Comments to EPA - deadline is May 31st, 2013

To Whom It May Concern:

I offer these comments in response to the Bristol Bay Watershed Assessment and the proposed Pebble Mine.  I want to first thank the Environmental Protection Agency for listening to the voice of the people in the region, for undertaking this watershed assessment and for utilizing peer-reviewed science in their assessment. 

I encourage the EPA to uphold the considerations of the National Environmental Policy Act (NEPA) in their decision-making process.  And there is a decision to be made – whether to sit by idly and allow this thing to come into existence, ultimately wiping out our world-famous sustainable sockeye and Chinook salmon runs, or whether to exercise their 404(c) veto power and exempt the highly productive Bristol Bay watershed area from mining.  The fate our region and future generations of Bristol Bay residents, commercial and subsistence fishermen are counting on you to make the right decision. 

NEPA requires federal agencies to “use all practicable means” to do the following:

1.      Fulfill the responsibilities of each generation as trustee of the environment for succeeding generations;

2.      Assure for all Americans safe, healthful, productive, and aesthetically and culturally pleasing surroundings;

3.      Attain the widest range of beneficial uses of the environment without degradation, risk to health or safety, or other undesirable and unintended consequences;

4.      Preserve important historic, cultural, and natural aspects of our national heritage, and maintain, wherever possible, an environment which supports diversity, and variety of individual choice;

5.      Achieve a balance between population and resource use which will permit high standards of living and a wide sharing of life’s amenities; and

6.      Enhance the quality of renewable resources and approach the maximum attainable recycling of depletable resources. 

If EPA does not exercise their 404(c) authority, and allows the Pebble Mine (and subsequent future mines) to be developed, it will be in breach of its duty to future generations, because subsequent generations of residents and commercial fishermen will be deprived of the privilege of harvesting our life-giving salmon from the rich Bristol Bay waters.  The Watershed Assessment indicated that there is an inherent risk with mining operations, and with the introduction of culverts, roads, oil spills (some of which have already happened), and other such disturbances to the watershed, there WILL be an impact that will be measurable, and likely irreversible.  The Pacific Northwest has been struggling to rebuild their salmon stocks after the introduction of hydroelectric dams in the region and other such disturbances, such as logging, population growth, mining, and roads.  It is practically impossible to rebuild stocks once they are damaged beyond a certain point.  Studies on runoff originating from copper from brake pads on roads in Oregon indicate that salmon are extremely susceptible to minute quantities of copper.  Because this is a copper mine being proposed, this should be a huge red flag to the EPA that this is an unsustainable project that will result in depletion of our salmon resources for future generations.

Allowing Pebble Mine to be permitted by the State of Alaska (who has never denied a large mine permit to date), would violate NEPA’s second requirement, as it would result in an unsafe and unproductive area.  The mining executives have touted the term “no net loss” in their propaganda, but I find it completely disingenuous that they can simply “create” wetlands.  There is no such thing as “no net loss” as the loss will be to the 22 square miles of disturbed area that the mine would create.  Once it is disturbed, it will never be restored to its original natural productive state.  It will be not only “unaesthetic”, but downright ugly.  The tens of thousands of visitors who come to these river systems, paying thousands of dollars for the vacation of a lifetime will not appreciate a 2 mile wide open pit mine.  Additionally, the dust and other disturbances will disturb the migrating caribou and moose, and will translate to dust particles of toxic heavy metals blowing onto our pristine tundra areas where people currently pick berries and do their hunting. 

The Bristol Bay watershed area has been providing wild salmon for the people, and for thousands of commercial fishermen who come to the region to harvest the catch for hundreds of years.  The use of this area for productive salmon rearing habitat is the highest beneficial use possible.  Mining is one of the riskiest occupations in the world.  Based on past predictions of water quality, 75% of the time, the mining companies have gotten their water quality predictions wrong.  For instance, the Pebble Partnership has touted highly that salmon and mining can co-exist, but 3 out of 4 past mines tell us a very different story.  There are literally dozens of instances where mining operations have either harmed or completely destroyed fisheries around the world.  I would hope that EPA would learn from the mistakes of other mines that have failed and not go down that road.  Bristol Bay is too precious to simply throw away to mining.

