Thiessen said the final BBWA
report does not include any recommendations or regulatory actions that will affect future development of the Pebble Project.
Although EPA's 'hypothetical mine' is sited at the location of the Pebble deposit, BBWA authors continue to refuse to consider the most extensive scientific data set available on the region - environmental baseline data collected by the Pebble Limited Partnership (the "Pebble Partnership" or "PLP") at a cost of some $150 million.
And we believe the draft BBWA to be a fundamentally biased report that should have no bearing on the future of America's most important undeveloped mineral resource.
Northern Dynasty's letter to EPA Acting Administrator Bob Perciasepe states the federal agency has further failed to provide for an open, objective and transparent public and scientific review of the 2013 draft BBWA by unnecessarily restricting public comment opportunities on a 1,300+ page document and restricting public access to its Peer Review Panel, ignoring the agency's own guidelines for scientific peer review.
While unprecedented, Northern Dynasty said at the outset of the BBWA process that EPA's study could have served a valuable purpose for project stakeholders and the people of southwest Alaska if it provided an objective, science-based assessment of the true risks and opportunities associated with modern mine development in the region prior to the onset of project permitting," Thiessen said.
a summary report with numerous examples that demonstrate how BBWA study authors have distorted the potential effects of a mine designed and operated to modern engineering standards on the natural resources of Bristol Bay, relating to study methodology, steady state mine operations and range of failure scenarios;
For instance, the EPA's tailings embankment design and its road-building, culvert and pipeline design standards were derived from other sources, yet contribute to some of the most significant impacts predicted in the BBWA
the draft BBWA report suffers from a lack of sufficient data and information to support the conclusions reached, yet the report authors in many cases overlooked the voluminous site-specific data provided by PLP as part of its 'Environmental Baseline Document'
the draft BBWA report over-estimates both the likelihood and consequence of a range of potential systems and operational failures;
the draft BBWA report presents inappropriate and misleading case studies;
the 'hypothetical mining scenario' presented in the draft BBWA does not employ 'best mining practices', or the alternative engineering approaches, environmental safeguards and other mitigation strategies commonly used at modern mines to avoid environmental effects.
With the Pebble Partnership expected to finalize its development plans for Pebble next year, and to initiate federal and state permitting under the National Environmental Policy Act (NEPA), Thiessen suggested that EPA should shelve the draft BBWA report, not expend the many millions of dollars and possibly years necessary to complete it, and prepare to participate in the NEPA review of Pebble.