Register for free to join our community of investors and share your ideas. You will also get access to streaming quotes, interactive charts, trades, portfolio, live options flow and more tools.
Register for free to join our community of investors and share your ideas. You will also get access to streaming quotes, interactive charts, trades, portfolio, live options flow and more tools.
Oops...10+ mm shares just went through and dropped share price to 0.60
What's not to like, except that it would be even better if the volume was higher...
Quarterly results have been published:
NAK Quarterly Results
Alaska Journal of Commerce Corps receives, but doesn’t release, final Pebble mitigation plan
Corps receives, but doesn’t release, final Pebble mitigation plan
By: Elwood Brehmer
Alaska Journal of Commerce
Post date:
Wed, 11/18/2020 - 9:02am
The Pebble Partnership submitted its final paper to the U.S. Army Corps of Engineers two days ahead of its Nov. 18 deadline, but the last key piece of the project that has garnered significant attention from the White House will be kept under wraps for the time being, according to Corps officials.
Pebble’s final compensatory mitigation plan needs to offset the loss or degradation to nearly 3,300 acres of wetlands and 185 miles of streams, largely through direct “in-kind” compensatory mitigation measures to preserve areas within the remote Koktuli River watershed where the proposed mine sites, according to requirements the Corps of Engineers established in late August.
The company was also required to deliver the plan within 90 days in a letter Corps Alaska Regulatory Division Chief David Hobbie sent to Pebble leaders Aug. 24.
A spokesman confirmed via email that the Corps had received Pebble’s final mitigation plan and indicated it is currently under review and will be released when it is deemed compliant with applicable regulations, but when that will be is unclear.
Questions regarding the authority under which the document would be withheld from the public were not answered in time for this story.
Advertisement
Pebble spokesman Mike Heatwole said the company would wait for the Corps to release the mitigation plan.
According to officials for the Alaska Department of Natural Resources officials, which manages state land, the agency also has not received a final copy of Pebble’s wetlands mitigation plan either.
The compensatory mitigation plan is the last piece of Pebble’s plan the Corps needed before issuing a record of decision on the project — the key federal approval or denial.
Ron Thiessen, CEO of Pebble’s parent company Vancouver-based Northern Dynasty Minerals Ltd. said the final Pebble environmental impact statement published by the Corps in July already concluded that the large open-pit copper and gold project can operate in-concert with the Bristol Bay ecosystem and meeting the mitigation requirements will provide further evidence that Pebble “can and will co-exist with commercial, subsistence and sport fisheries in Southwest Alaska.”
“The ‘in-kind’ and ‘in-watershed’ requirement for mitigation the (Army Corps) established for Pebble clearly sets a high bar for offsetting project effects on wetlands and other aquatic features, but it’s a challenge we have embraced and believe we can achieve,” Thiessen said.
With little development in the Koktuli drainage and large tracts of state land, traditional means of compensatory mitigation such as restoring damaged wetlands or preserving areas under the threat of development were largely viewed as very challenged by the Corps’ requirements by project observers.
The Pebble deposit is also on state land.
Former Pebble CEO Tom Collier said in response to the mitigation thresholds that the company would likely focus its mitigation plan on preserving an area several times larger than the aquatic areas impacted by the project.
Collier abruptly resigned from Pebble in September following the release of a recorded videoconference by individuals posing as potential Chinese investors dubbed the “Pebble Tapes” in which Collier and Thiessen were recorded boasting about their relationships with state and federal officials and plans to greatly expand the mine .
The stringent mitigation requirements laid out by the Corps were in sharp contrast to Pebble’s proposed mitigation plan and guidelines issued by the Trump administration in 2018 specifically for Alaska that emphasized flexibility in mitigation requirements for projects in the state given its relative abundance of wetlands.
They also seem to contradict the final EIS, which generally maintained the conclusions in the draft EIS and states there would be “no measurable change” in the numbers of salmon returning to the Nushagak and Kvichak rivers or in the long-term health of the commercial fisheries in the region. The Koktuli River is in the upper reaches of the Nushagak watershed.
Pebble’s initial compensatory mitigation plan released in January relied on a collection of smaller — and likely less costly — mitigation efforts outside of the Koktuli watershed.
