1. The EPA actions against the Pebble Project are wrong and rooted in politics, not science.

2. The proposed determination is a political action and is being taken outside of the normal permitting process. It is preemptive and precedent setting. There is an established process for evaluating resource development and other projects in the US and it should be followed.

3. EPA should take into consideration that blocking domestic mineral production of copper only ensures China will further its hold on being the primary supplier of critical metals for renewable energy and other technologies. With the EPA’s help, China will become the Saudi Arabia of copper production.

4. If Pebble can be stopped due to politics, what project is next?

1. Pebble could provide thousands of jobs, generate hundreds of millions of dollars in economic activity, and make important contributions to the state and local government in Alaska (over $150 million according to the EIS). This is especially important for communities closest to the project that have few year-round jobs and face extremely high costs of living.

2. The justification for Pebble action could be applied to any watershed in Alaska including the Copper River, Yukon River or Kuskokwim River.

3. Copper is an essential mineral for the nation’s goals of expanding renewable power sources such as wind and solar. Pebble is one of the most significant copper prospects in the nation and around the world.

The biggest beneficiary of preventing Pebble and other US copper mining projects will be China.

Most of Alaska’s land is considered pristine and undisturbed, including much of the land selected by the state for development. This type of approach from the EPA could bring Alaska’s economic future to a screeching halt.

4. There has been no attempt to assess the economic impacts of this decision to the state of Alaska.

1. The proposed determination intentionally elevates one resource at the expense of another rather than working within Alaska’s long-standing environmental framework of co-existence among industries.

2. The Pebble Partnership has long stressed the criticality of the project co-existing with the fishery and supporting additional economic opportunities for the region.

3. The land around Pebble was specifically selected by the state of Alaska as part of its statehood land opportunity. When Alaska became a state, it was granted the opportunity to select 105 million acres for the purpose of helping the young state’s economy. Permanent federal action blocking development of 309 square miles of Alaska’s selected lands is a violation of this agreement.

4. The mine-impacted anadromous streams amount to less than 1/10 th of 1% (0.08%) of all mapped anadromous streams in the Bristol Bay watershed (9819 miles). As the EIS acknowledges, impacts to salmon species are so small that they cannot be measured.

5. EPA must grant the state of Alaska a leading role in evaluating the project as it is on Alaska land and removing 309 square miles of Alaska’s land by fiat is a violation of Alaska’s Statehood Compact with the federal government.

1. The arguments used against Pebble will become the norm for stopping development as many in the mining industry are already seeing similar arguments at other projects in the U.S.

2. The EPA’s actions are inexcusable. The actions are outside the normal permitting process and the agency has allowed politics to interfere with its core regulatory mission.

3. The Proposed Determination should be rejected, and the agency should return to its proper regulatory role.

4. EPA should withdraw the proposed determination (preemptive veto) and allow the established process to play out.

1. EPA was a full participant in the Environmental Impact Statement (EIS) process for the Pebble Project over the course of three years and never raised objections of this magnitude.

2. This effort is a blatant attempt to undermine the multi-agency EIS for Pebble that found no harm to the Bristol Bay fishery. The EIS specifically said that fishermen would see no reduction in fish values and that downstream waters would not see impacts beyond what would be expected to be seen in season fluctuations.

3. EPA must acknowledge that the EIS for Pebble clearly states the mine can be developed without harm to the Bristol Bay fishery.

4. There would be no measurable change in the number of returning salmon and the historical relationship between ex-vessel values and wholesale values. (ES 87)

5. The mine site area is not connected to the Togiak, Ugashik, Naknek, and Egegik watersheds and is not expected to affect fish populations or harvests from these watersheds. (Table 4.6-1, P4.6-4)

• The mine-impacted anadromous streams amount to less than 1/10th of 1% (0.08%) of all mapped anadromous streams in the Bristol Bay watershed (9819 miles). As the EIS acknowledges, impacts to salmon species are so small that they cannot be measured.

• The habitat disturbance at Pebble is underutilized by anadromous fish. While fish presence has been observed, it is not well utilized when compared with similar habitat downstream or in other parts of the watershed.

• More than half of Alaska’s lands are considered wetlands, with Alaska boasting more wetlands than the entire Lover 48 state combined

• The North Fork Koktuli is not significant habitat for Sockeye salmon in the Bristol Bay watershed.

• The EPA action is clear in its intent to preclude any activity in the watershed around the Pebble site (North Fork Koktuli, South Fork Koktuli, and Upper Talarik Creek) regardless of action by the USACE.

• Most of Alaska’s land is considered pristine and undisturbed, including much of the land selected by the state for development.

• The land around Pebble was specifically selected by the state of Alaska for its mineral potential as part of an historic land exchange between the state of Alaska, the federal government, and Cook Inlet Region.

• The justification for Pebble action could be applied to any watershed in Alaska including the Copper River, Yukon River or Kuskokwim River.

The following citations from the EIS demonstrate that project will not harm the fishery:

• There would be no measurable change in the number of returning salmon and the historical relationship between ex-vessel values and wholesale values. In addition, there would be no changes to wholesale values or processor operations expected for Alternative 1a. Under normal operations, the Alternatives would not be expected to have a measurable effect on fish numbers and result in long-term changes to the health of the commercial fisheries in Bristol Bay.(ES 87)

• The mine site area is not connected to the Togiak, Ugashik, Naknek, and Egegik watersheds and is not expected to affect fish populations or harvests from these watersheds. (Table 4.6-1, P4.6-4)

• Other salmon fisheries in Alaska exist in conjunction with non-renewable resource extraction industries. For example, the Cook Inlet salmon fisheries exist in an active oil and gas basin and have developed headwaters of Anchorage and the Matanuska-Susitna areas. The Copper River salmon fishery occurs in a watershed with the remains of the historic Kennecott Copper Mine and the Trans Alaska Pipeline System in the headwaters of portions of the fishery. Both fisheries average higher prices per pound than the Bristol Bay Salmon Fishery. (ES 86)