Investor Statement on EPA’s Review of Proposed Pebble Mine
March 7, 2014: Investors, concerned with the devastating impact a large scale mining operation would have on the Bristol Bay region of Alaska, welcomed the U.S. Environmental Protection Agency’s recent announcement that it will initiate a Clean Water Act 404(c) review process for the proposed project.
Bristol Bay is the home of the largest wild sockeye salmon fishery in the world, which is sustainably managed and central to the life of the Alaska Natives in the region. Protecting this national resource is important for the economy, sound resource development and the finances of companies that sell salmon.
We believe that an inclusive and scientifically based Section 404(c) process, in keeping with the Bristol Bay Assessment process we have seen thus far, can be consistent with the concerns we have articulated regarding economic growth, responsible mineral development, negative externalities, and the financial importance of ecosystem services.
We also urge Rio Tinto, a large stakeholder in the proposed mine, to re-examine its participation in the face of the growing risks and costs.
The investor group led by Trillium Asset Management LLC and Calvert Investment Management Inc, includes Christopher Reynolds Foundation, Clean Yield Asset Management, First Affirmative Financial Network, Green Century Capital Management, Inc., Investor Voice, SPC, Maryknoll Sisters, Newground Social Investment, SPC, Pax World Management LLC, Sierra Club Foundation, The Sustainability Group of Loring, Wolcott & Coolidge, Walden Asset Management, and Zevin Asset Management LLC.
EPA Moves to Protect Bristol Bay Fishery from Pebble Mine
FEBRUARY 28, 2014 // WASHINGTON, DC: The U.S. Environmental Protection Agency (EPA) is initiating a process under the Clean Water Act to identify appropriate options to protect the world’s largest sockeye salmon fishery in Bristol Bay, Alaska from the potentially destructive impacts of the proposed Pebble Mine. The Pebble Mine has the potential to be one of the largest open pit copper mines ever developed and could threaten a salmon resource rare in its quality and productivity. During this process, the U.S. Army Corps of Engineers cannot approve a permit for the mine.
This action, requested by EPA Administrator Gina McCarthy, reflects the unique nature of the Bristol Bay watershed as one of the world’s last prolific wild salmon resources and the threat posed by the Pebble deposit, a mine unprecedented in scope and scale. It does not reflect an EPA policy change in mine permitting.
“Extensive scientific study has given us ample reason to believe that the Pebble Mine would likely have significant and irreversible negative impacts on the Bristol Bay watershed and its abundant salmon fisheries,” said EPA Administrator Gina McCarthy. “It’s why EPA is taking this step forward in our effort to ensure protection for the world’s most productive salmon fishery from the risks it faces from what could be one of the largest open pit mines on earth. This process is not something the Agency does very often, but Bristol Bay is an extraordinary and unique resource.”
EPA is basing its action on available information, including data collected as a part of the agency’s Bristol Bay ecological risk assessment and mine plans submitted to the Securities and Exchange Commission. Today, Dennis McLerran, EPA Regional Administrator for EPA Region 10, sent letters to the U.S. Army Corps of Engineers, the State of Alaska, and the Pebble Partnership initiating action under EPA’s Clean Water Act Section 404(c) authorities.
“Bristol Bay is an extraordinary natural resource, home to some of the most abundant salmon producing rivers in the world. The area provides millions of dollars in jobs and food resources for Alaska Native Villages and commercial fishermen,” McLerran said. “The science EPA reviewed paints a clear picture: Large-scale copper mining of the Pebble deposit would likely result in significant and irreversible harm to the salmon and the people and industries that rely on them.”
Today’s action follows the January 2014 release of EPA’s “Assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay, Alaska,” a study that documents the significant ecological resources of the region and the potentially destructive impacts to salmon and other fish from potential large-scale copper mining of the Pebble Deposit. The assessment indicates that the proposed Pebble Mine would likely cause irreversible destruction of streams that support salmon and other important fish species, as well as extensive areas of wetlands, ponds and lakes.
In 2010, several Bristol Bay Alaska Native tribes requested that EPA take action under Clean Water Act Section 404(c) to protect the Bristol Bay watershed and salmon resources from development of the proposed Pebble Mine, a venture backed by Northern Dynasty Minerals. The Bristol Bay watershed is home to 31 Alaska Native Villages. Residents of the area depend on salmon as a major food resource and for their economic livelihood, with nearly all residents participating in subsistence fishing.
Bristol Bay produces nearly 50 percent of the world’s wild sockeye salmon with runs averaging 37.5 million fish each year. The salmon runs are highly productive due in large part to the exceptional water quality in streams and wetlands, which provide valuable salmon habitat.
