Pebble Mine—Preposterous

Northern Dynasty Minerals’ long-delayed permit application lacks credible plan to develop mine, protect salmon, address significant risks, or avoid bankruptcy.

If the consequences of developing the Pebble Mine weren’t so frightening, Northern Dynasty Minerals’ latest “plan,” as described in its December 2017 Army Corps of Engineers permit application and May 2018 “update,” would be laughable. The company’s claim to the U.S. Army Corps of Engineers, to potential investors, and to the public—the notion that this company has the technical or financial competence to develop this mine in this location—isn’t just doubtful. In a word, it’s preposterous.

Last week, to see for myself, I flew over the estimated 83-mile length of Northern Dynasty’s proposed transportation and infrastructure corridor for the Pebble project. Unable to gain land rights through Pedro Bay for a northern access route to Cook Inlet, the company has now come up with a plan that would make Rube Goldberg proud, posing a wide range of significant new risks to the region’s extraordinary natural resources, communities, and wildlife.

Iliamna Lake Crossing and Ports

Among the astonishing elements of the new corridor is an 18-mile barge crossing of Iliamna Lake, the largest and deepest fresh-water body in Alaska and the incubator for trillions of wild salmon that form the foundation for the world’s “Fort Knox” of sockeye salmon, the Bristol Bay commercial fishery. Last summer, it produced about 60 million fish, and this year the run is already 59 million and still going strong as the season continues. (According to a study by the University of Alaska Anchorage, every year the fishery generates about $1.5 billion in revenue and 14,000 jobs.)

Unfortunately, in addition to its unique status as home to a rare and unique fresh water seal found nowhere else in the world, Iliamna Lake is known for high winds, generating intense waves and severe water conditions that are certain to complicate Pebble’s plan to ferry ore and other materials associated with its massive project. As but one recent example, on the very day Northern Dynasty submitted its federal permit application proposing a barge corridor across Iliamna Lake—December 22, 2017—residents in the lake-side village of Kokhanok reported wind gusts of over 100 miles per hour. According to Peducia Andrew, president of the Kokhanok Village Council:

It was so bad here. There were houses that were kind of blown off their foundation and some of the smokehouses here that were kind of knocked over, and . . . there were skiffs, our Lunds, 18-footers, were just toppling around like they were toys.

In winter months, when the lake freezes and local community residents rely on the solid ice cover for snow mobile transit across it, Northern Dynasty proposes to deploy heavy duty ice-breakers to open barge corridors. These barges would operate from two new industrial ports, with one constructed on the northern shore west of the village of Iliamna and the other on the southern shore west of—you guessed it—the village of Kokhanok!

To claim that a plan to industrialize an area subject to these conditions (with daily barge transit for 18 miles across Iliamna Lake proposed as an essential element of that plan)—to claim that this would pose no threat to the ecological resources, services, and communities of Iliamna Lake (and, more broadly, to the health of the Bristol Bay salmon ecosystem) simply defies reality.

“Trust us” is the message from Northern Dynasty, which has promised it won’t proceed if safe operations can’t be assured. Of course. With such a reckless plan in such a sensitive place, what could possibly go wrong?

Amakdedori Port on Kamishak Bay, Cook Inlet

They propose, too, a third new industrial port, this one to be constructed in Cook Inlet at the terminus of a proposed 35-mile private road from the port on Iliamna Lake’s south shore to the mouth of Amakdedori Creek on Kamishak Bay—at the location of an ancestral Alaska Native village with associated significant historical, cultural, and subsistence resources. While initially envisioned by Northern Dynasty in December as a deep-water facility, to be dredged some 50 feet beneath the low-low tide level of the bay, a project update filed with the Army Corps in May now indicates that Northern Dynasty proposes instead to use barges to “lighter” cargo between the port and two proposed large tanker ship mooring facilities in the middle of Cook Inlet, one located 12-miles and the other 18-miles from the beach.

According to Cook Inletkeeper Bob Shavelson, the bay is known for “its harrowing winds, extreme tides, shallow and rocky waters and radical currents” and is subject to intense storms and currents fueled by “gap winds” funneled through the lowlands in the Alaska Range to this very spot. Like the Iliamna Lake segment, these conditions pose virtually insurmountable challenges for the complex and dangerous transfer operations around which Northern Dynasty has constructed its “still not ready for prime time” mining plan and permit application.

This remote stretch of open beach at Amakdedori Creek is not only rugged country but prime brown bear habitat as well. In fact, the proposed industrial development and related activities will be located just a few miles up the coast from the internationally-renowned bear and salmon populations at the MacNeil River State Wildlife Sanctuary and Katmai National Park and Preserve (site of the incomparable Brooks Falls). Seeming neither to notice or care, Northern Dynasty has thus now proposed to expand its sphere of potential collateral damage to include these exceptional natural gems as well.

Road Construction through Pristine Salmon Country

Not to be overlooked are the almost 65 miles of yet-to-be-constructed double-lane private road originating at the heart of the mine itself, crossing hundreds of salmon streams, water-bodies, and wetlands that characterize this ecologically sensitive, hydrologically-complex region—wreaking destruction and industrial havoc from mine construction through operations through long-term maintenance as, in theory, the security of the mine site, its infrastructure, and all its toxic elements are managed and contained in perpetuity.  And, as Northern Dynasty’s CEO Ron Thiessen has emphasized, the project described in the pending permit application is only the first step in the intended full development of the Pebble deposit.

Considered in its entirety, this is a preposterous plan—the latest manifestation of an absurd scheme to build a massive open pit copper and gold mine in the headwaters of the greatest wild salmon fishery on Earth. It is a plan founded on unrestrained arrogance and remorseless disregard for the region and the overwhelming opposition of its people—fueled by the fact that, for Northern Dynasty, it’s “Pebble or bust,” with no other assets to turn to.

Army Corps of Engineers Permit Review

Sadly, the Army Corps seems determined to accelerate review of the permit application toward a final decision in early 2020—a record pace for review of any significant mine project. Requests have been repeatedly made for a stay of the process until Northern Dynasty can submit an accurate project description, fill data gaps, and provide baseline information (including for the corridor) in support of an application stable enough for public review—requests by local leaders, commercial fishermen, businesses, supporting organizations (including NRDC and its members), and even the Governor and Lieutenant Governor of Alaska.

The Army Corps has ignored the absence of basic financial analysis typically required for any major mining project, including a preliminary economic assessment, pre-feasibility study, or feasibility study. The withdrawal of First Quantum Minerals in May—the latest Pebble funding partner to withdraw—has had no apparent impact on the agency, even though it was First Quantum’s funding in December that enabled Northern Dynasty to file its permit application in the first place.

Perhaps on the assurance of Northern Dynasty that another funding partner will be forthcoming, the Corps has continued to press forward. But whether some new funder materializes—or doesn’t—one thing remains crystal clear:

The project proposed by Northern Dynasty in its permit application—the Pebble Mine and its associated infrastructure—is a disaster in the making for Bristol Bay, its people, and its wildlife. For almost a decade, the project has been a poster child for failed promises and unsuccessful partnerships with legitimate mining companies, and any new investor oblivious to this embattled history and the project’s broad-based opposition is likely only to intensify the condemnation at local, state, national, and international levels.

The Pebble Mine must be stopped. It’s preposterous.