The Bristol Bay subsistence way of life is a historic and cultural stronghold for the indigenous people of the region.  Throughout the past several hundred years of genocide, introduced disease, forced assimilation, and cultural change, one constant binds the indigenous people to the land – the subsistence resources that bring families together to share in the harvesting, processing, and preserving of the catch.  Our salmon resources are a tremendous opportunity for our families to work together, from elders to pass on the knowledge of this important food, and for us to laugh and work together.  Some of my most memorable moments with my grandmother and great-grandmother are around the smokehouse, and splitting fish.  Those traditions cannot simply be replaced or compensated for.  They are priceless, and once lost, will be lost forever.

As trustees of this land for future generations, the people of the region have overwhelmingly voiced their opposition to the proposed Pebble Mine.  The Pebble Partnership’s own website has indicated that the mine would only provide some 153 local jobs.  Many of these would not be the high-paying jobs that are so highly touted by the State of Alaska and the mining executives.  The proposed Pebble Mine would not enhance the quality of life for people of the region.  The mining executives have indicated that it would be “camp style” living – 2 weeks on and two weeks off.  As somebody who has had to travel for work, I can tell you that it does not result in a harmonious family life or routine to have one parent absent half of the time.  The social implications of this type of system would be detrimental to the already struggling families in the region, and would result in higher rates of domestic violence, and likely, drug and alcohol abuse.  Several of my close friends are single parents and I see how they struggle to keep their families intact.  I would not want to see this type of social system being imposed on local mine workers in the region. 

Finally, the 6^th consideration of NEPA would not be met with this project.  Rather than “enhancing the renewable resources,” it would put them at great risk.  Until our landfills become mines and we have harvested all of the usable metals out of existing cells, perhaps then we should consider opening up new lands to mining.  Over 80% of gold goes directly into jewelry.  Jewelry for self-adornment seems like a very frivolous way to put our precious salmon resources at risk.

For the sake of my family, for the people of the Bristol Bay region, and for future generations of Bristol Bay fishing families, I implore the Environmental Protection Agency to exercise their 404(c) permitting authority and permanently protect the Bristol Bay headwaters and watershed area.

Thank you for your consideration.

