U.S. Environmental Protection Agency 

Draft Bristol Bay Watershed Assessment 

Record of Public Comment Meeting 

Nondalton, Alaska - Thursday, June 7, 2012 

 

[00:00:00.39] 

Will Evanoff 

This will be short and sweet. In representing the Nondalton Tribal Council and the tribe of 

Nondalton, I would like to say thank you for initiating this study and focusing on the part that 

documents the subsistence, nutritional, social and spiritual importance of salmon to the 

Denai'ina people and other native groups in the region. This information is vital to the survival 

of our culture and we appreciate having our voice and perspective be heard at a local level. 

Nondalton has already been heavily impacted by the mining exploration in the area. In the last 

six years, there has been a steady increase in visitors to the village, including scientists, 

researchers, reporters, mining companies, anti and pro Pebble people. The Nondalton Tribal 

Council, who is under the authority of a federally recognized tribe, has limited resources and 

staff to address the issues concerns and visitors coming into the community. There is an 

increased level of stress due to Nondalton Tribal Council opposition to the mine. The survival of 

our culture directly depends on the health of our land, the fish and the wildlife. No amount of 

money or jobs can replace our way of life and our culture. 

[00:02:12.20] 

Jackie Hobson 

My name is jack Hobson and I am a member of the Nondalton Tribal Council and we have been 

dealing with this issue for a long time. We are one of the six tribes who approached EPA and 

asked them to use their 404c authority to stop the Pebble Mine. But, they said they couldn't do 

that, they had to go through this process and that is what they are doing now. It has been going 

on over a year and I am very satisfied with what they have been doing, how they have been 

doing it and how they have been involving everyone in it. As you can see there are a fair 

amount of people in here and they are from all over, not just Nondalton. It is a whole Bristol Bay 

issue. Water is very important to everything we do. If you take a look outside, everything is 

coming back to life is due to water. Our bodies are made up of 70% water. The earth is 90% 

water, but if you think about it only 1% of the water is drinkable. A lot of things depend on 
water, even in the water there are things that depend on the nutrients that come from salmon. 

The salmon swims up the stream and they die, they go to the bottom of the lakes and streams 

and then they feed other invertebrates and microorganisms that feed fish and other stuff. As 

you all know, fish have been important to us all our lives. Not 4,000 lives but a millennium. 

That is what we are trying to do is protect our way of life our culture and the fish for the next 

generations to come. These are renewable resources that will always be around as long as we 

take care of it. Another thing, these fish and animals they can't speak for themselves and that is 

why we are here. We are the caretakers of the land. Our ancestors took care of it for us and 

now we have to pass it on to the next generation. What we do and how we do it will affect the 

next generation. We don't want to leave them with things that they are going to end up fighting 

forever. That is not the native way. We are asking EPA to use your authority to do what you 

have to do to protect our culture and our way of life. 

[00:05:56.10] 

Harry Kashnikoff 

My name is Harry Kashnikoff and I got to thank the EPA for coming here to speak up about 

what they are doing and I'm glad they are here and I hope they use the 404c. I am for 404c, 

because it's our land and it's our life. We have lived here all our lives and we don't want to lose 

it. I think our ancestors the people up there dealt with the same thing and we want our kids to 

live the same kind of life we did. Fishing, hunting, drinking the water and we don't have to worry 

about pollution. I am in support of 404c. 

[00:07:15.12] 

Nancy Delkittie 

Good afternoon welcome to our village. I would like to thank EPA for all the hard work you did 

on this assessment. This will help protect our clean water and our home, as we are not getting 

any kind of assistance from our state of Alaska government. My name is Nancy Delkittie. I am 

a Denai'ina, an Athabascan Indian. This village is my home. We are very rich people in our 

culture, our resources, plants, animals and salmon. They all need clean water. That is 

including us, the Denai'ina people of the land. But only because we are so blessed to have 

clean water. Salmon have been a great part of our diet for generations and will be in the future. 

When I was young, 11 years old in 1960, we didn't have freezers. I remember how busy - not 

just my family, but the whole village was in preparing for the summer salmon to come. 
Preparing the smoke houses, the drying racks, getting each smokehouse full, getting wood for 

the smokehouses. In the summer, our village came alive when salmon came. Our people 

would eat well. My Mom cooked salmon three times a day. Then when the berries ripened, 

my Mom would make a desert with the salmon as we still do today. Families worked all summer 

harvesting salmon. When we got done with the eating fish, we would harvest the salmon for our 

sled dogs. My Mom had two teams of dogs. Most families had two smokehouses, one for 

eating fish and one for dog food. Our parents and elders learned from our ancestors and they 

taught us at an early age how to harvest the salmon, berries and other plants. They also taught 

us how to salt salmon, the birds and beaver for winter. We also have a water holiday. On this 

day we show respect celebration to the water. It is a day we give the water a rest. We can't 

travel on water. On that day we give thanks for water the life giving gift, not only to the people 

but to the fish, plants and animals that need water. Salmon is known after 60 years that I know 

of, they are still in our diet today. Salmon will be here for the next generation to come. Without 

these we cannot exist as Denai'ina people. Are village will die. People will move. Our salmon 

will be no more. Our clean water will be polluted for mining. Thank you for helping to save our 

homes and food from the mining companies. We have been here for generations. Mining has 

been dividing our people for the past six or seven years. Family against family, brother against 

brother. This has to come to an end. 

[00:12:01.04] 

Clara Trefon 

I am the tribal administrator for Nondalton. I thank EPA for coming here and doing this activity. 

I ask that you do not extend the timeframe due to the importance of getting this done. There 

isn't enough information on other fish in the study such as rainbow, Dolly Varden, white fish and 

pike and other fish that we eat that use the mine area up there. And, migratory birds, that is 

really important to us. The place where they have the Pebble site is caribou calving ground and 

also used to be a spring fish site for our people. Can you look at the University of Alaska 

Fairbanks information on our culture and our people the Denai'ina people on how we use the 

land, where we fish, where we hunt and how we live and I don't think there is enough 

information on the culture? Because the state doesn't recognize tribes, we have limited input on 

the process for the permitting process because it is a state function. We are not recognized, so 

we don't have a voice in the state system. That should be noted in your study too. We have no 

recognition from the state and limited from Pebble. It is just based on the state regulations that 

don't include us. It is important to note that. Thank you and please don't extend the time. 
[00:14:08.19] 

Kristi Jefferies 

My name is Kristi Jefferies. I am a Denai'ina Athabascan Indian raised in Nondalton and I am 

proud to be raising my family here in Nondalton. My husband and I have two daughters aged 

six months and seven years old. Thank you for stepping in a conducting this scientific 

assessment on likely impacts for proposed large-scale mining. The assessment is well written 

and validates when we suspected, that at a minimum 10s of thousands of acres that support the 

fish and wildlife we rely on will be destroyed. It shows that billions of tons of toxic waste will 

remain and we will have to contain, manage and treat it for hundreds of years perhaps forever. 

