Policy Memo: Mining in Bristol Bay, Alaska

ON MINING IN BRISTOL BAY, ALASKA The purpose of this memo is to discuss the feasibility of mining in Bristol Bay, Alaska. The recommended course of action is that the (EPA) Environmental Protection Agency’s instructions be followed when mining in Bristol Bay to ensure sustainable development in Alaska. The Nushagak and Kvichak River watersheds reveal Alaska’s capability to develop by mining copper and gold deposits.[i] However, research conducted by the EPA has highlighted some of the negative environmental consequences of pebble mining in Bristol Bay. In this memo I will frame three approaches to mining in Bristol Bay and conclude on the most economically beneficial and environmentally feasible approach. APPROACHES TO MINING IN BRISTOL BAY:

• Oppose EPA’s Regulatory Authority and Push for Mining in Bristol Bay

Alaskans have a right to use their natural resources. The Pebble deposit could generate between $300 billion and $500 billion as well as provide 2000 jobs during the construction of the mine and 1000 jobs during the operation of the mine.[ii] From an economic perspective, mining in the Pebble deposit would produce a lot of revenue that could be used to develop and protect the Alaskan environment.

• Withdraw from Mining in the Bristol Bay Area

The impact of mining would cause irreversible problems for Bristol Bay ecosystem. [iii] The Bristol Bay commercial fishery generates $1.5 billion annually and it provides 14,000 jobs for Alaskans.[iv] Jeopardizing the salmon population could consequently harm the Alaskan economy since fisheries will cease to be a dependable source of income. It would be a safer move to utilize existing resources to develop the economy so as not to endanger the livelihood of Alaskan residents.

• Support Section 404 (c) and Follow EPA’s Proposed Determination[v]

The EPA’s research on the Bristol Bay region highlights the potential environmental impacts of large-scale mining in the region. This approach would mean that support for the Senate Bill 2156 “Regulatory Fairness Act”[vi] must be withdrawn so as to ensure protection of the Clean Water Act’s Section 404 (c). Mining would still be permitted; however, it will be limited to areas deemed by the EPA as safe. CRITERIA FOR DECISION ANALYSIS I will use weighted decision analysis criteria to determine which of the three approaches is most feasible economically and environmentally. The five different criteria I have chosen are: (1) political feasibility, (2) administrative feasibility, (3) environmental impact, (4) economic costs and benefits, and (5) social costs and benefits. POLITICAL FEASIBILITY Oppose EPA –Opposing unnecessary government regulatory agencies will show that you support the tenets of your party. Taking your upcoming elections into account, this approach could be a politically wise decision. Withdraw from Pebble Mine – Polls from 2014 show 62 percent of likely Alaskan voters against Pebble mine.[vii]  Withdrawing from Pebble mine would be strongly supported by your constituents. Support EPA’s Proposed Determination – Following the EPA’s instructions would mean that the Pebble deposit is mined carefully and with adherence to rules that are established to protect the environment. Protecting the Alaskan environment, and in turn the livelihood of residents of Bristol Bay, would increase support from your constituents. Generating revenue from the mine would also be a political victory. ADMINISTRATIVE FEASIBILITY Oppose EPA – Pebble Limited Partnership (PLP) will be mining, meaning getting permits and legal responsibility will lie with PLP. However, an advisory committee may be required to oversee a foreign multinational company operating in Alaska. Withdraw from Pebble Mine – Withdrawing support from mining industry would require no extra administrative effort. Support EPA’s Proposed Determination –Collaboration between EPA and PLP has to be established. Several advisory committees and research teams would be required to ensure Pebble is adhering to established protocol in protecting the Bristol Bay environment. ENVIRONMENTAL IMPACT Oppose EPA –Unrestricted mining would irreversibly damage the fisheries and the Alaskan ecosystem may collapse as a result of the elimination of sockeye salmon spawning waters and habitat. Withdraw from Pebble Mine – Withdrawing support for mining and thereby preventing mining in Bristol Bay would preserve the environment. No extra damage would occur to Bristol Bay by preventing mining. Support EPA’s Proposed Determination – Some negative consequences may arise from mining in Bristol Bay. However if the EPA is to be trusted then these consequences are minor and the ecosystem will still survive in the long-run, making this approach environmentally feasible. ECONOMIC COSTS AND BENEFITS Oppose EPA –Pebble deposit could create a lot of revenue once the minerals are mined. In the long run however it is difficult to see how the revenue would be used and whether or not it would be fairly distributed among locals. Moreover, if the environment is damaged then the fishery may fail meaning the loss of 14,000 Alaskan jobs and $1.5 billion annually. Withdraw from Pebble Mine – Disadvantageous because Alaskans lose the opportunity to prosper from mineral resources. Support EPA’s Proposed Determination – Can take advantage of revenue generated from Pebble deposit whilst at the same time ensuring the ecosystem is protected. This makes sure that Alaskans don’t lose their livelihood since the EPA’s restrictions would safeguard salmon populations. SOCIAL COSTS AND BENEFITS Oppose EPA –Destroying local livelihood by potentially eliminating salmon population would be a direct interference with traditions that have lasted generations. Withdraw from Pebble Mine –Many Alaskans oppose mining in Bristol Bay either because of the environmental consequences or because it threatens their employment. Support EPA’s Proposed Determination –Alaskans keep their livelihood and moreover those that are seeking a different lifestyle will find different opportunities such as the mining industry. CONCLUSION             The weighted decision analysis demonstrates how it is vital for the Alaskan population that mining undergoes due process conducted by the EPA. Contrary to opposing the EPA’s procedure of following Clean Water Act Section 404 (c), as  Senator it would be more favorable to support the EPA’s actions so as to maintain the economic and natural well-being of Bristol Bay and Alaska as a whole. Although opposing the EPA’s Proposed Determination may be politically advantageous, in all other aspects either withdrawing from mining or following the Proposed Determination is more beneficial. As Senator you seek to develop Alaska and allow residents to reap the rewards that the land has in store for them. Hopefully this memo will establish that supporting the EPA’s Proposed Determination does not prevent residents of Alaska from developing – rather it emphasizes developing sustainably so as to ensure the prosperity of Alaska for generations to come.