The Bristol Bay ecosystem generates hundreds of millions of dollars in economic activity and provides employment for over 14,000 full and part-time workers. The region supports all five species of Pacific salmon found in North America: sockeye, coho, Chinook, chum, and pink. In addition, it is home to more than 20 other fish species, 190 bird species, and more than 40 terrestrial mammal species, including bears, moose, and caribou.
Based on information provided by The Pebble Partnership and Northern Dynasty Minerals, mining the Pebble deposit may involve excavation of a pit up to one mile deep and over 2.5 miles wide — the largest open pit ever constructed in North America. Disposal of mining waste may require construction of three or more massive earthen tailings dams as high as 650 feet. The Pebble deposit is located at the headwaters of Nushagak and Kvichak rivers, which produce about half of the sockeye salmon in Bristol Bay.
The objective of the Clean Water Act is to restore and maintain the chemical, physical, and biological integrity of the nation’s waters. The Act emphasizes protecting uses of the nation’s waterways, including fishing.
The Clean Water Act generally requires a permit under Section 404 from the U.S. Army Corps of Engineers before any person places dredge or fill material into wetlands, lakes and streams. Mining operations typically involve such activities and must obtain Clean Water Act Section 404 permits. Section 404 directs EPA to develop the environmental criteria the Army Corps uses to make permit decisions. It also authorizes EPA to prohibit or restrict fill activities if EPA determines such actions would have unacceptable adverse effects on fishery areas.
The steps in the Clean Water Act Section 404(c) review process are:
Step 1 – Consultation period with U.S. Army Corps of Engineers and owners of the site, initiated today.
Step 2 – Publication of Proposed Determination, including proposed prohibitions or restrictions on mining the Pebble deposit, in Federal Register for public comment and one or more public hearings.
Step 3 – Review of public comments and development of Recommended Determination by EPA Regional Administrator to Assistant Administrator for Water at EPA Headquarters in Washington, DC.
Step 4 – Second consultation period with the Army Corps and site owners and development of Final Determination by Assistant Administrator for Water, including any final prohibitions or restrictions on mining the Pebble deposit.
Based on input EPA receives during any one of these steps, the agency could decide that further review under Section 404(c) is not necessary.
Now that the 404(c) process has been initiated, the Army Corps cannot issue a permit for fill in wetlands or streams associated with mining the Pebble deposit until EPA completes the 404(c) review process.
EPA has received over 850,000 requests from citizens, tribes, Alaska Native corporations, commercial and sport fisherman, jewelry companies, seafood processors, restaurant owners, chefs, conservation organizations, members of the faith community, sport recreation business owners, elected officials and others asking EPA to take action to protect Bristol Bay.
More information on the Clean Water Act Section 404 (c):
More information on the EPA Bristol Bay Assessment: http://www2.epa.gov/bristolbay
Contact Information: Hanady Kader, 206-553-0454, email@example.com
This press release was originally published by the U.S. Environmental Protection Agency which is solely responsible for its content.
Investors Urge President Obama and EPA Administrator McCarthy to Take Steps to Protect Bristol Bay Region of Alaska
On February 24, 2014, a coalition of concerned investors, lead by Trillium Asset Management and Calvert Investment Management, sent a letter to President Obama and U.S. EPA (Environmental Protection Agency) Administrator McCarthy urging the EPA to initiate a Clean Water Act 404(c) process to provide long term protection for the Bristol Bay region of Alaska.
In January 2014, the EPA released its final assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay, Alaska which states that large scale mining such as the proposed Pebble Mine has “potential for significant effects on Alaska Native cultures” and “the significant loss of Chinook salmon populations” which “would have severe consequences…”.
You can read the recent investor letter here.
Trillium Statement on the U.S. EPA’s Assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay, Alaska
January 16, 2014 – The following statements may be attributed to Jonas Kron, Trillium Asset Management’s Director of Shareholder Advocacy:
Yesterday, the U.S. Environmental Protection Agency (EPA) released its final assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay, Alaska which states that large scale mining such as the proposed Pebble Mine has “potential for significant effects on Alaska Native cultures” and “the significant loss of Chinook salmon populations” which “would have severe consequences…”
Trillium commends the EPA for producing a rigorous, science-based assessment and believes now is the time for the EPA to initiate a Clean Water Act 404(c) process designed to protect this important national resource.
Since 2011, investors representing over $100 billion in assets have provided comments to the EPA expressing concerns about large-scale mining in the Bristol Bay region of Alaska. The EPA’s report follows Anglo American’s recent announcement of its withdrawal from the proposed Pebble Mine because of the project’s risk/return profile. Mining company, Rio Tinto, has also announced that it is reviewing its continued participation in the project.
As investors, this risk/return analysis is fundamental and we believe that environmental, social, government policy and financial risk/return factors must be addressed in an integrated manner.