Such harm and long-term threats to the environment are clear and unacceptable. Please take 

action under 404c to prevent disposal of billions of tons of toxic waste in our wetlands. Please 

help us preserve our fish, wildlife and culture. The watershed assessment in my view 

underestimates the impacts that even underestimate are unacceptable. I am intimately 

connected to this region and I am concerned about our ancestral lands. I want to make sure 

that my children and grandchildren will be able to use the lands abundant resources for 

subsistence in the future and that they retain their culture. As a Nondalton Tribal council 

member, it is my responsibility to preserve the land and water for future generations. The land, 

water, fish and wildlife have allowed us to live in this area for thousands of years. This land is 

our home it is the land of our ancestors. It is our right as residents of this region to protect and 

preserve our traditions, culture and spirituality. For these reasons I strongly oppose the Pebble 

Mine as it presents unacceptable risks to our subsistence and culture. The watershed 

assessment shows us that no one can guarantee that industrial mining of copper is 

environmentally safe and rather will not endanger our land, waterways and way of life. It will 

damage our pristine land and water. It will harm the wildlife and vegetation, and most 

importantly the fishery that we rely on for food. I do not see that benefit, especially long term 

from this mine. It will jeopardize the land, water fish and wildlife and most important the people 

in our village. The people should be able to voice their opinion and be heard. I ask you to 

please take into consideration what is at stake here. Not just the environment we live in but also 

the welfare of our people and our traditional and cultural way of life is on the line. I know mine 

proponents want to delay the assessment because it is well done and underestimates the likely 

impacts and is based on good science. A 60-day comment period is sufficient. Please finish 

this is a timely manner and use the 404 c. Thank you very much for considering my concerns. It 

is very important and means a lot to me and my family. 
[00:18:12.20] 

Agnes Petrowski. 

My name is Agnes Petrowski. I am the VP of the Newhalen Tribal council and I also work for the 

Newhalen Tribe as the roads coordinator. I want to talk about the deadline of the assessment. 

First and foremost I am a mother and a grandmother of two years old and a month old. As a 

grandmother it is my responsibility to fight for and preserve our traditional rights for my 

grandchildren and future great grandchildren so they can practice subsistence way of life for 

generations to come. While I applaud the assessment as a beginning, by all means it will not be 

the end, especially when the people of Newhalen continue to live off the land. The comment 

period needs to be extended to early winter. EPA has chosen one of the busiest times of year 

in Alaska to hold hearings. Our people are on the move. Some are getting ready to commercial 

fish and working other summer jobs. Newhalen is a seasonal village. Our people need to work 

when jobs become available during the summer. So we will subsistence fishing and gathering. 

The executive summary doesn't allow me a sufficient time to express my concerns let alone 

those I serve. Time must be provided for our region to review the document and talk about it 

among ourselves in different settings and come to our own conclusions before the draft 

assessment. You were talking about the land and wetland that we depend on for subsistence. 

The tribe needs to be provided with adequate time to review and understand this assessment 

and what impacts it will have on our traditional lands. We are asking that more time be allowed 

and to extend the comment period. 

[00:21:22.05] 

Courtney Gomez 

My name is Courtney Gomez and I am a Chief on the Currying Tribal Council in Dillingham. 

Thank you for coming here today and to our region to meet with us all. I feel like the 

assessment is exceptional. I left Bristol Bay when I graduated from high school and went off to 

college and became a trained scientist returning to Bristol Bay to work from the BBNA natural 

resource department for the last seven years. It was only a couple of months ago that I traded 

careers so that I am no longer affiliated with any funding source so that I can be a more active 

citizen and choose for my tribal council and fighting for the rights of our people to protect our 

lands and waters. We feel very strongly that the timeline is sufficient and everyone who cares 

enough to comment has taken time out of their day. Look at all of us who made time to be here 
today. I am not a paid representative, paid by any organization to be here. I actually took 

vacation leave from my own job to be here today. We support the document. It is very strong 

and thanks you for taking the time. 

 

[00:22:35.18] 

Moses Kritz 

Thank you for being here. I thank the Nondalton folks for their generosity in allowing us to share 

their traditional foods. Thank you for allowing me to speak on behalf of our village. I am from 

Togiak and I'm the President of our traditional council. We are the western most part of BB. 

The reason that I’m here today is to ask you to help us. Our ancestors told us that water has 

sustained our way of life for thousands of years. I wear several hats. Traditional Council 

President. BBNC as a director. I'm also with BBEDC. It is a sufficient amount of time for 60 

days for the assessment and I think that a 404c is a must to protect our lands and waters. On 

another note, BBNC has always stressed fish first. I believe in it and I hope that you listen to us 

and protect our way of life and culture. Under BBEDC - history is very important to our 

communities and its economic values. So I thank you for listening and allowing. 

[00:24:59.10] 

Olga Balluta 

I just want thank all the people who are working so hard for the water, the fish and the plants 

and thinking of what our next generation is going to need. Doing the same thing maybe. Who 

knows, I don't know. Everybody is concerned about this mine, the water the fish and the plants 

and the animals. We all use that. We all depend on that. I know that everybody is all talking 

about it. I am glad that people are coming from all over everywhere to from city and down the 

state and especially Bristol Bay who is working so hard for everybody and our fish and water 

and our land. Thank you. 

[00:26:19.08] 

William Trefon Senior 

My name is William Trefon Senior. I am an elder from Nondalton, but I live at Port Alford for 

nine years. EPA watershed assessment - I didn't know if was going on for a year and now I 

don't really know what to comment on. It is very hard for me to say something that I want to 

say. We have been in this area for thousands and thousands of years and we lived off the 
water and the water was kept clean. That is how we want the environment to keep. Our people 

are an environmentally concerned people, so I just want to say that I am for clean water and 

clean land, but I am also for economic development where our people can go to work and have 

a place to work in this live in this area. Do I see it now, there are no jobs and a lot of people are 

moving out to where they can find work. So there are getting lesser and lesser people here 

because there is no economic base. Subsistence wise, we subsist, but it is not subsisting 

anymore, it is an allocation from the state. In the past we got what we wanted when we wanted 

it. Now the state tells us when the seasons open and to get it now. Subsistence is not like it 

used to be. Still we depend on fish, we put up a lot. We must keep the environment like it is. 

I'm hoping that EPA could be there in place to step in if the mine is polluting to stop the 

pollution. I'm not prepared for this kind of testimony. I didn't know this was developed this 

much. We should have been informed more on what was happening. I have been blind to this. 

I'm not against or for the mine, but I want to see my people have a place to work here in the 

area and subsistence to continue. 

[00:29:56.23] 

Gladys Evanoff (low audio) 

I am from Nondalton. I lived on subsistence all of my life. I would like to thank EPA for doing 

what they are doing to protect our environment. Please help us, it would be the biggest mine in 

the world. It hurts me deeply, I have actually cried that our home might be destroyed and I want 

to save our fish and wildlife. I want my grandchildren to be able to fish like I did. I want to be 

using my fish camp and living off the fish and subsistence every traditional way. I've lived this 

way my whole life and I'm 77 years old. I don't like people being against each other over this 

mine. We should all live together and love one another as neighbors. It seems like it is pulling 

us apart. Money should not take people apart. We should all respect each other and allow that 

we are who we are. I worry about this big mine that is coming in. Please help us protect Bristol 

Bay from the mine. 

