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Environment Magazine September/October 2008


September-October 2014

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Controversy in Bristol Bay: Coexistence, Mitigation, and Common Ground Over the Pebble Mine

On February 28, 2014, the U.S. Environmental Protection Agency (EPA) sent a letter to the U.S. Army Corps of Engineers, the State of Alaska, and the Pebble Partnership. That letter explained the U.S. EPA's intention to initiate “a process under the Clean Water Act to identify appropriate options to protect the world's largest sockeye salmon fishery in Bristol Bay, Alaska, from the potentially destructive impacts of the proposed Pebble Mine.”1 The U.S. EPA has entered into uncharted territory, particularly given that the company hoping to develop the Pebble deposit has yet to develop. However, the significance of the U.S. EPA's decision was summed up well by administrator Gina McCarthy in a conference call with reporters: “This 404(c) process is not something—and I want to stress this—that the agency does very often. But the Bristol Bay fishery is an extraordinary resource, and it's worthy of out-of the ordinary agency actions to protect it.” While unprecedented, this news was welcomed by the diverse and widespread coalition of Alaska Natives, commercial fishers, sportspeople, and many others who are hoping to protect their livelihoods and cultures tied to Bristol Bay.

Part I of this article, “Bristol Bay Wild Salmon, Pebble Mine, and Intractable Conflict: Lessons for Environmental Studies and Sciences,” surveyed the debate over the development of the Pebble Mine in Bristol Bay, paying particular attention to the diverse coalition banded together to protect the salmon fishery. The piece outlined the importance of Bristol Bay as the world's largest salmon ecosystem, supporting an economy valued at more than $1.5 billion annually, and the scope of the Pebble project, underscoring issues related to size, location, and type that make its development particularly problematic. This coalition can hardly be characterized as a traditional environmental coalition; it is truly a coalition of the unalike, if you will.

Part II turns toward dichotomies of the debate, first assessing the argument that mining the Pebble deposit is a necessary to support sustainable technologies for future generations, before devoting attention to questions of compromise or middle ground. In other words, is it possible to truly have both a mine at some scale and a sustained fishery? Is mitigation possible? How valid are promises to “improve the fishery,” as made by the Pebble Limited Partnership, which hopes to develop the Pebble deposit? The efforts of the coalition to protect Bristol Bay underscore the importance of wide and diverse coalitions for addressing conservation issues in the 21st century.

The Pebble Problem

The debate over Pebble, once termed “the most important environmental decision you've never heard of,” is the story of a proposal to build what could be North America's largest open-pit copper and gold mine, situated at the heart of the world's largest and most intact sockeye salmon ecosystem of Bristol Bay, Alaska.2 Bristol Bay is home to the world's largest runs of sockeye salmon, with returns averaging 37.5 million salmon annually and having been as high as 60 million.3 The Kvichak River alone claims the world's largest population of sockeye salmon. In global comparison, Bristol Bay produces 46% of the world's sockeye abundance.3 Economically, Bristol Bay's salmon ecosystem drives an annual economy valued at more than $1.5 billion and supporting more than 14,000 direct jobs.4

At the headwaters of this world-class fishery sits the controversial Pebble copper and gold deposit. The Pebble deposit does indeed represent one of the largest known undeveloped copper deposits in the world, with an estimated 10.78 billion tons of ore. Mining this ore could produce an open pit of up to six square miles and more than half a mile deep,5 and would potentially require up to three tailings ponds totaling nearly 17 square miles.6 With estimates of 72 billion pounds of copper, 4.8 billion pounds of molybdenum, and 94 million ounces of gold, when boiled down to basics the low-grade nature of the ore is apparent. At most, 10.6 pounds of metal would be recovered from every ton of ore.7 In another perspective, of the known 10.78 billion tons of ore, the ore averages 1% copper equivalent, which means that roughly 99% of the mined ore body is waste.5