The company first planned to replace culverts in the Dillingham area to restore salmon access to about nine miles of spawning and rearing habitat; improve water treatment facilities at villages near the mine site; and periodically clean debris from seven miles of beach around the Cook Inlet port site.
DNR spokesman Dan Saddler wrote that the Division of Mining, Land and Water staff met with Pebble representatives four times, the last time on Sept. 10, to discuss state law and processes regarding wetlands. DNR officials did not discuss Pebble’s plan after the Corps’ August letter, according to Saddler.
“In the absence of any application for state permits, DNR has no role to play in Pebble’s current activity in support of federal permits,” Saddler wrote.
DNR officials have no expectations as to what Pebble will propose to meet its mitigation requirements, according to Saddler.
Meanwhile, Sen. Lisa Murkowski — who has stressed her opposition to the project since late August and has since indicated a desire to preserve additional parts of the Bristol Bay region — unveiled an Interior and Environment spending bill Nov. 10 that directly addresses Pebble as well.
Murkowski chairs the Appropriations Subcommittee for the Interior and Environment.
A committee bill report states the subcommittee continues to monitor Pebble’s EIS process and concurs with the assessment in the Corps’ Aug. 24 statement that the project cannot be permitted as it stands “and appreciates the administration’s commitment to a decision guided by sound science.”
It further states that, “In the absence of a valid mitigation plan that has received all necessary approvals at the federal and state levels, the Committee urges the agencies to continue to withhold the applicant’s Clean Water Act permit.”
Murkowski spokeswoman Karina Borger wrote in response to questions about the intent language that it indicates Pebble’s wetlands fill permit should not be granted and “that the Army Corps should proceed to a denial of the permit application should Pebble fail to produce a fully viable mitigation plan, including all necessary approvals at the federal and state levels, within the agency’s 90-day timeframe.”
Murkowski would prefer the Army Corps deny the permit within the normal process to avoid needing an Environmental Protection Agency Clean Water Act Section 404(c) veto to stop Pebble because of the uncertainty it would bring for future projects, according to Borger.
Sen. Dan Sullivan, who like Murkowski was sharply critical of the EPA’s proposed veto in 2014 before Pebble applied for a wetlands fill permit, has said he supports such an action if it’s necessary to stop Pebble.
Elwood Brehmer can be reached at elwood.brehmer@alaskajournal.com.
Updated:
11/18/2020 - 9:25am
Last earnings report was August 13, 2020. Not surewhat the date is for next report but should be soon.....
Northern Dynasty options imply 24.3% move in share price post-earnings (TheFlyOnTheWall)
BY The Fly
— 3:04 PM ET 11/17/2020
Pre-earnings options volume in Northern Dynasty is normal with calls leading puts 9:2. Implied volatility suggests the market is anticipating a move near 24.3%, or 22c, after results are released. Median move over the past eight quarters is 2.2%.
$NAK A blow to the gold standard
Senate blocks confirmation of Trump Fed nominee Shelton
And the chipmunk says “Let there be Mitigation”.
Let’s get the mitigation plan submitted and then worry about the ROD.
Any idea when NAK will submit their mitigation plan? Due befor Nov 18 but why wait any longer. Submit it and get the ROD.
Pretivm Records Third Quarter 2020 Operating and Financial Results; Brucejack Continues to Deliver Strong Cash Flow and Remains On-Track to Achieve 2020 Guidance
Third Quarter (“Q 3 ”) and First Nine Months (“ YTD ”) 2020 Highlights:
G old production – Q 3 : 86,136 o unces ; YTD : 259,443 ounces
AISC 1 – Q 3 : $ 1,016 per ounce of gold sold ; YTD : $ 971 per ounce of gold sold
F ree cash flow 1 – Q 3 : $ 66.8 million ; YTD : $ 191.4 million
Production and sales volume on - track , unaffected by COVID-19
End of quarter cash balance: $ 1 75 . 0 million
All amounts are in US dollars unless otherwise noted. This release should be read in conjunction with the Company’s Financial Statements and Management’s Discussion and Analysis (“MD &A”) for the three and nine months ended September 30 , 2020 and 2019 , available on the Company’s website and on SEDAR and EDGAR.