In 2012, The Food Marketing Institute (FMI) issued a letter stating, “Bristol Bay is a one-of-a-kind fishery that is important not only to the ecology of the region but also to fulfilling the goal of long-term sustainable seafood sourcing.” Not only is the FMI a national trade association that represents 1,500 member companies – food retailers and wholesalers – in the United States and around the world with a combined annual sales volume of $680 billion, but also it represents many companies that are in our investment portfolios. Resources like Bristol Bay are important for our economy in countless ways and need protection.
Finally, we observe that from an investor perspective, a Section 404(c) process at this stage could help remove regulatory risk and uncertainty surrounding mining in the region. This presents the opportunity to enhance clarity that could in turn facilitate the efficient and environmentally responsible allocation of capital investment in mineral development. We believe it is prudent for all financially interested parties to understand now, as fully as possible, the regulatory environment. For that reason we believe strongly that the EPA should be provided with the resources necessary to continue with the 404(c) process.
Accordingly, we believe that an inclusive and scientifically based Section 404(c) process, in keeping with the EPA’s environmental assessment process we have seen thus far, can be consistent with the concerns with economic growth, responsible mineral development and the financial importance of ecosystem services.
For more information please contact Randy Rice at firstname.lastname@example.org or (617) 515-6889.
Trillium / Calvert Statement on Anglo American’s Withdrawal from Pebble Mine Project
September 18, 2013 // BOSTON, MA: Anglo American plc (LON: AAL) has announced that it is withdrawing from the proposed Pebble Mine Project in Bristol Bay, Alaska. This action, which casts a cloud of deep uncertainty over the project’s future, follows years of widespread opposition to the proposed open pit mine from Native Alaskans, sport and commercial fishing groups, environmental organizations, and retail grocers, along with other businesses and investors.
Anglo American’s withdrawal is a defining moment in this long running controversy which highlights the unique natural resource that is Bristol Bay. It is the home of the largest wild sockeye salmon fishery in the world, which is sustainably managed and central to the life of the Alaska Natives in the region.
Groups of investors, representing tens of billions of dollars, have expressed deep concern about the proposed mine. In letters to the Environmental Protection Agency in 2011, 2012 and 2013 investors shared their concerns about the Bristol Bay ecosystem, responsible mineral development, sustainable fishery management, Alaska Native culture, and the associated risks.
Trillium, Calvert and other concerned investors believe that this controversy serves as an important example of how environmental, social, government policy and financial risk factors must be addressed in an integrated manner.
We believe Anglo American reached a similar conclusion after its review of the risk/return profile of all projects currently in its pipeline, which led to its decision to withdraw from the project.
Because it is currently unclear whether remaining — or other — mining interests will pursue this large scale mine in any significant way, and because Bristol Bay is a vitally important natural resource, we wish to take this opportunity to, once again, urge the EPA to move forward with its science based review, the 404(c) process, and provide the Bristol Bay region with the protections it needs from large scale mining.
We will be working with fellow investors in the next few weeks to communicate our ongoing concerns to the EPA and other interested parties.
ABOUT TRILLIUM AND CALVERT
Trillium Asset Management LLC is the oldest investment advisor devoted exclusively to sustainable and responsible investing (SRI). With over $1.2 billion in assets under management, Trillium integrates Environmental, Social, and Governance (ESG) factors into the investment process as a way to identify the companies best positioned to deliver strong long-term performance.
Calvert Investments is an investment management company that offers mutual funds and separate accounts to institutional investors, retirement plans, financial intermediaries, and their clients. By combining rigorous analysis with independent thinking, our disciplined approach to money management goes beyond traditional factors in order to manage risk and to identify investment opportunities with greater long-term potential. We offer more than 40 equity, bond, cash, and asset allocation investment strategies, many of which feature integrated corporate sustainability and responsibility research.
Jonas Kron, Trillium Asset Management, (503) 592-0864, email@example.com
Stu Dalheim, Calvert Investments, (301) 961-4762, Stu.Dalheim@Calvert.com
New Investor Advisory Raises Questions About Proposed Open Pit Mine in Bristol Bay, Alaska
Earthworks, an environmental nonprofit, has recently published a report that details the growing list of regulatory, legal, engineering, and political challenges facing the Pebble Mine project.
The proposed open pit mine would be located at the headwaters of the Bristol Bay watershed, which produces 50 percent of the world’s commercial supply of wild sockeye salmon.
“Opposition to the Pebble mine project has translated into a barrage of legal, political and regulatory hurdles over the last year,” said Jonas Kron, an analyst with Trillium Asset Management, who reviewed the report. “After scrutinizing the project details, we believe there are significant risks that must be considered,” he added.
In 2011, Trillium organized a group of shareholders representing $170 billion of assets under management to publicly issue a joint statement calling for the Environmental Protection Agency to protect this vitally important national resource.
To read the investment advisory, click here.