Reviewing the history of Alaska, one can safely say that two key issues have defined the history of the state: mining and salmon. In Bristol Bay, these two foundations have come into full conflict, creating an epicenter for an environmental battle that for nearly a decade has included some of the most expensive environmental legislation and ballot initiatives in Alaska state history and is quickly climbing the ranks of conservation issues in Washington, D.C.8

Sustainable Livelihoods for Bristol Bay's Future

In the first article, I detailed the social and economic dimensions of this debate, underscoring the value of the fishery and associated jobs at the heart of the dynamic coalition seeking to protect Bristol Bay. However, jobs and sustainable livelihoods for future generations remain at the heart of this debate. Wrestling with the cultural and economic dimensions of mining at the headwaters of Bristol Bay reveals that all those involved in the conflict do indeed need to address issues of long-term community sustainability.

Bristol Bay's salmon ecosystem is not only the largest in the world; it is also the most diverse sockeye salmon ecosystem.9 Where the ecosystem is incredibly diverse, few doubt that the economic opportunities of Bristol Bay could also use some diversity and enhancement. Where one lives in the region often impacts the degree of one's engagement in the fishery. Notably, those nearest to the Pebble deposit are less likely to be engaged in or see benefits from the commercial fishery.

Aside from the fishery and government jobs, employment opportunities in rural Alaska are certainly few and far between. Prior to the arrival of a cash economy, subsistence living was the norm, but with the infusion of a cash economy, the economy became mixed. While many in Bristol Bay depend both economically and culturally upon subsistence, subsistence alone is not sufficient for survival, and moreover, today's modern subsistence living depends upon modern tools, requiring available cash support to participate in subsistence activities.10 For many communities the commercial fishery provides that necessary balance. However, for communities, such as the villages of Iliamna and Newhalen, that are distant from the fishery, the promise of jobs in mining provides an appealing opportunity, at least in the short term.11

This dilemma forces stakeholders to evaluate not only what they want for future generations, but also what risks they are willing to take. Does mining offer an outlet to a more diverse economy for the region down the road? Can mining be done more safely now than in the past? Can mining and the fishery coexist?

Taking these questions seriously, the leading organizations of Bristol Bay (Bristol Bay Native Association, Bristol Bay Native Corporation, Bristol Bay Area Health Corporation, Bristol Bay Housing Authority, and the Bristol Bay Economic Development Corporation) set about on an unprecedented effort called the “Bristol Bay Vision Project.”12 In so doing, they engaged the region in a dialogue about what the region wanted for its future.

The project hosted more than 50 meetings in 26 Bristol Bay communities; through focus groups and listening sessions, nearly 1400 participants identified a range of concerns and visions for the future of Bristol Bay. In the end they developed a vision of the region, expressing the hopes and values of Bristol Bay, outlining that

The foundation of the Bristol Bay Region is committed families connected to land and waters. We believe future generations can live healthy and productive lives here. Across our region, we share common values of community, culture, and subsistence. We see a future of educated, creative people, who are well prepared for life. We assert the importance of local voices in managing our natural resources to continue our way of life. We welcome sustainable economic development that advances the values of Bristol Bay people. Our future includes diverse economic opportunities in businesses and industries based largely on renewable resources. Large development based on renewable and non-renewable resources must not threaten our land, our waters, or our way of life … We are unified to secure a prosperous future.12

Securing that prosperous future based on these values remains the next step, however, and many are beginning to engage in wrestling with how one moves from vision to action. For example, communities are exploring the potential for small-scale hydro projects, not based on dams, but using innovative technologies for wave-generated power. There are opportunities for geothermal power exploration. Many locals involved in the fishery are engaged in rigorous conversations on how to move more commercial fishing permits back into the hands of local Bristol Bay residents or to facilitate local, family-based fish processing opportunities rather than depending upon the larger fish processing companies, which might be national or internationally based. This work is only beginning, and it is hard to know to what degree these efforts will bear long-term fruit and alternatives to boom-and-bust jobs in the mining industry.