VANCOUVER, British Columbia, Oct. 29, 2020 (GLOBE NEWSWIRE) -- Pretium Resources Inc. (TSX/NYSE:PVG) (“Pretivm” or the “Company”) announces operating and financial results for the third quarter and first nine months 2020 (see “Key Operating Metrics” and “Key Financial Metrics” tables below).
“Brucejack continues to deliver strong cash flow and we remain on target to meet our annual production, free cash flow and AISC guidance,” said Jacques Perron, President and Chief Executive Officer of Pretivm. “In the first nine months of the year, the mine produced just over 259,000 ounces of gold generating $448.0 million in revenue and $191 million in free cash flow.”
2020 Guidance
2020 Production Guidance Maintained
The Company produced 259,443 ounces of gold during the first nine months of 2020 and expects to meet 2020 gold production guidance at the Brucejack Mine of 325,000 ounces to 365,000 ounces. Production is planned to continue in the fourth quarter 2020 at an average rate of approximately 3,500 tonnes per day due to planned maintenance and an increased focus on waste management from increased lateral development with the objective of operating at the nominal rate of 3,800 tonnes per day at the end of the quarter. The average annual gold grade is expected to remain in the guidance range between 7.6 grams per tonne and 8.5 grams per tonne at an average gold recovery of 97.0%.
Management believes 2020 production guidance remains achievable assuming there is no new significant impact on operations at the Brucejack Mine, including due to the novel coronavirus (“COVID-19”) pandemic. We have taken precautions to mitigate the risk of COVID-19. However, the COVID-19 pandemic and any future emergence and spread of similar pathogens could have a material adverse impact on our business, operations and operating results, financial condition, liquidity and market for our securities.
2020 Financial Guidance Maintained
Total cash costs1 and all-in sustaining costs (“AISC”) were $763 and $971 per ounce of gold sold, respectively, for the first nine months of 2020. Management expects to achieve our total cash costs guidance range of $750 to $860 per ounce of gold sold and AISC guidance range of $960 to $1,120 per ounce of gold sold.
AISC estimates include costs associated with lateral development at a rate of approximately 1,000 meters per month through 2020. In addition, the AISC estimates include costs associated with enhanced COVID-19 protocols, infill definition diamond drilling and a high-density test reverse circulation (“RC”) drilling grade control program to increase the volume of grade information necessary to enhance mine planning and optimize gold production.
Sustaining capital expenditures for the year, a component of AISC, are expected to be between $30.0 and $33.0 million, which includes additional definition drilling and mill building repairs. Other capital expenditures include approximately $10.0 to $15.0 million in expansion capital expenditures and approximately $10.0 million for regional exploration.
2020 Free Cash Flow Forecast Maintained
Free cash flow for the first nine months of 2020 was $191.4 million at an average realized gold price1 of $1,758 per ounce. We expect to achieve our 2020 free cash flow forecast range of $205 million to $275 million which was based on an average realized gold price of $1,800 per ounce.
While operating under the COVID-19 safety protocols, the Company will focus on preserving liquidity in the form of cash and cash equivalents and reducing the amount outstanding under its existing Loan Facility.
Nice summary, rugh. There has been so much information over the years that it's easy to overlook some of it. Appreciate the reminder about what David Lowell said.
There are two basic theories for the origin of crude oil: biotic and abiotic. The biotic theory predominates. It attributes oil's formation to the decay of animal and plant matter. The less widely accepted – even controversial – abiotic theory denies the involvement of living organisms in the production of crude oil.
a·bi·ot·ic
/?abi'ädik/
adjective
physical rather than biological; not derived from living organisms.
"abiotic chemical reactions"
devoid of life; sterile.
"soils are seldom completely abiotic"
Nice rise going into the close...
Good to see you here, tootall. Are you still following NAK?
YAHOO NEWS
Alaska's Senate race rocked by leaked videos
.
.
The race drew some national attention last month when secretly recorded videos leaked by an environmental group showed Tom Collier, the now-former CEO of a mining partnership looking to develop Alaska’s Pebble Mine, talking about his influence over Sullivan.