[00:31:46.18] 

Darlene Wygone 

I just came from Koliganek and I would like to thank EPA for coming here to hear the comments 

and to be invited here to come and speak. We came a long way living off our land and water. 

There is no separation. We are very seasonal for our traditional foods and salmon culture. I’m 

a commercial fisherman. I went down to Ekuk to set my lines and get ready for fishing and I 
also went there to pick up some greens and vegetables and then there is medicine plants that 

we live off on the land. You are talking about the effects of how a large-scale mine will affect us. 

It will affect us real. Our land and waters are like you hear a lot of these people talk about how 

we live. It is still continuing today. We would like to see that it stays protected. That it is not 

only going to affect the people around here. It affects everybody from all over. Even people 

from Red Dog mine and the people up in Barrow ask about how we are doing against the 

Pebble mine. We are still talking about it. There are a lot of people who don't want it. There 

are a lot of people who like to earn income. But, me personally I like how we are living now, 

fishing and off the land without the gold mine, even my family also and other people. I am not 

against people who work hard, but I would rather not see that. Help us now to stop the mine. 

Don't let it drag on and on. If the large-scale mining goes on, it's going to hurt us physically and 

spiritually. There is going to be a lot more like now - gold mining brought prostitution and 

drinking and alcohol and all that stuff. Throughout the years we have had to learn how to deal 

with all that stuff. It will be harder for us and who is going to help us. EPA will have to look 

somewhere else and to some other department. Please put a stop to the mine. 

[00:35:58.07] 

Valerie Engebretsen 

My name is Valerie. I work for Pebble. I have a big family who loves the outdoors and enjoy 

their subsistence way of life. Subsistence is good, but it is not paying for my bills and does not 

clothe my kids. I oppose EPA's action concerning the watershed assessment. I believe it was 

rushed. They only spent 11 months studying an area of 20,000 sq. miles and they only give the 

public 60 days to read and comment on the draft. It is during the busiest time of year for us all. 

EPA needs to give the public and themselves more time to learn and educate on these matters 

so we can make rightful and informed decisions. I also want to clarify a misunderstanding of an 

elder. We don't threaten our elders. Our people. We educate them. I want to make good 

decisions. No one speaks for me. Tribal leaders, BBNC, Nunamta. No one has the right to put 

words and false accusations on anybody. Furthermore, we also need to educate ourselves on 

the 404c as well as all the regulations that follow. The EPA needs to extend the public 

comment period time to a later date. It is insufficient and rushed. We need more time to read 

through the watershed assessment and the 404c. I'm asking if what you are saying about the 

discharge in the water can you please put that in writing. Can you clarify that? I would really 

like to see that in writing. That is all I have. 
[00:41:15.03] 

Karen Evanoff 

Hi. My name s Karen Evanoff. I am a Tribal Member of Nondalton. My ancestors have lived 

here for generations on this land, and they were the first caretakers and managers of this land 

for centuries. Looking at the assessment on line and I also looked at Pebbles assessment 

online. Compared to what EPA has, which is much smaller, Pebble goes from the floor to the 

ceiling. It is a much larger volume of information to take in. EPA is doing something on time for 

once. You are getting things done sufficiently and in a timely manner. The federal government 

has a responsibility to ensure the health of the environment and food and water for future 

generations. Overall the survival of our earth. Our earth is suffering in a huge way and it is 

because of the greed of human beings around the world. This began centuries ago when 

western society began to lose the deep connection with nature and the relationship with nature 

being an equal. Living in harmony with all that is natural on earth. I say this because (Yup'ik 

word), white people used to live in harmony with all that is on earth. Before dominance and 

exploitation took over, before taking from the land became the priority. We as indigenous 

people have held on to this relationship much longer. This area and our way of life is the last 

few of remaining cultures that rely on salmon not only for food, but as the core of our culture and 

our identity. The traditional ecological knowledge and characterization study which is this one, 

that documents the importance of salmon to the people of the region, is a vital part of the overall 

assessment. It is vital because it portrays the voice and the spirit of the people, and the social 

relationship with the fish and the wildlife, and between people in our community and between 

each community. We shared with each other. That is part of our custom. It also documents the 

sacredness of our area and the inner biological clock that keeps us in tune with the land and the 

abundance that it provides. Right now, this clock is ticking in each one of us as we anticipate 

the coming of the salmon. If we are part of the generation that has lived here for centuries and 

this intimate interconnection with salmon is within all of us, no matter how dependent we have 

become on the material world, or how immersed we have become on the western society. The 

remaining of the study besides this one needs to incorporate the voice and the science of the 

people in order to be complete. Local input into the scientific research is beneficial for many 

reasons. We know the land best where the fish and wildlife are. The kinds of fish, the 

movement and change of wildlife, the habitat area, reasons for decline, water quality, just to 

name a few. Western science is only one part. Our ancestors knew about the minerals back in 

our sacred mountains. They made a conscious choice not to talk about it openly because they 

knew that outsiders would come and hardship that would cause to our land and our people. 
The spring season we are in now, in our culture, is the most powerful season of the year. 

Everything is waking up and coming back to life. We believe that everything on earth is alive 

and has a spirit. This is called (Yup'ik word); it means it is saying something. It is crying out in 

pain because of the destruction. I hope our answer in Alaska will come from people like you in 

this room and that you will work hard to protect what we have left. 

[00:46:38.10] 

Carol Loftfield 

This is an emotional thing for the 404(c). I hope it is done in a timely manner. My name is Carol 

Loftfield and I've been a resident of Nondalton for about 20 years now. I'm a pilot, artist and 

educator. I can give you facts and figures, I could try to prove to you how important this land is 

to me, to the people who call it home, to all that live here. But the facts and figures paint a small 

picture of a much larger truth. Facts and figures describe, define and measure. If lucky, they 

allow for accurate predictions. But what we are talking about today is a deeper truth. There is 

an inexpressible beauty here. A beauty that is part of a profound relationship. The black bear, 

the brown bear, the red berries, the aqua water, the powder blue sky. These are the colors of 

my home. The colors of this land. This is the beauty. But the beauty, its color, its motion and 

meaning is much more. To wax poetic, it is a great flowing design, with creatures lives and 

habits all interwoven. The black bear munches on red berries, and then drops the plants tiny 

seeds on trails far and wide. The tiny seeds take root and start anew. Both mundane and 

marvelous, it is all in concert. Every life form singing its part in this great song of beauty and 

interdependence. This beauty, this interdependece includes you and me as much as the red 

berry and the black bear. Whether we participate through choice or not, we are still part of an 

extraordinary and magnificent grand design from the bears in our own backyard to the sparkling 

stars in the heavens above. This is our beauty. It is ours, not as in we own it. Rather, it is ours 

in the choices we make in relation to it. This is a time for important choices. Is our relationship 

with this land one of carving out in gigantic proportions its precious metals, or is it protecting its 

great flowing design. Its waters, its fish, its creatures lives and habits - all interwoven. What is 

proposed is a mining complex unprecedented in size and impact. I choose to protect this land 

against such massive extraction. Thank you for listening. 
[00:50:19.24] 

Christopher Gay 

Hello everybody. For those who don't know me, my name is Chris and I've been here 40 years. 

