On December 8th, AWRTA sent the following letter to EPA Administrator, Lisa Jackson. As the letter states, AWRTA does not oppose mining, but we do oppose unwise development that threatens the state’s unique environment and the recreation and tourism industry that depends upon it.
Dear Administrator Jackson:
The Alaska Wilderness Recreation & Tourism Association (AWRTA) respectfully requests that the Environmental Protection Agency (EPA) immediately initiate a section 404(c) process pursuant to 33 U.S.C. § 1344(c) to prohibit specification of those waters of the United States associated with the development of the Pebble Mine in Alaska’s Bristol Bay as disposal sites for dredged or fill material.
AWRTA is a member-led association that represents more than 80 tourism businesses, individuals, and organizations in Alaska. AWRTA advocates for the sustainability of Alaska’s natural and cultural resources, responsible tourism, and tourism planning for communities. Member businesses and partners strive to work with communities to protect and enhance quality of life, provide good jobs and business opportunities, and create strong incentives for protecting Alaska’s wildlife, wilderness, and special places. AWRTA has a keen interest in maintaining the environmental quality upon which its business members depend and is extremely concerned that the proposed Pebble Mine will harm Bristol Bay’s exceptional recreational opportunities and the numerous small tourism companies that depend on the region’s healthy lands, waters, and wildlife.
The vast Bristol Bay watershed in southwestern Alaska is one of the most pristine and scenic ecosystems in Alaska. It supports a robust tourism and recreation industry which is second only to commercial fishing in regional importance. Bristol Bay contains the world’s greatest sockeye salmon fishery and the region’s lakes and rivers support trophy-class rainbow trout and a vigorous sport fishing industry that attracts anglers from around the world. More than 70 sport fishing lodges and hundreds of sport fishing guides operate in Bristol Bay and the adjacent coast of Cook Inlet. Sport fishing contributes $166 million to the regional economy each year. In addition, the Bristol Bay watershed’s abundant caribou, moose, bear, and other wildlife support a multi-million dollar sport hunting and wildlife viewing industry.
The Bristol Bay region contains two exceptional national parks, Katmai and Lake Clark, which are widely known for their spectacular wilderness character and outdoor recreation opportunities. Over 100 commercial tourism companies are authorized to operate in Katmai and Lake Clark, including air taxis, hiking, skiing, and backpacking guides, small boat cruises, kayak rentals, wildlife viewing tours, hunting and fishing guides and outfitters, and nature photography tours. A recent report by National Parks Conservation Association and Katmai National Park and Preserve stated that most of the $50 million spent by Katmai’s 25,000 visitors in 2007 was spent inside the park and in neighboring communities. Visitor spending was found to support 647 jobs, 60% of which are in the five boroughs surrounding the park. Because of the essential economic role that tourism plays in the region, AWRTA is concerned about any activity that may disrupt or degrade the area’s recreational resources.
While the operational details of the Pebble Mine have not been disclosed, the vast scope of the proposed mining operations, associated construction, and support activities makes negative impacts to the Bristol Bay region inevitable. It is apparently undisputed that the Pebble Mine would be the largest open pit mine in North America and would use cyanide to extract copper, gold, and other minerals. The mine is projected to generate 10 billion tons of waste. Mine infrastructure would include massive tailings reservoirs, power generation facilities, an extensive network of roads, a slurry pipeline to Cook Inlet, and a marine terminal. The entire Pebble Mine development would impact an estimated 50 square miles. An industrial development of this magnitude, even if it were to function exactly as planned, would permanently change the pristine Bristol Bay watershed and degrade the area’s spectacular scenery and remote character.
In reality, large-scale hard rock mines are prone to accidents and carry inherent environmental risks. Recent research by Ann Maest, PhD and Jim Kuipers, P.E. found that 76 percent of the hard rock mines studied violated water quality standards, polluting rivers and groundwater. The Pebble Mine would be an exceptionally large operation in a seismically-active area. Drainage from mine facilities, whether from chronic leaks or a catastrophic failure, would contaminate the rich river systems of Bristol Bay with cyanide, copper, and other pollutants, harming fish, wildlife, and the many tourism businesses that now depend on the region’s spectacular scenery and healthy environment.
The Clean Water Act is the nation’s primary line of defense against pollution in our waterways. Under section 404(c), EPA has the authority to prohibit the disposal of dredged or fill materials in waters where there would be an unacceptable adverse effect on, among other things, recreational areas. AWRTA believes it is appropriate and necessary for EPA to preemptively exercise that authority with respect to those waters impacted by the discharge of dredged or fill material from the Pebble Mine. AWRTA does not oppose mining, but we are concerned about inappropriate commercial development that jeopardizes the state’s growing recreation and tourism economy. The Pebble Mine would permanently change the character of Bristol Bay, negatively affect the area’s reputation as a tourism destination, and have significant financial implications for the tourism industry. In short, it poses a clear and unacceptable adverse risk to the region’s unique recreational attributes. AWRTA and its members join the majority of the region’s residents in opposing the Pebble Mine. We urge EPA to immediately exercise its section 404(c) authority under the Clean Water Act.
Sincerely yours,
Dan Oberlatz, Vice President and owner of Alaska Alpine Adventures