TORONTO (miningweekly.com) – Dual-listed project developer Northern Dynasty Minerals has filed a 205-page submission with the US Environmental Protection Agency (EPA) in response to its call for public comments on the revised draft Bristol Bay Watershed Assessment (BBWA), calling the draft report and the process used to complete it “biased, manipulative and contrary to the EPA's own guidelines”.

Northern Dynasty president and CEO Ronald Thiessen said the 2013 draft BBWA, released in April, suffers from the same significant shortcomings as the original report published in May 2012 – in particular, that the EPA continued to assess the environmental effects of a hypothetical mine of its own invention, one that did not employ modern engineering standards, environmental safeguards or project-specific mitigation measures and could not be permitted under US or Alaska law.

Despite the fact that the EPA's “hypothetical mine” was sited at the location of the Pebble deposit, Northern Dynasty believed the BBWA authors continued to refuse to consider the most extensive scientific data set available on the region – environmental baseline data collected by the Pebble Limited Partnership (PLP) at a cost of about $150-million.

Northern Dynasty said the EPA’s failure to fully consider the PLP's environmental data was contrary to its own guidelines for data quality and was compounded by the fact that the BBWA study authors had never set foot on the Pebble project site.

"The BBWA process has truly become the 'theatre of the absurd'.

“Rather than waiting for the PLP to submit a proposed development plan for consideration by federal and state regulatory agencies under the National Environmental Policy Act, something that is expected to occur this year, [the] EPA has invented its own hypothetical mine, it has continued to ignore modern mine engineering practices and regulatory requirements, it has shunned the best available scientific and environmental data at its disposal and it has created a public and peer review process designed to minimise scientific scrutiny of its work," Thiessen said.

He added that Northern Dynasty believed the BBWA process to be a cynical effort to manipulate public perception about a project before it had been proposed or undergone federal and state permitting.

“And we believe the draft BBWA to be a fundamentally biased report that should have no bearing on the future of America's most important undeveloped mineral resource,” Thiessen said.

Northern Dynasty sent a letter to EPA acting administrator Bob Perciasepe, stating that the federal agency had also failed to provide for an open, objective and transparent public and scientific review of the 2013 draft BBWA by unnecessarily restricting public comment opportunities on a more than 1 300-page document and restricting public access to its peer review panel, ignoring the agency's own guidelines for scientific peer review.

"While unprecedented, Northern Dynasty said, at the outset of the BBWA process, that EPA's study could have served a valuable purpose for project stakeholders and the people of south-west Alaska if it provided an objective, science-based assessment of the true risks and opportunities associated with modern mine development in the region prior to the onset of project permitting," Thiessen said.

"Unfortunately in its current form, the BBWA is not an objective, science-based assessment but a demonstrably flawed and biased document now being used to substantial effect by the antidevelopment community to manipulate public and political opinion about one of America's greatest assets, the Pebble project."

The EPA was not immediately available for comment.

A recent report examining the potential economic impact of the proposed Pebble copper, gold and molybdenum mine on the Alaskan and the US economies had found that the mine could support 15 000 American jobs and contribute more than $2.4-billion a year to the US gross domestic product.

However, not everybody sees the potential positive economic impact.

Environmental objections to Pebble mainly revolve around the size of the project and the possible effects on the ecosystem, particularly the waterways that serve as runs for sockeye salmon during their spawning season. Salmon fishing is a vital economic prop in Alaska.

Concerned groups, including the Pebble project’s opponents, have requested the EPA to investigate the Bristol Bay watershed under Section 404(c) of the US Clean Water Act. This grants the EPA the right to “restrict, prohibit, deny, or withdraw the use of an area as a disposal site for dredged or fill material if the discharge will have unacceptable adverse effects on municipal water supplies, shellfish beds and fishery areas, wildlife, or recreational areas”.

The Pebble project proposes to construct a large openpit mine; an on-site milling facility; on-site storage for rock, ore and tailings; a port facility; an access road connecting the mine site to the port; on-site water supply for the mill; and to provide electrical power for the mine site.

In addition, the project plans to include an on-site 378 MW gas-fired turbine plant, a 138 km transportation corridor to Cook Inlet for road and pipeline rights of way and a new deep-water port at Cook Inlet.

The project’s key assets are the near-surface 4.1-billion-ton openpit-style Pebble West deposit and the deeper and higher-grade 3.4-billion-ton Pebble East deposit, which is amenable to underground bulk mining methods. The Pebble resources rank among the world’s most important accumulations of copper, gold and molybdenum.

Estimates show that the Pebble deposit comprises measured and indicated resources of 5.94-billion tons, grading 0.78% copper equivalent and containing 55-billion pounds of copper, 67-million ounces of gold and 3.3-billlion pounds of molybdenum.

The deposit also has 4.84-billion tons of inferred resources, grading 0.53% copper equivalent and containing 26-billion pounds of copper, 40-million ounces of gold and 2.3-billion pounds of molybdenum.

Capital expenditure on Pebble is expected to reach between $6-billion and $8-billion. Anglo American is required to fund $1.5-billion of the project costs to retain its 50% interest, taking the Pebble project through permitting and into construction.