the government of Alaska should give Pebble Mine a fair chance

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By ignoring available evidence gathered by Pebble and from public sources, the Assessment authors overstated the presence of salmon living where the mine is assumed to be constructed. It assumes that no mitigation will be available based on a report by avowed mine opponents who represent anti-Pebble activists. This assumption is belied by decades of evidence about the effectiveness of salmon habitat mitigation techniques.

For scientific support, the Assessment uses numerous studies by anti-mine activists. EPA quietly commissioned Peer Reviews of seven studies authored by anti-Pebble activists, presumably in hopes of bolstering their credibility. No studies supportive of the Pebble Project received any such treatment, including the Pebble Partnership’s $150 million contribution of the most comprehensive and relevant environmental data set available on the region. When EPA quietly had seven of those studies peer reviewed, EPA’s own peer reviewers found them to be biased and unreliable, but EPA used them anyway.

EPA manipulated the peer review of the Assessment itself in a way designed to minimize criticism of the Assessment. EPA violated its own standards when, during the first peer review, it unduly restricted the schedule, shielded the peer reviewers from public comments, and then held a closed-door meeting with the peer review panel. During the second peer review, EPA shut out the public entirely, completely violating its own standards for transparency.

For the first peer review, EPA provided a very narrow charge to the Peer Reviewers for their review of the initial watershed assessment draft in 2012, and limited public access to the Peer Review panel to three-minute per-person verbal presentations. EPA met with Peer Reviewers in private, refused to release their full reports on the watershed assessment document and subsequently published a significantly watered down summary report.

Notwithstanding these limitations, the Peer Reviewers gave voice to some very serious criticisms of the watershed assessment, some of which are presented in this submission. For the second draft of the watershed assessment in 2013, EPA provided its charge to Peer Reviewers in private. In fact, no public access to the Peer Reviewers was permitted whatsoever, and EPA recently reported it may publish the final draft of the watershed assessment before any Peer Review input is made public. While EPA’s management of the Peer Review process in 2012 fell well short of the agency’s own guidelines for such processes, the 2013 Peer Review made an open mockery of them.