plan that best co-exists 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.

To date, no thorough evaluation of the technical information has been undertaken by a regulatory agency. The EIS should review all data gathered by the company as part of a rigorous and complete analysis of the project’s plan. This should include how the company can responsibly operate a mine and balance this with environmental protection.

More than a decade of environmental research has been conducted since exploration ramped up in the early 2000s. Extensive environmental baseline data collection and geotechnical programs have also been done. Further, under the new plan, all water would be captured and carefully treated prior to discharge. And water discharge would be done strategically to enhance fish habitat – another matter the Corps should acknowledge in its review.


RDC urges the Corps to work in an efficient manner to rationally and scientifically determine the merits of the project, with consideration of the full social, economic, and environmental impacts and benefits. Now is the time to encourage responsible resource development in Alaska, and in America, and to encourage investment in projects by way of a predictable, timely, and efficient permitting process at the state and national level. 

In addition, this is an early step in a very long process, which will also include multiple and ongoing opportunities for public input. Thank you for the opportunity to provide comments on the scoping for the Pebble EIS.


Resource Development Council