My father and I run a sport fishing lodge. I've been a pilot guide for the last 25 years. I know 

the area very well, including the Koktuli, and Talarik Creek, Stuyahok and all that connecting 

watershed area. Back in 96 and through 98 they said that the hydro dam would not affect our 

fisheries. Well it has. Fourteen years later and our salmon are still declined. Our fish are been 

eaten by northern pike and trout, dominant which are starting to dominate the lake system 

because of the lack of salmon. The rivers are sensitive and touchy to the salmon migration. 

The change of the smell from a small project like this should be considered in the fact of how 

large that is going to be. It is going to have such a major impact for generations. Our children 

are not going to have anything left when it is all done. I've flown this area for a long time, and I 

can tell you that it is definitely something that would have to be done extremely carefully and it's 

possible that the area could not handle that type of large development. I'm not an anti-miner, I 

like my electronic devices and copper, and gold and all that stuff. It is all about saving 

something that can be saved and protecting other things like the caribou, the fish and the 

moose. They can't protect themselves. If a small project like that should be taken into 

consideration when we are looking at something that is so big. We are already in decline here. 

Our population of salmon is trying to come back. It is trying, but it is going to need help from us. 

Thank you. 

[00:52:54.14] 

Clyde Trefon 

Hi. My name is Clyde Trefon for most of you that don't know me. There was a petition going 

around to get an extension that was stopped here. We still have phone calls that people wanted 

to sign it so that we could extend that. That was stopped here. Like what Val was saying, there 

was a rumor that an elder being threatened that they needed to sign it or go to jail. That is not 

true, that is a bald faced lie. I got on the radio and said if anyone wanted to clear this up they 

could call me about it and no one called me. With that, like what my Dad Bill Trefon was saying, 

it should be extended. He needs more time to learn about it, we all need more time to learn 

about it and it's going on too fast. If you guys are saying that you are only going to be here for 

Pebble, then you need to say it on paper that you are only going to be here on Pebble and 

nothing else, because we heard stories from people who were former EPA workers. They say 
that you guys could basically lie to us and so we want to see it on paper. Like we did in the 

past, but without the treaty being broken though. So we want to see all of this on paper that you 

guys going to be here for Pebble and Pebble only. Is that going to happen? 

(Rick Parkin asks him to send him question in writing because he is not clear on what is being 

asked for - there is an exchange for clarification) 

My family does subsistence. We like our fish. But still, nobody is going to give my boys jobs. 

Nobody is going to pay my bills. I'm not for or against. I want clean water, but we need jobs 

around here. Who is going to pay for my bills? I sure don't want to go back to welfare like I've 

been on for a while. I'm eight years sober today. I'm proud of that. No local help, just Valerie 

and my folks. I do my subsistence, I love my fish. My kids stay at fish camp from when we 

move down there to when we come back. We don't go down there in the daytime and come 

back in the evening, then all your fish is eaten by a bear. We don't do that, we stay with our 

fish. Thank you guys very much. 

[00:56:46.14] 

Charlotte Balluta 

Good afternoon. I'm Charlotte Balluta. I'm the environmental coordinator for the Nondalton 

Tribal Council. I am Denai'ina Athabascan born and raised in Nondalton. I'm (?), my mother 

was a chief's daughter and this is what she taught me. To respect the fish. I would like to thank 

the EPA for doing this assessment, because what you are doing is very important to me, our 

people and our future generations. We have to protect our culture, our environment from the 

proposed Pebble Mine. For decades, we have been caretakers of our land. It has been passed 

down to us for generations. We are very fortunate to have Lake Clark National Park to help 

protect our land and culture. The park has been a good neighbor. If the Pebble Mine or the big 

hydro along the Susitna River is developed, it would threaten our culture, water, fish and 

everything we value. The fish are very important to us. The first fish that comes in, we give it to 

the elders. Everyone comes together and we share the fish. To respect the first fish of the 

season we eat and when we are done we take the bones and put it back in the water. That is 

thanking the fish for giving its life to us. I'm a grandmother of three and I want to pass this 

tradition on to my grandchildren as my mother taught me. So that in my future, my 

grandchildren will be able to eat fish, because it is a most healthy food. I'm proud to say that 

our water is the most pure, clean, healthy water. It’s sad to see other places where they can't 
drink their water because it has been contaminated by mining. That is not what I want for future 

generations. Once again, I would like to thank EPA for being here and doing what they are 

supposed to be doing in environmental protection. Please finish the watershed assessment in a 

timely manner. I think that 60 day comment period you have for the assessment is plenty. 

Thank you for listening to us and stepping in to study this mine. You listened to us and took 

action when we asked for your help. We appreciate it and if you can help us to continue to 

protect our water and fish. Please use the Clean Water Act authority to protect Bristol Bay 

forever. 

[00:59:31.23] 

Donne Fleagle 

Thank you. My name is Donne Fleagle. I am from McGrath. I am Athabascan according to the 

migration stories that I'm learning from my job. It's very interesting about this BB area as it 

relates to the Kuskokwim. I'm from the headwaters of the Kuskokwim and how the relations and 

villages are connected. It’s been an interesting part of my job that I'm covering. I work for 

Wetaviiq, a subsidiary of the Alaska Peninsula Corporation. It represents five villages Port 

Heiden, Ugashik, South Naknek, Newhalen and Kokhanok. My job is to explain is to explain the 

EPA Bristol Bay watershed assessment. The assessment came out 10 days late, and I'm 

working very hard, I'm just one person. I will be travelling out to the communities next week and 

the week after to explain what I can on the EPA assessment. I'm here on behalf of APC and 

Wetaviiq to request that EPA consider a 120 day extension, which gives all of us the opportunity 

in our own time to review and make comments. We know that if this was in the dead of the 

winter, I wouldn’t be challenged with 2nd and 3rd quarter visits. We are now. We are right in 

the middle of summer and we have such a short window in which to perform a lot of things for 

ourselves economically and personally. We are under the gun. I have some questions and 

some comments and I don't expect any answers today. I would like to know when a regulatory 

decision on the 404(c) be made. I am in agreement with others in the room on the need for 

some additional data. Not that it would make the decision process any easier, but it would be 

good to have data. Data on fish that are in the watershed area. I'm also curious about the 

Alaska Native cultures and the impact from the mine scenario, which you know from the 

executive summary, is uncertain. I am wondering if it is possible in the world that we live in now 

to do a comparison. If it is in the continental US or in south America, or someplace where there 

is a small isolated culture that has experienced mining and we can look at the benefits and also 

the adverse impacts. Just to get an idea. To move beyond where we are at. It is mentioned in 
the Executive Summary about multiple mines. I have to ask, will others follow suit. I imagine 

they will also be subject to the Army Corps of Engineers and EPA review and the 404(c). I am 

also curious if any of these other prospects that you looked at - I think there was one called 

groundhog mountain, if there are any that are nondestructive to the streams and waters. I am 

also curious as to why the draft assessment says do not quote or cite, when my job entails 

some kinds of data that I have to put out when I have to inform other people. I also would like to 

echo what one very good thing I heard said, being from out of the area, is that the whole thing 

seems to boil down to Pebble or no Pebble. What I have seen is a lot of tension, stress and 

hard feelings from a region that I've always thought of as one, that has been able to house a lot 

of different Alaskan cultures that have such a spirit of hospitality, generosity and strength. It 

also hurts me to see friendships back away because of our various positions on this. I just want 

to say that I hope that things get better here, and I want to thank EPA for helping me with the 

job that I've had to perform and will continue to perform. 

