Comment Information

It is essential that as many people as possible submit comments to the Army Corps of Engineers by July 1, 2019.

THIS IS THE LAST CHANCE WE HAVE TO IMPACT THE PERMITTING PROCESS.

Please review the list below of the major deficiencies in the Draft Environmental Impact Statement for Pebble Mine and send your comments to the following email address:

drafteis@comments.pebbleprojecteis.com

TEXT FOR COMMENTS TO THE ARMY CORPS:

The new Pebble Partnership mine proposal and associated infrastructure now stretch from the Bristol Bay side of the mountains to the Cook Inlet side. The application submitted to the Army Corps of Engineers includes a deep water port at Amakdedori beach and road that stretches across critical brown bear habitat from near Kokhanok, AK to Amakdedori beach. This proposed road comes within 250 feet of the McNeil River State Game Refuge boundary and the port facility is one bay north of McNeil River. Due to this proximity, it is CRITICAL that the Army Corps of Engineers do the work of gathering data to support their claims in the Draft Environmental Impact Statement.

McNeil River State Game Sanctuary was established by the Alaska State Legislature in 1967 to preserve the unique congregation of brown bears at McNeil Falls. When under-regulated, human behavior began to impact the bears and in the early 1970’s a lottery system for access was put into place to limit and structure human presence in the area.

This carefully regulated system and the practices developed at McNeil River SGS are the foundation for the modern bear-viewing industry.

The proposal to put a deep water port so close to the the boundary of the McNeil Refuge would have negative impacts on both the bears in the area that make up this unique congregation and to the visitors to the the Sanctuary and Refuge who rely on the strict safety practices put in place by the AK Department of Fish and Game.

ACTION ITEMS TO INCLUDE IN YOUR COMMENTS:

  • Substantial impacts on McNeil area brown bears have been ignored in the Army Corps of Engineers Draft Environmental Impact Statement (EIS).  Even though the Refuge boundary is as close as 250 feet, the Corps of Engineers states “McNeil River State Game Refuge and Sanctuary are outside of the EIS analysis area.”

Bears have extensive ranges and do not recognize lines on an EIS map. The Corps must consider impacts on McNeil bears for the entire area including the McNeil River State Game Sanctuary and Refuge.

  • The Corps denied requests by the Alaska Department of Fish and Game for missing draft EIS scientific information on bear populations and movements because “it is not necessary or essential to disclose the reasonably foreseeable significant impacts”

“Reasonably foreseeable significant impacts” are precisely why the Corps must provide more detailed scientific information on potential risks and impacts to bears.

  • The Corps says the information requested by ADF&G “would not be essential to make a reasoned choice among alternatives”.

There are several “Alternatives” in the Draft EIS – The one we support is the “No Action Alternative”.  The requested detailed scientific information denied by the Corps is absolutely critical to identify the impacts between proceeding with mine, road and port complex versus the No Action Alternative.

  • The Corps says they will address and mitigate impacts on bears in a “Wildlife Management Plan.”  This “Plan” does not exist and will only be developed by Pebble “as part of a later permitting process prior to commencement of construction”.

The so-called “Wildlife Management Plan” should have been required and made available as part of the Draft EIS for public review.  Yet it does not exist. It is a finger in the eye of the public’s right to know that, even now, it is not available.

By these, and other, biased actions, the Corps has revealed itself as no more than an agent for the international Pebble Partnership, not Alaskans, in pushing the EIS process through.

OTHER SPECIFIC COMMENTS TO INCLUDE:

Possible direct effects on bear population:

  1. It is likely that there will be increased contact between bears that use McNeil River and humans outside of the McNeil River program that could result in food conditioning of bears or direct mortality of bears by intolerant humans.
  2. The road and resulting traffic would fragment habitat and and bisect a travel corridor potentially deterring bears utilizing McNeil Refuge and Sanctuary.
  3. Industrial facility in the heart of bear country increases the likelihood of bears becoming food conditioned thus reducing safety for visitors in the sanctuary and refuge.
  4. Increased noise levels from construction might deter bears from coming to McNeil River Falls.
  5. Dredging off Amakdedori Beach might affect schooling of salmon or Dolly Varden before they run up Chenik Creek, McNeil River and Mikfik Creek. McNeil bears are known to eat fish in these as well as other stream systems in the area.
  6. Noise from increased large vessel traffic (boats moving product from the terminal at Amakdedori to the Kenai Peninsula) might affect bear behavior and use of McNeil River by bears.

Possible effects of disturbance and displacement of bears from increased noise or perturbation of food resources in the areas surrounding McNeil River:

  1. Displacement of bears could reduce the number of bears using McNeil River and preventing access to a critical natural food source.
  2. Direct mortality of bears from humans would affect the immediate population of bears using McNeil River.
  3. Because the viewing program at McNeil River is structured around consistency of human behavior in the Sanctuary and especially around bears, many bears using the area have become habituated over time. The habituation extends into subsequent generations, as young bears typically follow their mothers’ feeding and home range patterns. Thus, a less immediate though more serious decrease in bears using McNeil River could also be a result of this project.
  4. Exposure to human food waste at industrial site could lead to food conditioning of bears.
  5. Food conditioning of bears so close to a bear viewing area would lead to unsafe conditions for bear viewers in the McNeil River State Game Sanctuary and Refuge.

Direct or indirect effects of project on bears that use McNeil would also affect the McNeil River Visitor Program:

  1. Increased airborne noise could diminish the high value visitor experience now associated with McNeil River.
  2. Increased waterborne noise could affect distribution and abundance of marine fauna, diminishing the high value visitor experience now associated with McNeil River.
  3. A decrease in the number of bears using the Falls would affect the unique bear-viewing program at McNeil River.