On November 9, 2012, the US Environmental Protection Agency ("EPA") released a Peer Review Panel's report on its draft Bristol Bay Watershed Assessment (BBWA) report, entitled 'External Peer Review of EPA's Draft Document: An Assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay, Alaska.'
The Peer Review Panel Report provides a summary of the panel's key criticisms and recommendations for improving EPA's draft BBWA report, responses of individual panel members to EPA's 14 charge questions used to evaluate the draft BBWA report, and several appendices that provide information about public comment concerning the draft BBWA report and review process, as well as biographical information on panel members.
Below are a few representative quotes from the Peer Review Panel Report that demonstrate: (1) the flaws that panel members identified in the EPA's draft BBWA report; and (2) why the Bristol Bay Watershed Assessment does not provide a sound basis for any administrative action by EPA.
William A. Stubblefield -- Senior Research Professor in the Department of Molecular and Environmental Toxicology at Oregon State University
- Unfortunately, because of the hypothetical nature of the approach employed, the uncertainty associated with the assessment, and therefore the utility of the assessment, is questionable.
- I'm sure there are a number of technological/engineering measures that could be implemented to reduce the potential for environmental injury associated with development of mining in the Bristol Bay watershed.
Steve Buckley -- Geologist with 25 years of experience in earth science, specializing in fluvial sedimentology
- The engineering and mitigation designs associated with the no-failure mode of operation are inadequate. There is no detailed discussion of engineering practices. There is insufficient discussion of any potential mitigation measures and there is a lack of any detailed research into applicable engineering and mitigation methods.
- The summary of uncertainties and limitations dwells on things that "could not be quantified" due to lack of information, model limitations, or insufficient resources. Thus, this reader was left somewhat in limbo as to the potential magnitude of effects from mining activities.
- The background information presented in the characterization of the ecologic, hydrologic, and geologic resources is overly broad in scope. Specifically, the descriptions of the relationship between landforms, streams, and surface water and the interaction with groundwater are mentioned as very important to fish in the watersheds, yet there is insufficient detail to assess these interactions and consequently, the characterization of these resources is weak. There is more detailed information available in the Environmental Baseline Document (EBD) regarding the relation between landforms, streams, groundwater, and fish habitat in the watershed.
David Atkins -- Hydrologist, expert in mine hydrology and geochemical assessment
- The importance of this impact [elimination of streams/wetlands], is not put in context of the watershed as a whole, so it is not possible to determine the magnitude of the risk to salmon. The Assessment also did not consider whether there are any methods that could effectively minimize, mitigate or compensate for these impacts.
- Without a more detailed understanding of the mine plan and associated engineering, as well as additional detailed analysis, it is difficult to determine if the failure probability estimates presented in the Assessment are reasonable.
Dirk van Zyl -- Professor and Chair of Mining and the Environment at the Norman B. Keevil Institute of Mining Engineering, University of British Columbia and expert on sustainable mineral development
- Any mine in Bristol Bay will have to undergo a rigorous and lengthy regulatory review and permitting process. I do not know of a process that will exclude consideration of the impact of all mine facilities on the streams and wetlands in the region. Therefore, I would suggest that the full implications of "mine operations conducted according to conventional practices, including common mitigation measures, and that meet applicable criteria and standard" should have been addressed in the report.
- Because of this major oversight of the realities when permitting and operating a mine it is essential that the scenarios be reviewed by evaluating effects that regulatory requirements and resulting mitigation methods would have.
- The resulting risk assessment can be at best characterized as preliminary, screening level, or conceptual. There are both technical and process issues that must be addressed before this risk assessment can be considered complete or of sufficient credibility to be the basis for a better understanding of the impacts of mining in the Bristol Bay watershed.
Phyllis K. Weber Scannell -- Environmental Consultant and former Biologist for the Alaska Department of Fish and Game
- The Environmental Assessment seems a bit premature in making an assessment of the potential for acid rock drainage (ARD) or metals leaching (ML). Further, the description of the potential mine may not reflect a likely mine scenario. It is difficult to calculate potential risks to the environment without a specific mine plan.
- Some of the assumptions appear to be somewhat inconsistent with mines in Alaska. In particular, the descriptions or effects on stream flows from dewatering and water use do not account for recycling process water, bypassing clean water around the project, or treating and discharging collected water.
John D. Stednick -- Professor and Program Leader of the Watershed Science Program, Forest and Rangeland Stewardship at Colorado State University
- The direct loss or inaccessibility of upstream salmon habitat does not necessarily translate to salmon loss.
- No information was provided on pipeline structure or placement, other than mentioning of stream crossings. The pipeline failure of concentrate slurry was modeled using chemistry from Aitik (Sweden) mine. Is this best approximation? That mine is about 80 years old...
Paul Whitney -- retired Wildlife Ecologist with extensive experience in fish and wildlife interaction
- If the risk to fish cannot be quantified because there is little or no demographic information, then any evaluation of risk to wildlife can't be quantified and must be qualitative. Merely stating that a qualitative increased risk for fish will also result in a qualitative increased risk for wildlife is not adequate. I am not satisfied with such an obvious and general conclusion. I do not understand why the scope of the main document is limited to an indirect evaluation of fish-caused risks to wildlife.
Gordon H. Reeves -- Research and Fish Biologist with the Aquatic and Land Interaction Program of the United States Department of Agriculture, Pacific Northwest Research Station
- The purpose of the report is unclear, which makes it difficult to assess... There certainly was much confusion among members of the review panel and the people who commented on the report because of this. I think that the credibility of the report could be improved substantially if the analyses were formalized and more clearly articulated and defined.