September 6, 2022 — The following was released by the National Fisheries Institute:
Dear Administrator Regan & Regional Administrator Sixkiller:
The National Fisheries Institute (“NFI”) submits these comments to the U.S.
Environmental Protection Agency (“EPA”), with respect to the EPA Clean Water Act (“CWA”)
Section 404(c) Proposed Determination to prohibit and restrict the use of certain waters in the
Bristol Bay watershed as disposal sites for the discharge of dredged or filled material associated
with the Pebble Deposit.
NFI supports EPA’s updated, Proposed Determination to veto development of the Pebble
Limited Partnership’s 2020 Mine Plan. If finalized, EPA’s Determination would protect the
Bristol Bay watersheds and rivers that support the world’s largest and most economically and
ecologically valuable sockeye salmon fishery, a fishery that in the most recent harvest accounted
for 57 percent of the world’s sustainable wild salmon harvest. The Pebble Mine project poses a
significant threat to the Bristol Bay fishery. The project as proposed by the Pebble Limited
Partnership (“PLP”) should not proceed.
NFI is the nation’s largest seafood trade association and represents every facet of the
commercial seafood supply chain, including harvesters, processors, exporters, importers,
wholesalers, distributors, retailers, and seafood restaurants. NFI member companies include
Alaska-based harvesters, vessel owners, processors, and Native Corporations. These producers
catch, land, process, and supply seafood products – including Bristol Bay salmon – to customers
across the United States and in markets around the world. In the process, salmon producers
employ thousands of workers and support remote Alaska communities and the families those
communities sustain.
As EPA recognizes, Bristol Bay is home to the largest sockeye salmon run on the planet,
and it ranks as one of the most valuable fisheries in the United States. The Bristol Bay salmon
fishery, which is subject to stringent management requirements established by the Alaska
Department of Fish and Game, in fact incorporates five specific fisheries. It is among the most
sustainable major fisheries in the United States. In 2021 alone, 66.1 million sockeye salmon
returned to Bristol Bay, with a record commercial harvest of 40.4 million fish.
This represents a staggering 57 percent of the world’s wild salmon harvest.2
The Bristol Bay harvest plays a crucial role in commercial and subsistence salmon
fishing alike. According to a recent estimate, the Bristol Bay sockeye fishery alone provides
over 15,000 jobs and generates roughly $2 billion dollars in annual economic activity.3
These jobs help make Alaska a commercial seafood hub and help U.S. producers compete in seafood
markets across five continents. Bristol Bay salmon gives these producers a product tailor-made
for domestic and overseas consumers seeking a sustainable, premium, center of the plate fish. In
addition, the Bristol Bay sockeye fishery is essential to subsistence fishing that takes place
throughout the watershed that the Pebble Mine project would threaten and in Bristol Bay itself.
Subsistence fishing, including of sockeye salmon, has been a tradition in the region for
generations, and it, too, is essential for Alaska communities to continue to thrive.
There is also a public health dimension to the proposed Pebble Mine project. Heart
disease remains one of the nation’s principal causes of death. Under-consumption of seafood by
Americans – and the cardiovascular problems that this under-consumption invites – causes an
estimated 88,000 premature deaths in the U.S. every year.
The Dietary Guidelines for Americans – the government’s principal nutrition policy document – recommends that people eat
2 to 3 servings of seafood each week. And salmon is a nutritional powerhouse, high in protein, healthy fats, and nutrients such as calcium and Vitamin D, and low in saturated fats and additives. Salmon abounds in the omega-3 fatty acids that are critical for cardiovascular and cognitive development in adults and children alike. These benefits are especially important for
Alaska communities and native populations, who regard the locally caught salmon they feed
their families as an indispensable part of their way of life. Any effort to address the seafood
consumption shortfall the DGA highlights must include salmon.
Development of Pebble Mine plainly threatens this fishery – and in turn the companies,
communities, families, and consumers that rely on the fishery. Both EPA and the U.S. Army
Corps of Engineers have determined that the project would irreparably harm the Bristol Bay
fishery. If fully developed, Pebble Mine would generate billions of tons of toxic mining waste
that would feed into the Bristol Bay waters. According to the scientific review conducted by
EPA, the mine as proposed by PLP would destroy more than 100 miles of streams and 2,113
acres of wetlands around Bristol Bay, permanently degrading salmon habitat in Bristol Bay’s
headwaters.Industrial development that adheres to appropriate environmental safeguards can
be acceptable. But in this case, it is clear that PLP’s proposed Pebble Mine would undermine the
entire Bristol Bay salmon fishery.
Without CWA Section 404(c) protections in place, Bristol Bay’s future is at risk, creating
economic insecurity for seafood workers, communities, salmon supply chains, and businesses
across the country. In the event that degraded habitat causes the fishery to decline, that will have
immediate and long-term economic and social consequences: loss of income for seafood
workers, reduced seafood supply, increased prices for a highly popular seafood item, diminished
dietary outcomes for consumers, and even destabilized communities in the affected watershed.
This is no way to treat one of the crown jewels of the American fisheries empire.
The Pebble Mine proposal has generated widespread opposition from Alaska Natives,
Tribes, Bristol Bay residents, commercial fishermen, seafood processors, and environmental
advocates. Bristol Bay must be permanently safeguarded to ensure it can continue to provide
jobs, revenue, cultural traditions, and sustainable seafood for Americans and consumers around
the world. Accordingly, NFI urges EPA to finalize permanent CWA protections for Bristol Bay.