While Sullivan had put out a statement indicating he was opposed to the Pebble Mine project due to its environmental impact, the footage showed Collier boasting about the company’s sway over local officials and suggesting the senator was hoping to “ride out the election” and would not ultimately be an impediment to the project.
Gross has called on Sullivan to return donations from Collier. For his part, Sullivan has insisted he “unequivocally” believes the Pebble Mine project “cannot be permitted.”
“Any suggestion otherwise is either wishful thinking, a blatant mischaracterization, or a desperate attempt to secure funding for a mine that cannot move forward,” Sullivan said in a statement.
Looks like a slight break to the south with nearly 500,000 shares traded 2:30-2:35. Largest single sell I saw was 62,373 but majority of trades were sells.
Fidelity says due out Oct 28 (Unconfirmed).
Low volume take down from 1.15 to 1.10.....
From the letter:
"My other core objective is to ensure the USACE has the information required to finalize the ROD for the Project. One of the key elements necessary for the USACE to accomplish this is the compensatory mitigation plan. We are on track to deliver a plan that meets the USACE’s requirements, and when it is deemed complete, it will be published on the Project website."
My guess is that with the change in CEO's there is a need by the new CEO to carefully review the mitigation plan before it is submitted.
Thx. Quite a range, from $12 to $18.50....
Good news - submitted before the EOM like promised. Wait now on ROD - soon
Nope. 19.2%
you say 'riders' - I say 'fleas'.....$NAK
PVG continues to surge - $14.44 now...
'this month' could be any day now. I'm sure they are not going to tip their hand at a conference like this - maybe next week PR with more details at that conference. Just thinking/wishing out loud...
I believe you have to go back some 10 years to find a close over $14 like it had today!
Copper looks like it could break through $3.10 today.
Big jump at the open and now up over 8% - significantly more than other gold companies that are up a few percent on the increased price of gold. Hmmm....
Northern Dynasty, Pebble Partnership leaders to provide Pebble Project update at upcoming conferences
H.C. Wainwright & Co. Global Investment Conference (Sept. 15), Gold Forum Americas 2020 (Sept. 21)
September 14, 2020 Vancouver – Northern Dynasty Minerals Ltd. (TSX: NDM; NYSE American: NAK) ("Northern Dynasty" or the "Company") confirms that financial market participants can receive an update on the Company and its 100%-owned Pebble copper-gold-molybdenum-silver-rhenium project in southwest Alaska via two online presentations from its senior leaders this week.
On September 15, beginning at 12:30 pm EDT/ 9:30 am PDT, Northern Dynasty President & CEO Ron Thiessen will present at H.C. Wainwright & Co.’s 22nd annual Global Investment Conference. Interested viewers can access Mr. Thiessen’s address at https://wsw.com/webcast/hcw7/ndm.to/1806896.
On September 21, beginning at 11:00 am EDT/8:00 am PDT, Tom Collier, CEO of Northern Dynasty’s 100%-owned US-based subsidiary Pebble Limited Partnership, will present at the Gold Forum Americas 2020 Conference. Interested viewers can access Mr. Collier’s address by selecting 'Day 2' of the 'Explorer & Developer Forum 2020' agenda at https://www.goldforumamericas.com/program-agenda/. A replay of the live session will be available approximately 90 minutes after the session concludes.
In July 2020, the US Army Corps of Engineers issued a final Environmental Impact Statement for Alaska’s Pebble Project, describing a modern hard rock mine that would co-exist with clean water, healthy fish and wildlife populations, while making a profound socioeconomic contribution to the Bristol Bay region, the State of Alaska and the United States. Northern Dynasty expects to receive a final Record of Decision for its flagship project this fall.
Northern Dynasty calls J Capital Research report ‘fatuous, flimsy and fundamentally self-serving’
September 10, 2020 Vancouver – Northern Dynasty Minerals Ltd. (TSX: NDM; NYSE American: NAK) ("Northern Dynasty" or the "Company") responded today to a report issued by Beijing-based short seller J Capital Research (“JCap”) on September 9, 2020, calling it “fatuous, flimsy and fundamentally self-serving,” as well as “typical of such efforts to profit by destroying the value of honest shareholders’ investments.”