[01:05:06.05] 

Carol Ann Woody 

So, I wanted to thank you for the opportunity to comment on the watershed assessment. I am 

Dr. Carol Ann Woody. I am a fisheries scientist and I've worked in this region since 1991. 

Since 2006, I have basically worked full time focusing on potential impacts from Pebble on the 

fisheries resource for tribes and non-profits in the area. I've reviewed most of the EPS's 

watershed assessment, and I have found that the writing, it is very well written. It is concise. It 

is clear. It is based on the best available science. You have done a good job. From my 

perspective, I think the 60-day comment period is adequate for the information that you have 

presented. If anything, I think your assessment of the potential impacts of mineral development 

to fisheries resources actually is very conservative, almost too conservative. The reason I think 

this is that you assume that the Pebble prospect would only develop 6.5 tons of their 10.8 billion 

ton estimated resource. Because all estimates of the mineral wealth, jobs and benefits from 

that particular resource are based on full exploitation of the 10.8 billion tons. The watershed 

assessment should consider impacts of expansion to the 10.8 billion ton Pebble Mine scenario. 

Mines will generally expand and expand as long as they are economically viable, as do the 

impacts. One thing that I didn't see in the assessment is that waters in the region are very low 

hardness. They cannot inputs of acid. Pebble Limited Partnership's own data indicate that it 

will be an acid generating mine. The majority of the ore in there is acid generating. Because 

the waters have very low hardness and very low dissolved organic carbon, and I studied this, 
which means there is high potential for rapid impacts. It will start with the algae and then the 

invertebrates, then the fish and it is something that is very important to consider. The 

information on wetlands in the region is not well characterized. I've spent a lot of time on the 

ground at Pebble, the Koktulis and Talarik, and it is very very wet. I think it is even wetter than 

has been characterized and the impacts will be much greater than have been characterized. As 

most of you know, of all of the fish bearing streams in Alaska, fewer than half of our streams 

have ever been surveyed. Many streams in the region have never been surveyed and looked 

at. Just a few years ago I went out and we added 105 miles of anadromous waters that no one 

had ever identified, including streams on top of the Pebble deposit. In the cumulative impacts 

section of your assessment, it indicates about 200 miles of streams or rivers could be blocked or 

destroyed Over 20 hundred acres could be converted to toxic waste dumps, which would 

require constant vigilance and maintenance into the future, possibly forever. I think it would be 

good to add to the cumulative effects section, a comprehensive table that adds to 10.8 billion 

scenario of development for Pebble along with the Groundhog scenario and three others, I can't 

remember the names right now. But I think that putting a table together so that people could 

see how many lost streams, how many blocked streams, how many areas of wetlands or 

estimated areas would be covered, all the way to the scenario, because frankly I think that if the 

Pebble Mine has 10.8 billion tons and they have potentially more based on new maps that they 

have, then they will develop all of it. I think it is only fair to the people who live here that they 

have a good idea of what they may lose. Despite some of the underestimates of likely impacts 

to fisheries, I think the watershed assessment and also the preponderance of scientific evidence 

on mining, indicated that BB fisheries would be irreparably harmed by large-scale mining due to 

how large the mines are; the type, because copper sulfide mines can create acid and copper is 

the most toxic to aquatic life. Also, where it is located in the headwaters, in a very wet region 

down the Talarik into Lake Iliamna, which is the world’s largest sockeye salmon rearing lake, 

where hundreds of millions to even billions of sockeye salmon rear 1-2 years before they go to 

see. If there were to be an impact in Iliamna, it would destroy the Kvichak run. In the Nushagak 

run, impacts there as you have indicated, it would harm not just the Chinook, but many of the 

other species. Thank you for intervening on behalf of the tribes who were worried about their 

fish and water resources, and thank you for the good job. It was very interesting. I hope you 

make some modifications, but I think you can get it done in 60-days. 
[01:11:42.15] 

Tina Anderson 

(Facilitator reads statement for commenter) I am going to read this statement for Tina Anderson 

who is Iliamna Natives Corporation Board Member. It is the local native corporation closest to 

the Pebble. They own 90,000 acres of surface land near the proposed Pebble project. We do 

not want the 404c imposed on our lands. BBNC, Nunamta and Trout Unlimited and people who 

live in Dillingham, EPA can impose it on their lands. All these organizations do not speak for us. 

Dillingham, Nondalton and all the special interest groups are going to create cultural and 

economic genocide for us. We do not live on subsistence, we need an economy. By the way, 

BBNC owns subsurface lands and do not have say over our surface lands. They should not be 

part of this assessment and all of the board members are from Dillingham or Nushagak, who do 

not have the best interest of us. We want more time to understand what the 404(c) could do to 

our native lands or people. We would like you to extend the comment period. We also want 

EPA to do a written statement that this will not be imposed on local native landholders like the 

Sacketts, who got fined 37,500 a day for supposedly violating the 404(c) Clean Water Act or like 

the Victoria Curry from Pennsylvania whose Dad was put in jail for violating Clean Water Act for 

three years and who ended up passing away after being released from jail. Reassure us in a 

written statement about what 404 regulation could be imposed on us if the 403(c) was 

regulated. The 402 has to do with subsistence. Stop trying to control us. We do not want any of 

you to decide what is best for us. We can do that ourselves. Thank you. 

[01:14:28.07] 

Heather Nudlash 

My name is Heather Nudlash. I am Denai’ina Athabascan from Nondalton. I currently live in 

Dillingham. As far back as I can remember we always had fish. My earliest memory as a child 

is down here in a fish camp. Playing in the water and helping my great grandmother and the 

rest of my family put up fish. Salmon is a renewable sustainable resource that will last forever if 

we take care of it, versus a mine that will last a few decades and leave toxic waste forever. 

Don't ruin it for short term gain. Salmon is about 75% of my food. I look forward to putting up 

subsistence every year. I hope that my son is able to enjoy the way of life, putting up salmon, 

doing the whole subsistence thing, and taking care of the land. I hope that he can enjoy clean 

water the rest of his life, along with my grandkids, his grandkids. Salmon is a super food. Clean 

water is always good to have. Stop Pebble before it ruins our culture and way of life. Stick to 
your timeline and don't extend it. If people want to make comments, they will make time if it is 

important to them. Protect our fish. Help us in our time of need. 

[01:16:09.00] 

June Tracey 

Hi. My name is June Tracey. I've been born and raised in this area here. I am the second 

daughter of (background noise) and our traditional chief Balluta. My Mom passed on in 1976. 