Demand for Metals, Modern Technologies, and Sustainable Jobs

In a world increasingly dominated by rapidly moving technological advances, we are forced to take stock of the need for metals essential to sustainable technologies. Are these minerals essential and indispensible to the development of sustainable technologies for Alaska, America, or the world?

Some scholars have argued that rather than pushing mining onto a foreign country such as South Africa or Mongolia, mining in Bristol Bay is the more ethical choice.13 Oswald Schmitz and Thomas Graedel13 of Yale School of Forestry and Environmental Studies began a review of Pebble by reminding readers that today's “technological arms race” depends upon metals such as copper and gold. This is a common argument from the Pebble Limited Partnership (PLP), which has run ad campaigns targeting individuals who drive hybrid vehicles or support sustainable technologies.

In these arguments, Pebble is a mother lode that we cannot ignore. But this argument again begs the question of how we weigh the risk of resource development over the value of existing renewable resources. There are two approaches to this question: First, what are the actual demand and need for copper? Second, is it truly possible to mitigate Pebble's impact on Bristol Bay—legally and technologically?

Recent increases on the cost and value of copper have led many to mistake market value fluctuations with physical shortage in copper globally. While copper demands have increased over the years, notably in China, where demand has grown at 6% annually in recent years, the global availability of copper has not decreased.14 The National Defense Stockpile Center, which maintains and monitors stocks and availabilities of strategic metals and minerals for the United States, reports annually on the availability of copper. In the 2013 report, the NDSC shows no national shortage of copper expected. Moreover, while it lists copper as a strategic metal, it does not list copper as a metal in critical supply.15

Yet even if copper is not in critical demand, Schmitz and Graedel caution consumers to consider the social impact of mining in America versus other regions of the world. They write that “if the ethical environmental position forces mining activity elsewhere, then the rationale for wilderness protection in Bristol Bay becomes murkier, especially if the mining occurs in places where the standards of environmental protection are weaker.”13 However, this rests upon the assumption that regulation will protect both people and ecosystem in Alaska, whereas in other nations companies will face less stringent oversight and be more willing to exploit local populations. While intended oversight is arguably strict in Alaska, and human rights abuses are less likely, even the strictest regulations cannot prevent potential impacts to a fishery. So, the question again for those in the debate center on the allowable level of risk one is willing to tolerate.

Can Mining and Fisheries Coexist in Bristol Bay?

Former PLP chief executive officer (CEO) John Shively has stated that “If it is a choice between mining and fish, we go away. Fish come first.” Through media and community education campaigns, PLP has tried to persuade the Alaskan public that the debate is indeed being presented as a false dilemma. In reality, they argue, there is no debate. The fishery and mining can “coexist.” However, as I detailed in the previous article, according to the U.S. EPA in its Watershed Assessment, long-term coexistence of fishery and mining district is highly unlikely.

The size of the deposit is a major cause for concern. Newcomers to the debate often ask whether Pebble could be developed at a small scale, thereby sparing the ecosystem the dramatic or catastrophic impacts. However, Northern Dynasty Minerals (NDM) projects in its presentations to investors that the Pebble deposit is at least 10.78 billion tons. Although Pebble is the focal point of the debate, there are other deposits surrounding the Pebble claims block. In total there are more than 600,000 acres of mining claims in the Bristol Bay Basin, with the majority of them directly surrounding the Pebble deposit. The abundance of deposits and lack of current infrastructure lead many to believe that the development of Pebble opens the gates to a mining district in Bristol Bay, thereby amplifying possible impacts.

Examining Pebble's impacts alone, several points stand out. First, even at minimal development, impacts to the region's complex hydrology, rivers, and critical salmon habitat could be significant and irreversible. The U.S. EPA found that even the development of a mine of 0.25 billion tons could lead to the direct loss of 38 km of streams, with an additional 4.8 km of wetlands and ponds lost (Assessment 7-24). These streams and ponds are part of an intricate network of headwater streams, which are lower gradient, thermally diverse streams and wetland that provide important habitat for juvenile salmon to forage, overwinter, and rear prior to commencing their ocean migration (Assessment 7-31).

