A Whole Lot Missing in Pebble Mine’s Permit Application

After a decade of promising to submit permit applications to build its giant gold and copper mine proposed at the headwaters of the world’s greatest wild salmon fishery in Bristol Bay, Alaska, Northern Dynasty Minerals—the Canadian mining company behind the Pebble Mine—says it finally did so today.
Credit: Robert Glenn Ketchum

Including the Permit Application

After a decade of promises, Northern Dynasty Minerals—the Canadian mining company behind the proposed Pebble Mine—says it finally submitted permit applications to build its giant gold and copper mine at the headwaters of the world’s greatest wild salmon fishery in Bristol Bay, Alaska.

So, what’s missing? It turns out, a whole lot.

For starters, the permit application. Northern Dynasty did not make it available to the public. We’re submitting Freedom of Information Act requests to the Army Corps of Engineers for copies of Pebble’s application and supporting documents, but it shouldn’t be this hard. Surely a company that’s been clamoring for a transparent process would be…well…more transparent.

Pebble’s Vice President of External Affairs Mark Hamilton recently lamented about the “absence of informed and respectful discourse” in America today, and vowed to appeal to Alaskans’ “reason” when considering the Pebble project.

It seems counterproductive to promote a reasoned and “informed discourse” by filing a permit application with the government…and not simultaneously releasing it for public review.

And clearly there is no real commitment to engaging with the public if you dump big news on the Friday before Christmas. 

Other than the permit application itself, what else is missing?

Here are four biggies:

1. Science

According to its press release, Northern Dynasty submitted a permit application for a much “smaller” mine with a 5.9 square-mile footprint. But in its three-year, twice peer reviewed scientific assessment of the potential mining impacts on the Bristol Bay Watershed, the U.S. Environmental Protection Agency (EPA) evaluated an even smaller mine—with a 4.1 square-mile footprint—and found that even that smaller mine would present unacceptable adverse impacts to the region and fisheries. EPA determined that even this small mine—much smaller than what Pebble is currently proposing—would destroy nearly 24 miles of streams and more than 1,200 acres of wetlands, lakes, and ponds, including streams, wetlands and ponds with documented salmon. For this reason, EPA proposed common-sense restrictions that, if finalized, would have prevented Pebble from building its current 5.9 square-mile mine. Although EPA has now proposed reversing those restrictions, all the science and scientific findings in its Watershed Assessment remain intact—and directly rebut Pebble’s claim that its new smaller mine can miraculously “co-exist” with Bristol Bay’s unparalleled wild salmon fishery.

Even a smaller-than-initially-planned mine will create larger-than-can-be-borne risks to the $1.5 billion annual commercial fishery in Bristol Bay that supports 14,000 jobs.

2. A feasibility (or prefeasibility) study

Companies usually complete prefeasibility studies before submitting a permit application in order to determine whether the project is economically feasible. Pebble has not done so, and has no plans to do so until well into the permitting process. A feasibility study is critical here, because Pebble is promising the public the environmental footprint of a smaller mine while simultaneously promising its investors the economic rewards of fully developing all the ore resources in the Pebble deposit. Both promises cannot be true.

A recent corporate presentation reveals the truth: this “new” (smaller) mine plan is just “the first phase” of development. Pebble’s real intent is to develop the mine to the fullest extent, with this “smaller” mine plan just the first phase of a segmented project. Pebble needs to be fully transparent in its intent and apply for permits for the full scope of intended work. It also needs to prove that this “smaller” mine—the first phase in what will be a gargantuan mine—will be economically viable on its own.

3. Financing

Northern Dynasty Minerals’ consolidated financials explicitly acknowledge the critical need to obtain financing, as well as “substantial doubt about the Company’s ability to continue.” It recently announced this that it is in discussions with First Quantum Minerals, which may (or may not) enter into an options agreement to bankroll permitting costs—with the option to acquire half of the Pebble project in four to six years. Notably, the deal has not been finalized. Although Northern Dynasty spun this as good news, investors weren’t buying it. And the fine print of its press release told the full story:

“The likelihood of a partnering transaction is subject to risks related to the satisfactory completion of due diligence and negotiations, including finalization of definitive agreements and fulfilment of conditions precedent therein, including receipt of all necessary approvals. Such process may not be successfully completed or completed on terms satisfactory to the Company.”

The fine print further cautioned:

“The likelihood of future mining at the Pebble Project is subject to a large number of risks and will require achievement of a number of technical, economic and legal objectives, including … receipt of significant additional financing to fund these objectives as well as funding mine construction. Such funding may not be available to the Company on acceptable terms or on any terms at all.”

In other words, Pebble needs a huge influx of cash—both to permit and build the mine.

4. Stakeholder Support

Pebble’s announcement of its permit application was met with resounding opposition from the Bristol Bay region. According to a statement by the tribal, political and economic leaders in the region:

[T]he Bristol Bay region met the Pebble Limited Partnership’s long-delayed federal permit applications with skepticism and renewed determination as Northern Dynasty continues to move forward with a mine Alaskans don’t want. More than 80 percent of Bristol Bay residents, hundreds of businesses, and thousands of fishermen oppose the mining proposal. During a recent comment period, over 1 million people, including close to 26,000 Alaskans, weighed in supporting protections for Bristol Bay from the Pebble Mine. Alaska Governor Bill Walker joined those voices; stating recently: “I am not supportive of the Pebble Mine.” People of the region remain steadfastly opposed to the proposal to build a mine at the headwaters of the fishery that has supported the area since time immemorial.

How many times in how many ways can the people of Bristol Bay say NO to the Pebble Mine?

Bristol Bay Native Corporation: “Nothing about the proposed Pebble mine has changed. It is still the wrong mine in the wrong place and is opposed by a large majority of Bristol Bay residents.”

Bristol Bay Native Association: “Bristol Bay has opposed the Pebble Project based on years of extensive study and consideration by our people.”

United Tribes of Bristol Bay: “Given the overwhelming scientific knowledge we already possess about our region, we know the permitting process will confirm that the mine will not work in Bristol Bay.”

Alaska Speaker of the House Bryce Edgmon: “Today’s permit applications by the Pebble Limited Partnership do nothing to change the powerful opposition to their plans by my Bristol Bay constituents. The vast majority of the people I serve are more resolved than ever in their determination to protect their livelihoods and their way of life.”

Nunamta Aulukestai: Pebble Mine “is not welcome here, whatever story they sell. This is not about money to us. This is about our communities, our cultures, our homes.”

Bristol Bay Economic Development Corp.: [H]ere in Bristol Bay, we will choose our sustainable commercial fishery that generates thousands of jobs over a short-term development project.”

Commercial Drift Fisherman: “[A] mine cannot co-exist with our world class fishery. Bristol Bay has the last great wild sockeye fishery, and no amount of money in permitting is going to change the science and facts that this mine will disrupt our already booming and sustainable commercial fishery.”

Trout Unlimited: Bristol Bay is a globally recognized tourist destination that supports Alaskan families and businesses. Visitors don’t pay thousands of dollars to see giant mines in Alaska—they come to fish and hunt and experience the great outdoors.”


For the record, that was a collective and resounding NO from organizations that represent the economic, cultural and social foundations of Bristol Bay. To quote one of my favorite Christmas carols, “it’s been said many times many ways…”

The Pebble Mine is simply the wrong mine in the wrong place. It’s bad for business, and it’s bad for the environment. And nothing in the permit application can change that.