I've been listening to everything that has been said. I'm not used to doing ceremonies. All of 

my chada's and chidas have brought us from generation to generation on how to survive, how 

to live off the land, how to do things in the area. Every season has something to do with 

survival. I listened to everyone who is making comments and agree with everybody. I wasn't 

going to do a testimony, but my dad is 89 years old and he can't hardly talk or hear or anything. 

He said that we have to do something. Now something is being done. He told me well I'm not 

going to be around what goes on in the future, although he doesn't like to admit that he is 

getting old, but he is. He still does his subsistence. He still sets out his nets and runs around 

with his nets and still gets the smokehouse ready. This is something that inspired us children 

and the grandchildren and my great grandchildren. This is something. It is so very dear to us, 

because sometimes we take things for granted here. We live here all our lives and we take 

things for granted. We look at it, we see it and we say, oh, but it is our home and it has been 

home for generations (speaks in Denai’ina). I am proud of who I am, I am proud to say I am 

from here, and this is something that everybody has been talking about. This is our land. This 

is our life. This is thing here has been going on for the last eight years. The people come here 

and they interview. They want to know how we live. They want to know how we talk and they 

want to know how we think. But it is up to us as people who live here year round to make this 

decision. We have EPA here and I really appreciate you guys coming in and being able to voice 

our opinions and listen to us. At first I thought, they say, we are poor, but I don't think there is 

such a thing in our Denai’ina ways as poor. We are rich in every which way that you could think 

of. We don't worry about homelessness. We don't worry about somebody who don't have a 

home. We don't worry about starvation. This is something that this land gave us. This is our 

supermarket. I don't know what is going to happen in the next 10-15 year, but I would like for 

my children to come back from wherever they may be and have my grandchildren run around. 

Any my great grandchildren, there are two years old still running around with dried fish hanging 

out of their mouths and enjoying it. I would like to see this go from generation to generation that 

our young children can run around in this beautiful land and see what it is all about, able to drink 
the water and be able to stand on the beach and have cup of Chai or go down to the water and 

grab a cup of water, without worrying. Can we eat it, can we drink it? This is something that we 

really have to think about and something that I have thought a lot down at my fish camp. They 

asked me if I'm nervous and I am nervous. I really appreciate this room full of people who 

travelled all the way up here to listen to this testimony and who are concerned about what is 

going on in our part of the country. Let's take our native pride back, this is what I mean. This is 

ours. This is what we are all sitting here for and we are all concerned. Thank you. 

[01:22:09.22] 

Heidi Kritz 

Thank you guys for coming to Bristol Bay. My name is Heidi Kritz and I am from Dillingham. I 

was raised in Togiak and Aleknagik. Growing up in a traditional family, I was taught how to tell 

the difference in fish at a very young age and how to process them. My sister and I started with 

trout, like my grandma says, as you got older you graduated to better eating fish like reds, and 

more recently kings. At the start of my 8th grade year, I was asked what I knew about the 

Pebble Mine and I didn't know anything. This is when I learned that it would be the largest mine 

in North America, it would be seen from space and it would be right on the headwaters of Bristol 

Bay. I actively became involved in a group called Rebels to Pebble. I continued to educate 

people on the effects this mine could bring to the environment and to our native people. If this 

mine goes through, we would be devastated, because it runs the risk of destroying the most 

important part of our culture and our livelihood. Destroying the land we come from won't only 

affect my generation, it will affect many generations that come after mine. Please use your 

authority to help us protect our land. Thank you. 

[01:24:03.13] 

Jasmine Kritz 

Hello. My name is name is Jasmine Kritz. I am 19 years old and the oldest of 8 children. I 

grew up moving back and forth from Togiak and Aleknagik and I currently reside in Dillingham. 

The fish has been a very big part of my life. At a young age, I was taught by my grandparents 

how to split fish and the process of drying fish. Unfortunately, if the Pebble Mine is approved 

and carried through with, I will no longer be able to continue to split or put away fish, let alone 

teach my own children or grandchildren one day. Because, no matter how safe they say Pebble 

Mine could be, there is always the possibility of an earthquake or any other kind of natural 
disaster that can cause a leak from the waste made from the mine and there is no way to 

protect the rivers. I am afraid that my generation could be the last to see the beautiful fish that 

our Bristol Bay has if the Pebble Mine is approved. Please do what is right so we can keep on 

subsistence and commercial fishing off of our land. Even though the Pebble Mine could provide 

jobs for approximately 100 years, that doesn't compare what our BB has provided us since long 

before I was born and long before my grandparents were born. Bristol Bay will provide for us for 

the rest of our lives. Thank you for coming and listening. 

[01:26:11.10] 

Melissa Blair 

With all due respect to the Nondalton village elders, leaders and residents who depend on the 

land today, my name is Melissa Blair and I am the representative from the National Parks 

Conservation Association. Thank you EPA for listening and responding to the tribes of Bristol 

Bay, the people who asked you to use the Clean Water Act to help protect the clean water and 

salmon fishery of Bristol Bay. It is so incredibly important to the people and the jobs and the 

tourism and the communities into the future. Thank you for the watershed assessment. It is 

comprehensive, well written, and very understandable. You now have scientific information and 

data and traditional knowledge to understand how unique the Bristol Bay fishery is and how 

important it is to the ecosystem, jobs and culture. You also understand massive size and scale 

of the potential mining district and the risk it poses to this region. NPCA. We encourage you to 

use the Clean Water Act to protect BB. This fight has gone on long enough and it is time for 

people to have a chance to begin to heal. While the watershed assessment does examine the 

possibility of not just one massive mine, but a massive mining district being built right alongside 

Lake Clark National Park, we don't think it goes quite far enough to understand risks that a 

massive mining district would pose to the National Park, especially the mining plans that are in 

the headwaters of the Susitna River, a freshwater tributary of the Clark. You would think that 

living downstream from of a 4 million acre national park, especially one of the best and vast in 

the country would guarantee that you would have clean water and a clean environment to 

sustain you for generations. Unfortunately, as you have heard today and you have heard 

throughout the bay, that is just not the case with what looms just over these hills. The first time I 

came to Nondalton, I was in the back and I saw some folks walking around with bottles of water. 

I asked Liz Alexie for one. She said, oh no, absolutely not. You are going to drink our water, 

because we have absolutely the best water in the world. I hope that you always do. Thank you. 
[01:29:03.29] 

Bonnie Gestring 

Good afternoon everyone. I would like to thank the EPA for the assessment. I've read the 

document and it clearly highlights the severe and lasting consequences to wild salmon from 

mining the Pebble deposit. I am particularly concerned about the likelihood of acid mine 

drainage becoming a severe and lasting source of pollution to communities below the mine. 