Regardless of amount of the deposit developed, mineral extraction would require the construction of a 118-mile road from the deposit to a port in Cook Inlet. This road would cross approximately 64 streams, of which 55 are known to support migrating or resident salmonids. Roads present a host of risks to salmon habitat, ranging from culvert failure to truck and transportation accidents that could spill fuel, metal slurry, chemicals, or other toxins into “streams or wetlands, resulting in toxic effects on invertebrates and fish” (Assessment ES 17). Other potential impacts include, but are hardly limited to, the storage and treatment of potentially acid generating mine waste, known as tailings.

In the end, though, few are convinced that if the PLP submitted applications for a permit to develop a small, short-term mine, it would actually stick to that plan. On the one hand, it does not make economic sense to mine a small portion of the deposit. As the U.S. EPA notes, “Because these deposits are low-grade—meaning that they contain relatively small amounts of metals relative to the amount of ore—mining will be economic only if conducted over large areas and will necessarily produce large amounts of waste material” (Assessment ES-9). Furthermore, in the Wardrop Report—a report developed for potential investors and on file with the Federal Securities and Exchange Commission—NDM underscores the 45-year mine, accessing 6.5 billion tons of ore, as the base case for economic return on the investment.

Therefore, while PLP might insist that it would only develop a small portion of the deposit, the reality is that even small development could have significant impacts. More importantly, initial permit applications for mine development are hardly ever the final word. As the U.S. EPA explains of its own assessment of Pebble,

If the Pebble deposit is mined, actual events will undoubtedly deviate from these scenarios. This is not a source of uncertainty, but rather an inherent aspect of a predictive assessment. Even an assessment of a specific plan proposed for permitting by a mining company would be an assessment of a scenario that undoubtedly would differ from actual mine development.

In other words, mine plans are always evolving until the mine is finished and closed. Typically those evolutions include expansion of the project to maximize the potential of the deposit.

These debates over the size of the possible development all include key issues that impact salmon as traced out in the first article. In the end, there is no honest option for a small mine. Location, lack of infrastructure, and low-grade nature of the deposit all necessitate mining this and surrounding deposits to the greatest extent possible. The longer and the greater scale of mining, the more protracted is the risk to the fishery.

Mitigation Measures and Technological Fixes

Over the course of the decade, PLP has not denied that Pebble would have impacts on the watershed. During a presentation to the Northwest Fishermen's Association, former CEO John Shively noted that the development of Pebble would certainly remove some streams and kill some fish (see, accessed 21 March 2014). However, PLP contends not only that plenty of opportunities for mitigation exist, but that PLP can actually improve the fishery beyond its current, world-class state. As it wrote to the U.S. EPA in response to the U.S. EPA's second draft of the Watershed Assessment,

Pebble has already identified opportunities to more than offset direct project effects on stream habitat through fish mitigation projects in close proximity to the proposed mine development. Throughout the 400 square mile area surrounding Pebble, there are tremendous opportunities to undertake fish mitigation projects that would substantially increase the productive capacity of the area for both salmon and resident fish species.16

Regarding mitigation, there are two ways to approach the issue. First are the use technologies for waste storage and management, water treatment, and discharge, or habitat improvement or restoration. The last of these are required under the second level of mitigation in large-scale mining development, in regulatory guidelines for compensatory mitigation.

Regarding mitigation technologies to prevent or minimize water quality impacts to the fishery through metals and contaminants leaching, wastewater treatment, management, and discharge, the U.S. EPA has acknowledged that technologies capable of providing protective measures certainly exist. However, the U.S. EPA also noted in the final draft of its Watershed Assessment that while risks can be reduced through “unconventional” or “novel” mitigation measures, “these practices may be unconventional because they are expensive, unproven, or impractical” (Assessment ES-27). Beyond waste management and water treatment, PLP has also promised to improve the habitat by opening up new habitat, improving fish passage, and updating culverts on roads currently crossing streams. According to PLP, these approaches involved theoretically opening up new, unused habitat in the watershed away from the deposit site. One example put forward by PLP involves the removal of beaver dams to improve fish passage.

