The new Pebble Partnership mine proposal and associated infrastructure now stretch from the Bristol Bay side of the mountains to the Cook Inlet side. The application submitted to the Army Corps of Engineers includes a deep water port at Amakdedori beach and road that stretches across prime bear habitat from near Kokhanok, AK to Amakdedori beach. This proposed road comes within a mile of the McNeil River State Game Refuge boundary and the port facility is within sight of a popular bear viewing destination.
McNeil River State Game Sanctuary was established by the Alaska State Legislature in 1967 to preserve the unique congregation of brown bears at McNeil Falls. When under regulated human behavior began to impact the bears in the early 70’s a lottery system for access was put into place to limit and structure human presence in the area. This carefully regulated system and the practices developed at McNeil are the foundation for the modern bear viewing industry.
The proposal to put a deep water port so close to the the boundary of the refuge would have negative impact on both the bears in the area that make up this unique congregation and visitors to the the sanctuary and refuge who enjoy wilderness and solitude.
Possible direct effects on bear population:
1. Increased noise levels from construction might deter bears from coming to McNeil River Falls.
2. Dredging off Amakdedori Beach might affect schooling of salmon or Dolly Varden before they run up Chenik Creek, McNeil River and Mikfik Creek. McNeil bears are known to eat fish in these as well as other stream systems in the area.
3. Noise from increased large vessel traffic (boats moving product from the terminal at Amakdedori to the Kenai Peninsula) might affect bear behavior and use of McNeil River by bears.
4. It is likely that there will be increased contact between bears that use McNeil River and humans outside of the McNeil River program that could result in food conditioning of bears or direct mortality of bears by intolerant humans.
5. The road and resulting traffic would fragment habitat and and bisect a travel corridor potentially deterring bears utilizing McNeil Refuge and Sanctuary.
6. Industrial facility in the heart of bear country increases the likelihood of bears becoming food conditioned thus reducing safety for visitors in the sanctuary and refuge.
Direct or indirect effects of project on bears that use MR would also affect the MR Visitor Program:
1. Displacement of bears could reduce the number of bears viewed by people, resulting in a diminished viewing experience.
2. Direct mortality of bears from humans would affect the immediate population of bears using MR.
3. Because the viewing program at MR is structured around consistency of human behavior in the Sanctuary and especially around bears, many bears using the area have become habituated over time. The habituation extends into subsequent generations, as young bears typically follow their mothers’ feeding and home range patterns. Thus, a less immediate though more serious decrease in bears using MR could also be a result of this project.
4. Exposure to human food waste at industrial site could lead to food conditioning of bears.
5. Food conditioning of bears so close to a bear viewing area would lead to unsafe conditions for bear viewers in the McNeil River State Game Sanctuary and Refuge.
The nearly 50 million acres of roadless areas in our National Forests are an American treasure. The forests protected by the 2001 Roadless Rule— more than 1.5 million Americans voiced support for the Roadless Rule during the original rulemaking process, which followed decades of clear-cutting that had a destructive and lasting impact on the Tongass — provide vital habitat for thousands of wildlife species, safeguard drinking water supplies for millions of Americans, and ensure quality recreation cherished by all. The existing rule protects roughly 9.2 million roadless acres from additional logging and new logging roads in southeast Alaska's Tongass National Forest.
Weakening this policy in Alaska will harm local and indigenous communities, Southeast Alaska’s economy, salmon fisheries, and wildlife. The Tongass, America’s largest and wildest national forest, draws outdoor adventurers, boaters, birders, hunters, and anglers. An intact Tongass supports a robust Southeast Alaskan economy through tourism, commercial and sport fishing, and small businesses. Its old-growth trees provide irreplaceable wildlife habitat for myriad species including wild Pacific salmon, Alexander Archipelago wolves, and Sitka black-tailed deer.
The Tongass National Forest falls within the traditional territories of the Tlingit, Haida and Tsimshian Peoples, the original inhabitants of this land since time immemorial. Current Roadless Rule protections also extend to cultural and sacred sites of great importance to Alaska Native people, who rely upon the Tongass for spiritual and subsistence practices.
The State of Alaska is seeking a state-specific Roadless Rule that could unravel or eliminate critical ecological and cultural protections provided under the existing 2001 National Roadless Rule, by opening up Tongass roadless areas to new logging roads and old-growth clearcutting. Logging the Tongass would threaten the health of Alaskan salmon by polluting rivers and streams, and by removing trees that help regulate water temperature. Additionally, the Tongass serves as a buffer against climate change and as a refuge for salmon, birds, and other wildlife. Much like the Amazon rainforest, the Tongass’ stands of ancient trees are champions at absorbing greenhouse gas emissions, storing approximately 8 percent of the total carbon in all national forests of the lower 48 states. It is the largest intact temperate rainforest in North America and serves as a “carbon life-raft” by storing carbon and maintaining America’s resilience in the face of the climate crisis.
Klukwan is a village of 90 people in Southeast Alaska that’s home to the Chilkat Indian Village, a federally recognized tribe, on the banks of the Chilkat River 22 miles north of Haines, Alaska. The Chilkat have lived in the Chilkat Valley for over 2,000 years. It’s a land of natural bounty. The braided glacial river hosts all five species of wild Pacific salmon, and the people of the Chilkat Indian Village live a subsistence lifestyle based on the salmon, berries and wild game, such as moose, that live in the valley. The natural health of this ecosystem is now under threat by Constantine Metal Resources, a Canadian mining company that is in the advanced exploration stages of a copper, zinc, gold and silver mine near the headwaters of the Chilkat River.