“We have heard and responded to the same baseless claims in JCap’s ‘research’ report countless times since they were initially levelled by New York-based ‘short-and-distort’ firm Kerrisdale Capital back in 2017,” said Northern Dynasty President & CEO Ron Thiessen. “Financial markets weighed and dismissed Kerrisdale’s self-serving arguments then, and we are confident they will do so even more swiftly this time with these unoriginal allegations coming out of China.”
Thiessen noted that the allegations in the Kerrisdale report formed the basis of several derivative shareholder actions against Northern Dynasty, which were ultimately dismissed by the courts for failure to state a cause of action.
JCap’s report, entitled Pretend & Extend: The No-Return Deposit, claims that Northern Dynasty’s 100%-owned Pebble copper-gold-molybdenum-silver-rhenium project in southwest Alaska will lose money, that capital costs have been underestimated and that the project’s proposed mining plan intentionally targets low-grade portions of the deposit. Less than four months ago, JCap levelled similar accusations against Alaska’s other late-stage mineral prospect – the Donlin Gold project (co-owned by Barrick and Novagold) – leading to a civil action lawsuit for defamation being brought against the firm.
“We will take an appropriate amount of time to review the report and the market’s reaction to it, if any, as well as our options for protecting the company and our shareholders from these spurious claims,” Thiessen said, noting the Company may choose to issue a comprehensive response or may simply ignore what is intrinsically a self-serving attempt to profit by creating panic in the marketplace.
Thiessen advised investors to carefully read and consider the extensive disclaimers issued by JCap, which confirm the authors have shorted Northern Dynasty stock and absolve them of any potential responsibility for the ‘opinions,’ ‘inferences’ and ‘deductions’ in the report. “We encourage our investors in the strongest possible terms not to reward this type of value destructive and irresponsible behavior,” he said.
Thiessen believes other parties engaged in market manipulation and short-selling have conspired to cost Northern Dynasty shareholders, large and small, some $500 million in recent months. He said there is little the Company can do to prosecute or counter these illegal activities other than continuing to advance the Pebble Project toward final permitting, construction and profitable operations.
“Our focus must be on continuing to advance through the rigorous, objective and science-based federal permitting process in the United States, and proving that Pebble is a project of merit that will materially benefit project stakeholders in Alaska and our shareholders in America and around the world,” Thiessen said. “That’s what we intend to do.”
Thiessen pointed to several egregious lies and misrepresentations in the JCap report as evidence of the quality of the research and the integrity of its authors:
JCap claim: “…(Northern Dynasty) management is openly saying that, once the plan is under way, they will push forward with another 58 years. Management claims they will not need any additional environmental approval to extend the life of the mine.”
Northern Dynasty response: This claim is false. No future development scenario has been proposed at Pebble. The Company has consistently stated that any proposal for subsequent phases of development must undergo rigorous federal and state permitting processes.
JCap claim: “Pebble itself in 2018 relied on its 2011 scenario to argue that the mine is economically viable. The USACE (US Army Corps of Engineers) asked Pebble for modeling on the economic viability of the proposed mine. In response, Pebble provided analysis based entirely on the 2011 scenario.”
Northern Dynasty response: JCap intentionally mischaracterizes the US Army Corps of Engineers’ request for information and the Pebble Limited Partnership’s response. In fact, Pebble was explicit when providing the 2011 data to USACE that it did not reflect current project costs. The allegation that Pebble capital costs are underestimated by Northern Dynasty is based on this mischaracterization.
JCap claim: Northern Dynasty “has claimed poverty to dodge a feasibility study, which would demonstrate economic viability.”
Northern Dynasty response: Northern Dynasty has consistently stated it does not intend to complete a Preliminary Economic Assessment or other technical study to report on the future financial performance of the proposed Pebble mine until the project design is confirmed by regulators through the granting of a positive Record of Decision. That position and its rationale has not changed.
That would be a good outcome, tootall - hope you are right.
Simple to do and you can add your own commentary if desired.
