ASBN is teaming up with Businesses for Bristol Bay and Conservation Alliance to launch a massive national business sign-on letter to show the EPA the depth and breadth of support for protecting Bristol Bay.
Re: Comments in Support of Finalizing the Proposed Determination for the Pebble Deposit Area, Docket ID No. EPA–R10–OW–2022–0418
Dear Administrator Regan and Regional Administrator Sixkiller:
As businesses that are concerned for and invested in the future productivity of the Bristol Bay watershed, we are writing with regards to the Environmental Protection Agency’s Section 404© Proposed Determination for Bristol Bay. The undersigned businesses, trade groups, and organizations have a common interest in seeing Bristol Bay protected, which is shared across many sectors of the economy including the fishing, recreation, tourism, and food service industries.
Home to the world’s largest and most valuable wild salmon fishery, Bristol Bay has been at risk due to the proposed Pebble Mine for the last two decades. That threat has created uncertainty for the businesses and industries that depend on the productivity and health of Bristol Bay’s wild salmon. At a time of great instability in our supply chains, our industries cannot continue to carry that burden, and therefore request that the EPA move swiftly to finalize Clean Water Act 404© protections that are durable and ensure the long-term sustainability of Bristol Bay’s wild salmon runs.
Bristol Bay’s wild salmon support a renewable economic engine that drives Alaska’s economy and feeds into a variety of business sectors around the country. From commercial fishing to tourism to food service to recreation, Bristol Bay’s salmon provide income for thousands of businesses, support 15,000 jobs, and generate $2.2 billion in annual economic activity. In 2021, Bristol Bay contributed 57% of the world’s wild salmon harvest. And, as they have for millennia, the wild salmon returning each year to Bristol Bay ensure a way of life for Alaska Native communities, providing food, livelihoods and a vibrant cultural touchstone.
Yet the Pebble Mine threatens all of that. If fully developed, the Pebble Mine would generate up to 10 billion tons of toxic mining waste. As proposed in the Pebble Limited Partnership’s (PLP) 2020 mine plan, the 20-year mine would destroy more than 105 miles of streams and 2,200 acres of wetlands, permanently degrading critical salmon habitat in Bristol Bay’s pristine headwaters. Based on the EPA’s peer-reviewed Bristol Bay Watershed Assessment, the Pebble Mine would result in “unacceptable adverse effects” to areas important to fishing, recreation and wildlife, satisfying the statutory trigger to invoke Section 404© of the Clean Water Act.
Over the years, our businesses and organizations have stood with the communities of Bristol Bay in opposition to the proposed Pebble Mine. We continue to support their requests for strong and durable protections for Bristol Bay’s headwaters from the Pebble Mine and any other similar large-scale mining. We urge you to include their recommendations when shaping protections for this region.
The Clean Water Act 404© process must provide true protections to the headwaters, not just limitations based on past mining plans. We support EPA in completing the 404© process as swiftly as possible and call on the agency to finalize comprehensive protections by the end of 2022. The indisputable facts, clear science, and extensive administrative record overwhelmingly support a final 404© determination that protects Bristol Bay from not only the mine plan proposed by PLP in 2020, but any future large-scale mining like the Pebble Mine.
We thank the EPA for recognizing that Bristol Bay is an exceptional place that deserves exceptional protection, and for restoring science and public trust in the 404© process. Our companies and organizations support final 404© Clean Water Act protections that advance the long-term economic health of our country, defend thousands of renewable American jobs, and ensure that the people of Bristol Bay can live without the Pebble Mine overshadowing their future.