In various documents, PLP has identified beaver dams of 0.25 m and higher as barriers to potential, yet underutilized, fish habitat. In so doing, they have suggested beaver dam removal as a measure of mitigation. While in some contexts beavers and beaver dams might present problems for fish passage or even rearing salmon, beavers do not generally present a significant barrier to salmon passage or rearing. In an article titled “Mitigation of Wetland Impacts from Large-Scale Hardrock Mining in Bristol Bay Watersheds,” Tomas Yocum and Becca Bernard note that

A recent meta analysis of the impacts of beaver on freshwater fish indicates that beaver have a positive impact on coho, Chinook, Dolly Varden, rainbow trout, sockeye salmon, and steelhead. The most frequently cited benefits included increased habitat heterogeneity, rearing and overwintering habitat, flow refute, and invertebrate production.17

While beavers are widely considered more beneficial than harmful, the real issue rests in the sheer volume of mitigated habitat that would be required based on the potential and foreseen impacts from the development of the Pebble prospect.

The Clean Water Act (CWA), specifically 404(b)1 guidelines, recognizes that development will indeed have impacts. The 404 guidelines specify that mining waste, for example, or “dredged or fill material should not be discharged into aquatic ecosystems, unless it can be demonstrated that such a discharge will not have an unacceptable adverse impact either individually or in combination with known and/or probably impacts of other activities affecting the ecosystems of concern.”18 Though recognizing that development can and will have impacts on waters of the United States, the CWA and 404 guidelines specify that the impacts must be minimized or offset. In other words, as stated by the 2008 Mitigation Rule, projects are to avoid, minimize, and offset.

In the development of the Pebble deposit, avoidance of impacts is impossible by nature of the mining process. Minimization of impacts is flawed, as I noted earlier. And, as I now discuss, offsetting impacts through compensatory mitigation has significant challenges. Mitigation rules require that mitigation should not only be located within the same watershed as the impact site, but also must replace lost functions.19 In this case, as noted earlier, impacted areas represent essential headwaters habitat so are critical for maintaining the diverse ecological portfolio that was discussed in the first article.20

Typically, mitigation rules require a one-to-one compensation ratio. However, in cases of anadromous fish streams and wetlands adjacent to anadromous waters, regulatory guidance requires as much as two-to-one for restorative mitigation and three-to-one for preservation of comparable habitat elsewhere.21 As Thomas Yocum and Rebecca Bernard argue in the Seattle Journal of Environmental Law, opportunities for in-kind or in-watershed mitigation do not exist at the scales of Pebble's possible impacts in Bristol Bay. They write, “Offsetting large-scale impacts in ecologically intact environments,” such as Bristol Bay, “may neither be feasible nor effective.” This is especially the case in cases that have a shortage of “opportunities of aquatic restoration, enhancement, or preservation of similar resources.”22

Compensatory mitigation throughout the watershed of other, previously degraded sites might be an option in some cases. However there are no appropriate degraded sites of similar function in the watershed, save the potential impacts of Pebble itself.23

Mitigation rules do provide that in-kind mitigation outside the watershed, particularly through mitigation banks, is an option for developers. However, given the importance of Bristol Bay's salmon stocks, particularly regarding genetic diversity, these measures fail to fully compensate for impacts and do not protect the aquatic resources in question. In the end, also, when one considers the fate and history of salmon in the Pacific Northwest, combined with the investments and resources to restore those stocks with little success, a risk analysis should favor protecting renewable fisheries resources over nonrenewable mining endeavors. In the end, these dichotomies of fish versus mining, or even environment versus jobs, are not false dilemmas. Recalling the first article on the subject, in fact the diverse coalition of this conflict speaks volumes that cannot be understated.