Traders flipping large volume trades for a few pennies profit each (thousands of dollars profits or more per trade) - hence the 94MM share trade total and the rapid rise and fall of the share price....not sure what price can be sustained
Northern Dynasty: new Pebble mineral resource estimate increases US strategic Rhenium sources by 84%
August 20, 2020 Vancouver – Northern Dynasty Minerals Ltd. (TSX: NDM; NYSE American: NAK) ("Northern Dynasty" or the "Company") announces the results of an updated mineral resource estimate for southwest Alaska’s Pebble Project. Already considered among the most significant accumulations of copper, gold, molybdenum and silver ever discovered in the United States, the current study confirms the Pebble deposit also contains substantial quantities of Rhenium – a metal used in jet engines and other military applications, and to produce high-octane fuels.
The US Geological Survey (“USGS”) considers Rhenium a strategic metal and confirms the United States currently relies on foreign producers for 82% of its Rhenium needs.
“Certainly the US military has identified Rhenium as a critical mineral, and one the United States must develop additional domestic production of in order to enhance its military security,” said Ron Thiessen, Northern Dynasty President & CEO. “The development of Alaska’s Pebble Project would clearly go a long way toward filling that gap, while also addressing substantial US domestic supply deficits for other critical minerals – notably copper and silver.”
The inclusion of Rhenium into the Pebble resource estimate is based on more than 58,000 analyses from 699 core holes, totaling more than 840,000 feet of drilling.
For the estimate, the Pebble deposit was domained based on geology, alteration and grade distribution. Estimation parameters including top cuts, search strategy, and variography were developed for each modelled domain. Rhenium values were interpolated into the Pebble block model using Ordinary Kriging and classified according to existing criteria.
At a 0.30% copper equivalent cut-off, the Pebble Deposit contains:
2.6 million kg of rhenium, 57 billion pounds of copper, 71 million ounces of gold, 3.4 billion pounds of molybdenum and 345 million ounces of silver within the 6.5 billion tonnes in the combined Measured and Indicated categories at a grade of 0.40% copper, 0.34 g/t gold, 240 ppm molybdenum, 1.7 g/t silver and 0.41 ppm rhenium; and
1.6 million kg of rhenium, 25 billion pounds of copper, 36 million ounces of gold, 2.2 billion pounds of molybdenum and 170 million ounces of silver within the 4.5 billion tonnes in the Inferred category at a grade of 0.25% copper, 0.25 g/t gold, 226 ppm molybdenum, 1.2 g/t silver and 0.36 ppm rhenium.
Current total Rhenium resources in the United States are approximately 5 million kg. Pebble’s total Rhenium endowment represents an 84% increase to the nation’s known Rhenium resource base.
According to the USGS, some 8,400 kg of Rhenium was produced at six US operations in 2019. However, the United States also imported 39,000 kg – more than 82% of its current needs. Rhenium is used mainly in superalloys for turbine engines and for petroleum reforming catalysts, and demand is expected to grow.1
Globally, the primary source of Rhenium is mines developed on porphyry copper deposits like Pebble, recovered as a by-product through treatment of molybdenum concentrates.
As a significant deposit of Rhenium on US soil, development of the Pebble resource will materially advance America’s goal of achieving self-sufficiency in the critical minerals needed to support and sustain its economic growth, military security, manufacturing industries and transition to a lower carbon future.
___________________
1 Mineral Commodities Summaries 2020 – Rhenium, United States Dept of the Interior, US Geological Survey
Not only has cooper dropped back below $3, gold suddenly dropped $60+ and silver $1. NAK was up a few pennies and dropped back down at the same time.
Nearly 6 MM shares with a high of 1.70
August 13 letter from NAK to House Leadership in response to request for IG investigation:
August 13, 2020
The Honorable Carolyn B. Maloney, Chairwoman Committee on Oversight and Government Reform 2157 Rayburn House Office Building
Washington, DC 20515-6143
The Honorable Harley Rouda, Chairman Subcommittee on Environment
2157 Rayburn House Office Building Washington, DC 20515-6143
The Honorable Jackie Speier
U.S. House of Representatives
2465 Rayburn House Office Building Washington, D.C. 20515
Dear Chairwoman Maloney, Chairman Rouda, and Representative Speier,
I am writing in regards to a letter that the three of you have sent to the Inspectors General of the U.S. Department of Defense and the U.S. Army requesting an investigation into the U.S. Army Corps of Engineers’ (USACE) environmental review of the Pebble Partnership’s application for a Clean Water Act permit to develop the Pebble Mine in southwest Alaska. As you are no doubt aware, Inspectors General are tasked with investigating waste, fraud, and abuse in federal agencies. Yet your letter fails to identify or even allege a single instance of waste, fraud, or abuse on the part of USACE throughout its Pebble Mine deliberations. Rather, the letter is a recitation of many incorrect issues that have been raised over the last several months that warrant additional context and correction from us.
