Draft Assessment Should Be Dropped

Borell Consulting Services LLC, joins a growing number of scientific voices urging the Environmental Protection Agency (EPA) to stop the draft Bristol Bay watershed assessment due to errors and data deficiencies. In the firm's letter submitted to the EPA, principal Steve Borell states "the assessment is not a credible evaluation of the impacts of large scale metal mining in the watershed.

Borell summarizes the firm's concerns into three major areas including emphasis on the hypothetical mine created by the EPA, a mine that could not be permitted under existing state of Alaska and federal law requirements. The letter also notes conclusions in the Executive Summary not supported by the body of the assessment.

The letter concludes that the assessment is so flawed that it cannot be fixed and should be dropped from further consideration. Read Borell Consulting Services letter to the EPA.

McDowell Group Critical of EPA Methodology

The McDowell Group, noted throughout Alaska for their extensive experience conducting economic analysis and socioeconomic impact assessments, economic development planning, survey research and social services-related research, has submitted a letter to the Environmental Protection Agency (EPA) strongly critical of the lack of original data associated with the assessment.

Acknowledging there is little doubt the Bristol Bay salmon resource has great value to the people who earn income or subsist off of the resource, the McDowell Group has criticized the patchwork of numbers utilized within the assessment. The letter states 'the array of numbers presented serve better to confuse than inform."

The McDowell Group concludes that if economic analysis and related data are to be used to support public policy decision-making around management of the Bristol Bay watershed, the EPA should have original, up-to-date and peer-reviewed economic analysis performed, with results presented in a clear and concise manner. Read the McDowell correspondence.

No Federal Authority For Draft Assessment

Matthew A. Cronin, Ph.D., research professor of animal genetics for the University of Alaska Fairbanks, calls into question the Environmental Protection Agency's (EPA) legal authority to conduct its draft Bristol Bay watershed assessment.

In his letter to the EPA, Cronin notes the multiple submission of documentation by the state of Alaska and Speaker of the House, which have established that the draft Bristol Bay watershed assessment exceeds the intent of the Clean Water Act (CWA), and that the EPA does not have the authority to conduct the assessment or regulate mining on state lands.

Cronin concludes that, 'it appears that the draft assessment is an ill conceived and unconstitutional document that should be retracted.' Read Cronin's letter to the EPA.

EPA Should Guard Against Overreach

The Pacific Legal Foundation (PLF) is urging the Environmental Protection Agency (EPA) not to rely prematurely on the data from the draft Bristol Bay watershed assessment to evaluate the suitability of mining in the Bristol Bay watershed.

Stating the public would be ill-served by a preemptive EPA decision, PLF has noted three areas of review for EPA consideration, including the recent court decision cautioning the agency against strong-arm tactics. Read the PLF letter to the EPA.