Conclusion on Coalition

In the end, the unique coalition is one of the most compelling dimensions of the campaign against the proposed Pebble Mine. Historically in the context of North American fisheries management, the stakeholder groups of commercial fishers, subsistence communities, and sport anglers have typically been at odds with one another. Preferences and demands for allocation have often trumped collaborative enterprises in favor of sustaining healthy fisheries. However, in the context of Bristol Bay, these three primary stakeholder groups have for sometime operated collectively in protection of what many term the last great salmon ecosystem in the world. More intriguing is that these Alaska groups have found effective ways to integrate their work with more traditional, national conservation organizations such as Trout Unlimited, Natural Resources Defense Council, and the World Wildlife Fund.

Frankly, this coalition has gotten as far as it has, ranking this issue as a top issue on the docket of the White House and U.S. Environmental Protection Agency, directly because it has built off of this coalition.24 People pay attention when CEOs of fish processing companies, Native Corporations, and fishing and firearms manufacturing companies travel to Washington, D.C., together. Such coalitions carry political weight not only through financial connections, but also because they span both sides of the political aisle.

From environmental philosophy to environmental sociology, the Pebble debate is a fantastic case study for those interested in the political and human dimensions of conservation. What is apparent in this case is the importance of building a strong grass-roots base and putting the impacted stakeholders first. Environmental philosophers might refer to this as bioregionalism, where the local perspective should drive management decisions for t he region.25 In that regard, the proposed Pebble mine faces strong local opposition, with polling showing a range of opposition from 70 to 80%. Recent comments from Bristol Bay during a federal comment period on an assessment of ecological impacts from large-scale mining on Bristol Bay's wild salmon ecosystem had opposition at near unanimous. Bristol Bay's population is roughly 9,000 people. During a 2013 federal comment period, more than 1,200 Bristol Bay residents wrote to the U.S. EPA. Of those 1,200 comments, 98.6% supported U.S. EPA use of its authority under the Clean Water Act to prohibit large-scale mining at the headwaters of Bristol Bay. Only 16 Bristol Bay residents wrote to the U.S. EPA in support of the proposed Pebble Mine. In short, local voices and concerns provide the foundation for any and all messaging, education, and outreach.

As noted, the diversity of voices is what has carried the weight from southwest Alaska to Washington, D.C. Students interested in human dimensions of conservation would do well to explore this case study in conjunction within a subfield of environmental studies known as grass-roots ecosystem management (GREM), which seeks to apply lessons from environmental studies and sciences to improve initiatives of collaborative conservation. Edward Weber, leading thinker in the that field, focuses his attention on the ways in which some communities come together with former adversaries, forming “coalitions of the unalike” in search of collaborative conservation.26 If collaborative conservation is defined by coalitions of the unalike, then the coalition to protect Bristol Bay is the poster child.

The real lesson here is that issues in conservation can and should no longer be defined or owned by one particular stakeholder group. Especially as we evaluate larger issues related to resource extraction, development, or even climate change, both academics and actors on the ground would do well to find common ground with a variety of stakeholder groups, including former adversaries. In Bristol Bay, this means, for example, moving beyond a singular ecological focus, and understanding the cultural or economic dimensions of the debate.


1. Press release, U.S. Environmental Protection Agency. (accessed March 17, 2014).

2. (accessed August 7, 2013).

3. U.S. Environmental Protection Agency, “An Assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay, Alaska (Second External Review Draft),” U.S. EPA report 910-R-12-004Ba-c (April 2013).

4. G. Knapp, M. Guettabi, and S. Goldsmith, The Economic Importance of the Bristol Bay Salmon Industry (Anchorage, AK: University of Alaska, Institute for Social and Economic Research, April 2013).

5. H. Ghaffari, R. S. Morrison, M. A. deRuijeter, A. Živković, T. Hantelmann, D. Ramsey, and S. Cowie, Preliminary Assessment of the Pebble Project, Southwest Alaska (Vancouver, BC, Canada: prepared for Northern Dynasty Minerals Ltd., by WARDROP [a Tetra Tech Company], February 15, 2011).