Acid mine drainage is like opening Pandora's Box. It is long term and it is a problem that can't 

be fixed once it develops. The nation’s largest superfund site is a large copper sulfide deposit 

that is like the Pebble deposit, which acid mine drainage that will last for tens of thousands of 

years. One of the findings in the assessment that particularly struck me was the seepage from 

the waste rock piles, which they estimate in the assessment as being up to 2.8 billion gallons of 

contaminated water that would be generated every year, which would be a source of 

contamination to the upper Talarik Creek and down into Lake Iliamna if it is not completely 

contained forever. There are not examples of long term collection for the mining industries 

because they just haven't been around for that length of time either. There has been some talk 

about trying to address that acid mine drainage issue by placing the acid mine drainage 

generating waste under water either in the open pit or in the tailing pond. I want to emphasize 

that it is not a fix. Keeping the waste rock underwater while it slows the process, does not stop 

acid generation. The experience of operating mines, particularly those that are comparable to 

Pebble, there is ample documentation that industry to indicate that all tailings ponds leak over 

time. So my take away from the assessment is that all this information that was presented is 

that the assessment makes a very compelling scientific case for the need for a 404(c) to protect 

the salmon population productive and sustainable from here on out. I urge the EPA to move 

forward with the process as quickly as possible. Thank you. 

[01:31:49.06] 

Rick Rau 

Thank you. My name is Rick Rau and I live in Koliganek. I've been there five years. I've kind of 

been adopted into that village. I spent a long time in the military. My history is primarily in 

Allentown, Pennsylvania, which is right next to Bethlehem. If you are not familiar with 

Bethlehem, if you have steel built, any type of steel or iron produced between 1930 and 1975, it 

came from my home town. They mined the ore and coal from that region to the point of 

devastation. In my home town of Bethlehem, I didn't have a high school reunion and I've been 
out of high school a while. A lot of that is attributed to the mining, a lot of that is attributed to 

degradation of the water systems around. There are state parks nearby that have been affected 

by the mining. As a resident of Koliganek, I see a history repeat developing. Not just from my 

history, but from history across the nation. After reading the report and I did read it, I 

respectfully disagree about how the report is written. There are citations that need to be 

annotated a lot more thoroughly. I don't see a correct reference to anything that is cited in there 

and realize that it is draft and you say do not quote or cite anything from that source, but in my 

professional opinion the writing needs to be absolutely detailed. It seems rushed to me. I think 

that this assessment, while valid needs to be extremely well documented. I've seen things 

thrown out in my previous career in law enforcement based on the lack of people doing what 

they were supposed to do when it comes to documentation. As a federal employee, back when 

I had a job in the federal government, I saw a lot of time wasted because of red tape and a lot of 

improperly cited sources and documentation. I absolutely urge you to reevaluate whoever is 

writing your report for you and make sure that the citations are accurate and that there is 

nothing that could be left to be challenged. It seems biased. Starting phrases off with the word 

because. Detailing information that seems like it could be determined to be one sided could give 

people in the peer review committee the opportunity to discount that source or that information, 

based purely on the fact that it was biased. I definitely urge you to reevaluate that document 

and look at more of a historical value to it. There is a way to synthesize the information that you 

are putting out so that you can see others peoples history and how mining has affected their 

waters and their communities. Don't let that happen to the communities out here that have 

adopted me and taken me in when I've lost my home. 

[01:35:14.20] 

Luther Hobson Jr. 

Hi. My name is Luther Hobson. I was a fisherman for a few years down in Bristol Bay. I want 

to thank the EPA for coming here and listening to everybody who has something to say. There 

are so many people that eat from Bristol Bay all over the world and they pay cash money to eat 

all the different kind of food that comes from Bristol Bay. Maybe the FDA should be sitting at 

the table. 
[01:37:00.25] 

Tiel Smith 

Thank you for the opportunity. You have heard from me in a prior testimony, but I will add a 

little something this time. First of all, I am Tiel Smith and I was born and raised in the region 

and am now in Dillingham. Since 2004, I have worked for BBNC as the VP of lands and 

resources. I am a tribal member of the Curyung and I am a corporation shareholder. I fish in 

BB on the Kvichak at Graveyard Point, and I have for generations. I look forward to continuing 

to do that. In the few hours I've been sitting here and listening to testimony, I've gotten here 

with all these folks when I do meetings for the regional corporations. We talk about the lands 

and resources and corporate business. I won't talk about that, but I will say that each year I 

have a chance to talk about my job. It is two things basically. It is to continue to oversee the 

culture, tradition of our people and the use of their land. It is also to find responsible and 

sustainable development. It is a bit of a challenge to work those two together. BBNC will be in 

their 40th year along with the other corporations. We celebrate that and have done a 

tremendous assessment of our oil and gas opportunity and our hard rock mineral potential over 

the past forty years. But as you can see, if you look carefully in our region, there is not a 

development that we have found and we have spent thousands and millions of dollars looking 

for something to develop. We have never overlooked the fact that salmon and game have been 

so much as priority in our region. We recognize that. Especially in light of Pebble project being 

looked at so closely. We not only know about that, we have studied it and we know about many 

other prospects and exploration targets in the region, none of which today make any sense to 

develop, based on the necessity to look for increased protections to the fish and game. I would 

conclude this thought by saying; this is significant, because we own the most land in the region 

as a private landowner, 3 million acres. We do that in conjunction with village corporations who 

are also for profit corporations looking for good business opportunity, both who want to sustain. 

At this point we are looking for greater protection, so this environmental assessment lends itself 

very well to that exercise. We know about the state regulations, we know about the federal. We 

know about the types of protection that they can and can't give, so we are supportive of this 

type of action. We not only look scientifically and critically at our lands and waters, but we also 

listen to our shareholders and locals, so we have surveyed them. Not just a large number of our 

shareholders, but we have also surveyed by individual community. Each individual community 

has shown over 50% opposition to this particular large development. On a whole 81% are 

opposed to the Pebble project. At the same time, they support BBNC in their position to 

responsibly develop and sustainably develop. I find that to be a very good comparison. I would 
conclude with this one last fact, that these are rough numbers. Your meetings within the region 

have been able to yield about 250 comments. About 10 of those comments are supportive or 

neutral of mining development showing 9% opposition to large scale development and in 

particular Pebble in southwest Alaska. I think my numbers are pretty close. You have seen us 

be a part of these hearings as you've gone around. We appreciate this scientific effort and that 

is my testimony today. 