The Palmer Project raises serious concern among local residents, fishermen and conservationists because of the acid mine waste and heavy metals that could leach into the groundwater. A tailings pond or dry stacking of the toxic waste will require maintenance for centuries after the mine closes, and with the frequent earthquakes and heavy rains in the region, residents fear a disaster like what occurred at British Columbia’s Mount Polley Mine in 2014, when the tailings pond breached the dam and poisoned Polley Lake and the Cariboo River watershed.
In 2016, the Chilkat | Jilkaat Heeni was nominated as a Tier 3 waterbody (the highest level of protection for waterways in the US) by the Chilkat Indian Village of Klukwan because of its enormous cultural, economic, and ecological importance. As stressors in the ocean ecosystem increase, such as plastic pollution and acidification, river habitats like the Chilkat | Jilkaat Heeni become even more critical to the survival of salmon and communities.
The construction and operation of the proposed Constantine-Palmer Mine, 18 miles upstream from the Chilkat River and the town of Klukwan, and 35 miles from the town of Haines, could jeopardize the health and well-being of salmon and all who depend on them. The silver, zinc, copper, and gold ore currently being explored by Constantine Metal Resources is located in an area of high rainfall, seismic activity, and in a massive sulfide deposit – which will likely lead to acid mine drainage.
More concerns include:
Acid leaching potential: This area contains a volcanogenic massive sulfide (VMS) deposit. All sulfide mines produce acid mine waste, but wet climates like that of the Chilkat Valley intensify the risk of acid mine drainage--toxic, acidic wastewater leaching into our watershed.
Impacts that last forever: Acid mine waste requires treatment for perpetuity. Constantine tells us the life of the proposed mine would be 10-15 years, but the impacts could last forever, and taxpayers may be on the hook for treating the acid mine waste long after the mining company is gone.
An area prone to earthquakes: The seismic nature of the Valley could threaten the integrity of waste storage structures. In October 2018, 11 earthquakes occurred over the course of 48 hours, all around the perimeter of the Palmer Project.
Skipping approval: Constantine has already started digging trenches for discharging potentially acid-generating wastewater near Hangover Creek, despite not yet obtaining the required approval from DEC for a land application disposal (LAD) system—discharging wastewater underground.
Preventing public processes: Constantine has shifted the location of the exploration entry portal from federal Bureau of Land Management (BLM) to Alaska Mental Health Trust (MHT) land, skirting the NEPA process, including Environmental Analysis/Impact Studies that include a “no action” alternative, transparency, and a public process.
No consideration for climate change: Constantine’s Plan of Operations addresses five years of industrial activity, but many of the impacts will last for perpetuity. Constantine is using current climate and weather data to plan for these impacts, ignoring the rapidly changing climate. Climate models predict a warmer, wetter, stormier Chilkat Valley within decades.
In Northwest British Columbia, a modern-day gold rush is underway that could threaten B.C.'s and Southeast Alaska’s salmon, rivers, fishing and tourism jobs, and unique way of life. Spurred by weakened environmental and fisheries regulations and the construction of a massive new power line, over a dozen large-scale mines are in various stages of abandonment, operations, and development.
These Canadian mines in Northwest B.C. are located in transboundary watersheds of world class wild salmon rivers - the Taku, Stikine and Unuk. The Taku, Stikine and Unuk watersheds span almost 30,000 square miles, or an area roughly the size of Maine, and are the cultural and economic lifeblood of Southeast Alaska and Northwest B.C.
Most of these B.C. mines sit on acid-generating deposits and require tailings dams and active water treatment in perpetuity. Acid mine drainage and toxic heavy metals from these mines threaten British Columbia's and Southeast Alaska’s lucrative fishing and tourism industries, the traditional practices of indigenous peoples, and the way of life of all the residents of the region. These large-scale projects offer no economic benefits to Alaska.
Cumulatively, all of B.C.'s abandoned, developing, and existing mining projects in Alaska-B.C. watersheds threaten to permanently impact the economy and ecology of Southeast Alaska and British Columbia downstream. Recognizing this and beginning in 2013, thousands of individual Alaskans and British Columbians, Alaska federally recognized tribes, Alaska and national tribal organizations, dozens of Alaska businesses, Alaska municipalities, and fishing organizations, the State of Alaska, numerous Alaska state legislators, and the Alaska congressional delegation (and the Washington U.S. Senate delegation) have repeatedly called on the U.S. Department of State to pursue action under the Boundary Waters Treaty of 1909 on this matter.
Current B.C. and Canadian environmental assessment and permitting allows for mines to be developed in the B.C. headwaters of rivers flowing across the international border and into the United States without:
(1) the consent of indigenous communities in B.C. and the U.S., as well as private property owners;
(2) an analysis of historical impacts from such mines;
(3) the independent collection of at least 3-5 years of baseline/reference condition water quality and fish and wildlife population data;
(4) an independent, comprehensive evaluation of downstream impacts;
(5) a demonstration of technology to mitigate impacts that satisfies both the U.S. and Canada that shared resources won’t be harmed;
(6) the establishment of an independent, fully funded, and perpetual independent monitoring system;
(7) the establishment of a robust financial assurances regime that covers all mining impacts (catastrophic and cumulative) as well as the establishment of an arbitration process for settling claims.