6. U.S. EPA Assessment ES-17, 6–10.

7. G. Y. Parker, F. M. Raskin, C. A. Woody, and L. Traskey, “Pebble Mine: Fish, Minerals, and Testing the Limits of Alsaka's Large Mine Permitting Process,” Alaska Law Review 25, no. 1 (2008): 1–50, at 11. See also Northern Dynasty Minerals Ltd., “Advancing America's Most Important Mineral Deposit” (2008), available at (accessed January 14, 2010).

8. In 2008, antimining groups lobbied for a ballot measure, Proposition 4, which sought higher water standards for large-scale mining projects in Alaska, like the Pebble project. The ballot measure evolved into the most expensive political campaign in state history, with a total of $12.5 million spent. See E. Bluemink, “Pebble Players May Face APOC Penalties for Proposition Fight,” Anchorage Daily News (30 September 2009), (accessed January 14, 2010).

9. D. E. Schindler, R. Hilborn, B. Chasco, C. P. Boatright, T. P. Quinn, L. A. Rogers, and M. S. Webster, “Population Diversity and the Portfolio Effect in an Exploited Species,” Nature 465 (2010): 609–612.

10. J. A. Fall, T. M. Krieg, and D. Holen, “Overview of the Subsistence Fishery of the Bristol Bay Management Area.” Special Publication No. BOF 2009-07 (Anchorage, AK: Alaska Department of Fish and Game, Division of Subsistence, 2009).

11. L. Riemers, “EPA's Power Grab Will Hurt the Nation,” The Hill (August 31, 2012),



14. (accessed October 10, 2013).

15. Department of Defense, Strategic and Critical Materials Report on Stockpile Requirements (Washington, D.C.: January 2013). Further, a 2007 study by the National Research Council defines copper as essential but “not yet critical, in that the risk of supply restriction is low.” National Research Council of the National Academies. “Minerals, Critical Minerals, and the U.S. Economy” (Washington DC: National Academies Press, 2007), 7.

16. Northern Dynasty Minerals Ltd, “Summary Response to US Environmental Protection Agency (EPA) Revised Draft Bristol Bay Watershed Assessment (BBWA) Report” (May 2013), Appendix A, p. 3.

17. T. G. Yocum and R. L. Bernard, “Mitigation of Wetland Impacts from Large-Scale Hardrock Mining in Bristol Bay Watersheds,” Seattle Journal of Environmental Law 3 (2013): 71–100, at 97. See also P. S. Kemp et al., “Qualitative and Quantitative Effects of Reintroduced Beavers on Stream Fish,”Fish & Fisheries 13 (2012): 158.

18. 40 C.F.R. S 230.1 (c).

19. 40 CFR S 230.91 (b)(1).

20. S. Snyder, “Bristol Bay Wild Salmon, Pebble Mine, and Intractable Conflict: Lessons for Environmental Studies and Sciences,” Environment 56, no. 2 (2014): 17–26.

21. S. Army Corps of Eng'rs Alaska Dist., RGL ID No. 09-01, Alaska District Regulatory Guidance Letter 8 (2009),; see also discussion in Yocum and Bernard (note 17), 80.

22. Yocum and Bernard, note 17, 72.

23. Yocum and Bernard, note 17, 91.

24. J. Eilperin, “The Biggest Environmental Decision Facing Obama You've Never Heard of,” The Washington Post, May 31, 2013, (accessed August 7, 2013).

25. M. V. McGinnis, ed., Bioregionalism (New York, NY: Routledge, 1999).

26. E. P. Weber, Bringing Society Back In: Grassroots Ecosystem Management, Accountability, and Sustainable Communities (Cambridge, MA: MIT Press, 2005).

Samuel Snyder received his doctorate from the University of Florida, where he studied the dynamics of community collaboration among multiple stakeholders in fisheries conservation and restoration. He has worked in Alaska, devoting all of his time to conservation of Bristol Bay's wild salmon ecosystems and working with Alaska Native groups, commercial fishermen, and sportsmen.

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