[01:43:10.27] 

Russell Nelson 

I thank you. My name is Russell Nelson and I am from Dillingham. I sit on the board of 

directors for the BBNC and not all of us are from Dillingham. We have directors all the way from 

the east side of Anchorage over to Togiak, so I just wanted to say that since I heard someone 

say that we were all from Dillingham. I’m sure some of the other board members would object 

to a statement that they were from Dillingham. Not that Dillingham is a bad place. I grew up 

there, I love it, not so much just the town, but also getting out to the cabin where we do our 

subsistence hunting and fishing. Those are the really important parts to our family. This 

watershed assessment that you are conducting this comment draft, it doesn’t take long to read 

through. It's well done. I liked the pictures in it and then the three volumes. I went through 

them, I didn't study them closely, but I did go through them and I thought, what a great set of 

demographics for this area. A lot of people try to write grants to get money to help our 

communities, I think you say not to comment of it, but I think when it is finalized we are going to 

be plagiarizing a whole bunch of it to write our drafts. It's accurate and it's up to date. I think 

you have done a wonderful job. As far as the timeline for commenting on the assessment, 

there is not really that much stuff to comment on, except to add some things that you may have 

left out, such as seismic data could be added. When you look at the Pebble seismic data in that 

big pile of paper that they sent out, they put in about seven pages of seismic data and two of 

them they copied from someone else. They make this assumption that the Lake Clark fault 

comes straight down the lake, which aims at Pebble and all of the other faults just keep on 

going although they know there are fault lines that run right through Pebble, and in their data 

they make the assumption that the fault line goes either to the right or to the left very quickly and 

that it goes around Pebble. I don't see how they can come to that conclusion making an 

assumption like that. So that kind of data needs to be added. We really appreciate you guys 

coming and we appreciate you doing this draft assessment and we hope you finish up the 

assessment and I'm going to comment on your three volumes and it’s not going to take long. 
Most of it is demographics and you just have to fill in some little holes where it needs to be. July 

23, most of the people will be done fishing by then. Also, most people aren't fishing now. They 

are getting their boats ready but there is time in the evening if you are really concerned and 

really have an interest and intention to comment on this there is plenty of time for us to 

comment on it. Thank you. 

[01:46:24.11] 

Kim Williams 

Thank you EPA for the Assessment of potential mining impacts on the salmon ecosystems in 

BB. My name is Kimberly Williams and I am the Executive Director of Nunamta Aulukestai, 

which is Yup'ik for caretakers of our land. Nunamta is a non-profit corporation whose 

membership includes ten Alaska native village corporations and nine tribes located in the BB 

region of Alaska. Nunamta's mission is to establish a framework to collaborate in the mission in 

management and protection of lands and natural resources. I am the third chief of the Curyung 

Tribal Council, and I thank EPA for sitting down with my tribe in government to government 

consultation. It is too bad that the state of AK can't do the same. I would like to speak of the 

irony that the state wants more time for public comment. You have scheduled eight public 

meetings and a 60-day comment period so that we the public could speak to the assessment 

and we will get another opportunity to comment at the peer review of the document. The state 

of AK should look to EPA for the right way to get public comment. The state attorney general 

Geraghty complains that 60 days is inadequate. He had the audacity to ask for four months for 

the public and state to address the technical and legal merits of this assessment. Yet, the 

audacity of industry representatives who express their alarm that the public isn't given sufficient 

time to respond. How ironic and how hypocritical. For the last 24 years, the mining companies 

have been exploring for copper and gold on state lands in the headwaters of BB, hoping to 

develop the largest mine of its type in North America. They have drilled 1200 bore holes, some 

more than a mile deep and used fragile tundra and wetlands as their waste dump; criss-crossed 

subsistence areas with tens of thousands of helicopter flights. Removed millions of gallons of 

water from streams and ponds that support spawning salmon and other freshwater fishes. They 

have done all that with the states permission. Without public notice, without inviting public 

comment and without public hearings. While AK regulators have permitted industrial scale 

exploration, they have never asked the public to comment on whether the state should permit in 

the headwaters of the world’s premier sockeye salmon fishery, nor have they asked the tribal 

governments who the federal government recognizes. Nor have they asked the indigenous 
people who are Yup'ik and Denai’ina, who are real people with an intact and thriving sustainable 

salmon based culture, which this assessment recognizes and sets out to get our comments 

about a mine scenario that could produce billions of tons of toxic waste that could be stored 

forever, held back by an earthen dam. Thank you for gathering the science and a potential 

mining scenario to address the potential impacts that a large scale mine will do to our salmon 

streams and the impact it will have on us as a people. We are represented by trustees for AK, 

and we went to court seeking an adequate opportunity to address the technical and legal merits 

of the state exploration permit. The issue is on appeal to the Alaska Supreme Court and the 

state adamantly insists that the public has no right to even know about such permits in advance, 

let alone comment on them. The state systematically avoids any public notice and any hearing 

before it grants mining exploration and water permits. Do they give 60 days? Never. Even 

when the state does allow public comment, as it did for development of the Rock Creek gold 

mine near Nome. The comment period is half as long and the state is downright stingy in 

granting more time. It allowed the public just three extra days to comment on Rock Creek. 

They approved the project and then were forced to shut it down when the warnings from the 

critics proved accurate. Had the state been doing its job for the past two decades, it would have 

by now its own full record of public participation on the very issues raised by your draft 

assessment. It would have undertaken its own analysis of whether exploration and 

development are in the best interest of the state. The state would not then need 60 days to 

comment on the draft; rather they have been doing everything in their power both politically and 

through regulation to grease the wheels for development. They are ready to defend their 

rigorous permitting process and are quick to tell EPA "hands of Alaska" because their rigorous 

permitting process. But I am here to say, their use of a marine land classification in their own 

Bristol Bay area plan is their way for them to make it easier for permitting. We all know in this 

room that there are no walruses around the Pebble site. That is marine land classification for 

you. So, if the state of AK is interested in seeking public comment, through their exploration 

phase of the Pebble deposit, which is a large scale mine that gets addressed in your 

assessment, they would already know and conclude that mining at this scale would cause a loss 

of spawning and rearing habitat for both anadromous and freshwater fishes. The loss of 

wetlands that support migratory birds and habitat for caribou and other large game. It is not 

EPA's role to solve for jobs in our region, nor is it your job to solve the declining population or 

the closing of our schools in our region. Your role is clean water and the protection of these 

waters. The regulations need to ensure that we have clean water. Thank you for this 
assessment and doing what the state of AK should be doing. Tell them that the comment 

deadline is July 23. Thank you. 

[01:52:42.04] 

Peter Andrew 

Thank you. My name is Peter Andrew. BBNC board director, commercial fisherman and 

subsistence user. Yesterday, June 6 was a pretty important day that not everybody recognizes. 

Yesterday, 100 years ago, my father was awakened by mother. This was 1912. Katmai had just 

blown off. It was dark for three or four days. He said it was something that he would never, 

ever forget. I ask you guys to take another look at the seismic and volcanic activity which is 

fairly close to this particular project. I'd also like to remind you that the BBNC had not taken a 

position on Pebble or large scale mining lightly. We studied it for a few years. We agonized 

over it. With the support of our people, we feel very very, very, confident that a major part of our 

people want us to take this position and we did. So we are asking EPA along with the BBN, 

which in March passed a unanimous resolution asking EPA to come in and do the assessment 

and get it done. We will be asking again to use section 404(c). It is important to our culture and 

I thank these people for the hospitality. This is our land, this is our people, and this is our place. 

Please this is your place. This is America's place. President Obama classified Bristol Bay as 

one of the top national treasures. Please do your duty and protect our federal waters that will 

be in jeopardy. I thank you and I think I got the last word. 

End 

Note: This is not a certified transcript. This record of oral comments was transcribed by Judy 

Smith, EPA Community Involvement Coordinator from audio recordings taken at the EPA public 

meeting held in Nondalton, Alaska beginning at 5:00 p.m. on Wednesday, June 7, 2012. Every 

effort was made to transcribe the testimony accurately, but there may be errors or omissions 

because of background noise during the meeting or the sound quality of the recording.