	Political Feasibility	Administrative Feasibility	Environmental Impact	Economic Costs & Benefits	Social Costs and Benefits	Weighted Score
Criteria Weight	0.25	0.15	0.25	0.2	0.15
Oppose EPA	3	2	1	2	1	1.85
Withdraw from Pebble Mine	2	3	3	1	2	2.2
Support EPA’s Proposed Determination	3	1	2	3	3	2.45

[i] U.S. EPA, An Assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay. (U.S. Environmental Protection Agency, 2014). at https://cfpub.epa.gov/ncea/bristolbay/recordisplay.cfm?deid=253500 [ii] U.S. EPA, An Assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay. (U.S. Environmental Protection Agency, 2014). at https://cfpub.epa.gov/ncea/bristolbay/recordisplay.cfm?deid=253500 [iii] U.S. EPA, Proposed Determination of the U.S. Environmental Protection Agency Region 10 Pursuant to Section 404 (c) of the Clean Water Act, Pebble Deposit, Southwest Alaska. (U.S. Environmental Protection Agency, 2014), at https://www.epa.gov/sites/production/files/2014-07/documents/pebble_es_pd_071714_final.pdf [iv] Carscallen, Katherine, Bristol Bay Fisherman Oppose Legislation to Gut Clean Water Act (2014) at http://www.bbrsda.com/2014/03/bristol-bay-fishermen-oppose-legislation-to-gut-clean-water-act/ [v] : EPA (U.S. Environmental Protection Agency). 2014. Proposed Determination of the U.S. Environmental Protection Agency Region 10 Pursuant to Section 404(c) of the Clean Water Act, Pebble Deposit Area, at https://www.epa.gov/sites/production/files/2014-07/documents/pebble_es_pd_071714_final.pdf [vi] U.S Congress, Regulatory Fairness Act of 2015, (U.S. Congress, Senate, Committee on Environment and Public Works, 2015) at https://www.congress.gov/114/bills/s54/BILLS-114s54is.xml [vii] Robbins, Denise, Myths and Facts About Pebble Mine And The EPA’s Actions To Protect Bristol Bay, (2015), at http://mm4a.org/1MmdgrL