Comment Letter Opposing Pebble Mine’s Draft Environmental Impact Statement

This comment letter critiques the Draft Environmental Impact Statement (“DEIS”) for the proposal to develop the Pebble deposit as an open pit mine.

July 1, 2019
Michael Burger, Cara Horowitz, Nathaniel Logar

Located in the Alaskan backcountry about 200 miles southwest of the state capitol, Anchorage, the Pebble deposit is one of the largest undeveloped copper deposits in the world. The deposit also sits in the headwaters of Bristol Bay, the largest sockeye salmon fishery in the world and home to 25 federally recognized tribal governments. Its development would lead to significant harm to nearby spawning grounds, local communities, and the Alaskan economy.

In a comment letter submitted to the U.S. Army Corps of Engineers on July 1, 2019, Cara Horowitz, Co-Executive Director of the Emmett Institute and Nathaniel Logar, Emmett/Frankel Fellow at the Emmett Institute join Michael Burger, Executive Director of the Sabin Center for Climate Change Law at Columbia Law School to critique the recent Draft Environmental Impact Statement (“DEIS”) for the Pebble Limited Partnership’s proposal to develop the deposit as an open pit mine. The authors argue the DEIS is not thorough enough in considering environmental impacts of a potential Pebble Mine. The document fails to sufficiently consider cumulative impacts, does not address segmentation of the mine project, and shows no evidence that Army Corps of Engineers took a hard look at environmental impacts due to climate change and from mining operations. The authors argue the DEIS is markedly less thorough than the EPA’s 2014 Proposed Determination in considering impacts and is legally insufficient. The DEIS must be reconsidered.


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