Regards,

Izetta Chambers

Founder, Naknek Family Fisheries

4^th generation commercial fishing family member

Mother of a 5^th generation commercial fisherman

Wife of a Bristol Bay commercial fisherman

Tribally enrolled member, Naknek Native Village

Bristol Bay Fishermen Raise the Bar on Salmon Quality

Bristol Bay fishermen rapidly raising the bar on salmon quality

published in SEAFOOD.COM NEWS, Bristol Bay Times/Dutch Harbor Fisherman Opinion by Izetta Chambers  March 5, 2013 Izetta Chambers, is the Alaska Sea Grant Marine Advisory Agent in Dillingham, Alaska, where she lives.  The huge increases in frozen sockeye salmon have only come about as harvesters in the Bay have steadily increased quality through better care and handling of the catch. In 2012 for the first time, a majority of the catch was chilled or iced before reaching the plants. Having grown up in a fishing family in Bristol Bay, I have watched and taken part in the slow and sometimes painful journey to improve salmon quality. When I was little, I remember how fishermen used pews—essentially pointed stakes—to stab the fish in the head or belly and fling them into a delivery truck. It was an irreverent way to treat food. Fortunately, the practice stopped in the late 70s or early 80s. In those days, nobody used ice or refrigerated seawater. Bleeding the freshly caught salmon was unheard of. But I remember people on the Naknek beach being proud to deliver their fish in a timely manner. My family never let their fish sit long in the boats. It was a matter of pride to deliver the catch quickly. As they say, change happens slowly. One small change was the switch by processors away from the knotted-rope brailer bags that inflicted body-bruising damage to salmon pressed against the bottom and sides of the bag. The new bags used a flat mesh design that did far less damage. And when mesh bags got smaller—another small but important step—quality improved again. The really big changes began in the 90s, when fresh, high-quality, farmed salmon began showing up in markets around the world. While farmed salmon producers were going after the younger generation's growing demand for fresh and frozen salmon, we here in Bristol Bay were still chasing the World War II generation's desire for salmon—together with bones and skin—in cans. The appearance of farmed salmon did get fishermen to pay more attention to the quality of their product. But the road to higher quality had its potholes. In Naknek, I saw many different operations come and go, each with the notion that they were going to do things differently, with the focus on quality. Most of these early endeavors didn't pan out, but they did get all of us talking about how to improve the quality of our salmon. The 90s also were marked by falling salmon prices, which led to seafood processing plant closures and consolidation of the industry. Fishermen were hit hard, too. It wasn't easy to make a living as a fisherman when the price was only 40 cents a pound. A lot of fishermen packed up and left during this time. There didn't seem to be any easy solution for how our fishery was going to survive, much less improve. Looking back, these painful changes were needed. I'm still too proud to outright thank farmed salmon, but I have to admit that farmed salmon was the kick in the pants we all needed to adapt to new realities in the marketplace. Of course, it took time, and we still have a ways to go. But good ideas like careful handling of each fish and icing or refrigerating the salmon at sea have taken hold. More change came when the Bristol Bay Economic Development Corporation started making investments in such things as village ice machines, slush bags, and insulated totes. It has helped a lot that such ideas were promoted with education and training by the Alaska Sea Grant Marine Advisory Program, the Bristol Bay Economic Development Corporation, and, more recently, the Bristol Bay Regional Seafood Development Association and the Alaska Seafood Marketing Institute. Some people didn't believe that we could make real gains in salmon quality. When I tried to convince my mom in the early 2000s to use her slush bags and to ice her fish, she said, "Why? We deliver our fish within 30 or 40 minutes to the beach, and they get iced there. Why should we ice them onboard when we don't get paid extra for it?" It was a good question. The answer would come as the surviving seafood processors began to pay higher prices for higher quality salmon—not to pack into cans, but to turn into beautiful frozen and fresh fillets and whole salmon to claim markets dominated by farmed salmon. These days, only about one-third of the sockeye harvest ends up in cans, a percentage that has fallen each year since 2008. The rest is sold as fresh and frozen whole or as fillets. Thanks largely to the efforts of fishermen and processors, as well as both public and private groups, the volume of Bristol Bay salmon delivered in ice and refrigerated seawater has gone up each year. In 2012, for the first time, the majority of the 131-million-pound harvest was either iced or put into refrigerated seawater at the time of harvest. This focus on quality has had tangible benefits. The higher prices paid for salmon have generated bigger paychecks for the region's fishermen. The ready availability of high-quality salmon also has spawned new businesses that specialize in value-added seafood products, and has spurred more than a few fishermen to process their own catch and sell directly to restaurants and seafood shops. The sea change that is happening in Bristol Bay is a testament to multiple groups working to spread the gospel of higher-quality seafood. It also is a story of survival through adaptation. Preserving our fishing identity and way of life for our children required us to change, and will require continued change. Can we stop here? Of course not! We have to continue to adapt and respond to global market forces. But as fishermen and caretakers of the salmon resource, we now better understand that wild salmon is not the only—or even best—selling point. Wild salmon of exceptional quality must be our selling point. Izetta Chambers is the Alaska Sea Grant Marine Advisory Program Agent for Bristol Bay. She lives in Dillingham and participates in the Bristol Bay salmon fishery with her family.

FDA accepting comments on genetically modified salmon

FDA accepting comments on AquaBounty "Frankenfish" genetically-modified salmon application.

Here is the link to the notice in the Federal Register: https://www.federalregister.gov/articles/2012/12/26/2012-31118/draft-environmental-assessment-and-preliminary-finding-of-no-significant-impact-concerning-a

Here is one article from a scientific journal discussing some of the potential impacts on the wild salmon populations: http://www.rowan.edu/colleges/csm/departments/biologicalsci/faculty/obrien/GMO%20Another%20Example%20of%20Reading%20.pdf