Scientists Back EPA's Bristol Bay Assessment

Samuel Snyder, PhD

Alaska Conservation Foundation

Anchorage, Alaska

In many ways fly fishers and trout enthusiasts are streamside scientists. Fly fishing at its heart requires basic streamside ecological knowledge.  Beyond helping one pursue fishing more effectively, streamside ecology leads anglers to speak up for their favorite backyard streams or the places on the fly fishing bucket list, such as Bristol Bay, Alaska.

Because of that intricate relationship between fishing, science and conservation, Trout Unlimited places science at the heart of its mission and strives to apply "the very best information and thinking available" when addressing conservation issues related to trout and salmon.

From that position, Trout Unlimited has been for the last several years calling on the United States Environmental Protection Agency to use its authority to protect Bristol Bay.  In doing so, TU joined its voice to those of Alaska Native tribes and communities, commercial fishermen, and many others seeking to stop the potential development of the proposed Pebble Mine.  TU has long believed that the science was crystal clear, that despite what the Pebble Limited Partnership says,  large-scale mining and the great salmon ecosystem of Bristol Bay cannot exist.

Well, the science is now abundantly clear.

On January 15, 2013, EPA released the FINAL Assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay, Alaska. In that document, which took over three years, two rounds of public comment, two rounds of peer review to complete, EPA came to that clear conclusion.  In the Watershed Assessment EPA found that at a minimum Pebble would directly remove over 94 miles of streams, would directly destroy over 5,000 acres of wetlands, lakes, and ponds. EPA found that even with the best technology, Pebble would have a difficult time capturing and treating water  degraded by chemicals, metals, and possible acid mine drainage. EPA rightly acknowledged the shortcomings of the greatest technology out there and the near impossibility of mitigating these impacts over time. 

And because of that they underscore the possible impacts large-scale mining would not only have on the salmon-based ecosystem, but also on the economies and communities dependant upon Bristol. As the Assessment  stated, “Because salmon-based subsistence is integral to Alaska Native Cultures, the effects of those salmon losses go beyond the loss of food resources. If salmon quality or quality was adversely affected, the nutritional, social, and spiritual health of Alaska Natives would decline.” (ES-26). Let’s recall, too, that there are well over 1000 fly fishing and sport-based jobs in Bristol Bay as a part of a $1.5 billion a year industry of sport and commercial fishing.

Shortly after the final Assessment was released, Alaska Senator Mark Begich took a position  “based on science,” that Pebble was the “wrong mine” in the “wrong place,’ that Pebble was “too big.” He felt comfortable making that position because EPA had taken every precaution to ensure that the Watershed Assessment represent the most comprehensive available science regarding large-scale mining in salmon watersheds. The report draws on hundreds of peer-reviewed published reports and scientific findings.  Furthermore, it draws directly on documents prepared for and by Northern Dynasty Minerals (NDM), the company seeking to develop the Pebble deposit, and that during two rounds of peer review, national experts weighed in, improving the scope, structure, and content of the Assessment in a manner that well exceeds the requirements of traditional peer review processes.

The commentary from that peer review process is particularly insightful. The Final Assessment was lauded as “state of science” by Oregon State University toxicology expert William. Improvements were commended as “quantum leaps” by University of Idaho hydrologist Charles Slaughter. Phyllis Weber Scannell, who has extensive experience with Alaska’s mines, not only found the mining scenarios in the Assessment to be plausible, but noted that EPA presents “a realistic summary of possible mitigation measures and their value in the subject area.” Fisheries biologist Dennis Dauble insisted that “this document should serve as a model for completeness. The authors should be collectively proud of their accomplishment.” Finally, Roy Stein, chair of the Peer Review process, explained that he was impressed with how EPA took the time to work with the peer review team over the two peer review periods, and that “EPA has struck just the right balance with regard to summarizing the state of the probable mine impacts on the ecological and cultural resources of the Bristol Bay Watershed.” 

Well as if this isn’t enough, today I joined  over 360 nationally recognized scientists who have signed  a letter that not only commends EPA for its  work on the Watershed Assessment, but also urges EPA to use its  authority under the Clean Water Act to protect Bristol Bay.

One doesn’t need a PhD to know that large-scale mining in Bristol Bay poses a serious threat to Bristol Bay, the salmon, and the trout of that system.  But we can take additional comfort in knowing that the national science community is clearly behind EPA and the communities seeking to protect their homes, their livelihoods, and the dreams of anglers around the world.


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