Despite believing it to be unnecessary and many of the allegations raised as baseless, we welcome a review of USACE’s actions to date and pledge our cooperation. We are confident in the sufficiency and completeness of our technical work. We believe the USACE has undertaken a thorough, transparent and credible environmental review of the Pebble Project. Our support for an IG review is rooted in the notion that it will put to rest many incorrect statements about Pebble that have permeated the public conversation about our project.
Below are our responses to points raised in your letter to the IGs:
Assertion #1: “The full development of the Pebble Partnership’s proposed gold and copper mine in Alaska would be the largest in North America.” The project we took into permitting will not even be the largest mine in Alaska. According to the project description posted at Pebbleprojecteis.com, our pit dimensions are 6800 ft x 5600 ft with a depth after 20 years of 1950 feet. Alaska mining project Donlin Gold, according to the posted project description via Alaska Department of Natural Resources, would have pit dimensions of 3470 m (11384 ft) x 2530 m (8300 ft) with a pit depth of 1850 ft. Bingham Canyon Mine in Utah is 2.75 miles across (14520 feet) with a pit depth of 3960 feet.
Assertion #2: The proposed mine poses risks “if dams holding back the tailings fail in an earthquake.”
The premise of this assertion is that we did not take seismic conditions into consideration. The USACE addressed seismic risks directly in its EIS, and our project team has spent significant effort to ensure seismic risks is appropriately assessed and can be properly managed. As part of this approach, the Pebble design accounts for several earthquake scenarios, including one similar to the 1964 9.2 magnitude earthquake that shook Alaska and equivalent of a 7.5 magnitude earthquake on the Lake Clark fault – a fault that has not experienced seismic activity for over 10,000 years. Additionally, we utilize best practice for tailings management and storage by separating the largely inert bulk tailings from the pyritic tailings and by incorporating a very robust water management plan.
Assertion #3: The Pebble Mine creates “the threat of a catastrophic failure of a dam that would store acidic mining waste.” To begin, there will be no acidic wastes stored at the Pebble site. The issue of the threat of a catastrophic failure has been extensively discussed in the draft EIS, the preliminary final EIS, and the final EIS. The discussion has centered around the issue of whether a catastrophic failure analysis for the bulk tailings facility was warranted. The USACE has said that based upon how we plan on building, operating and maintaining the bulk TSF as a flow through facility, that the USACE could not establish a failure mechanism that would lead to a catastrophic failure. One of the major improvements we made to our design was to this flow through approach to the bulk tailings facility, which does not allow water to accumulate within the facility. The final EIS looked at four recent TSF failures in other parts of the world and also evaluated probable, yet highly unlikely, TSF spill scenarios. There is a robust discussion of this in the appendix K4.27.
Assertion #4: The “Army Corps expedited the Clean Water Act permitting and NEPA review process at the expense of a thorough scientific review.” This is incorrect. Your letter identifies no basis or standard against which to claim the Pebble Project EIS process has been expedited or scientific rigor sacrificed. In fact, the USACE’s timeline and comprehensiveness have been appropriate for a project like Pebble. The USACE has extended the process to allow more time for public comments and is behind its originally planned schedule to release a Record of Decision in early 2020. And a two and a half year NEPA review process is hardly “expedited.” Consider the length of time to evaluate the following projects:
• Haile Mine: The EIS process for the Haile Mine in South Carolina began July 2011, and the final EIS was published less than three years later in June 2014.
• Pogo Mine: In August 2000, Teck-Pogo Inc. applied for a Section 404 permit for a proposed underground cut-and-fill gold mine on State of Alaska-owned land in the Goodpaster River Valley. EPA, in close consultation with the USACE, published a DEIS in March 2003, then a final EIS in Sept. 2003 – three years and a month after the application.
• Kensington Mine: In 2001, Coeur Mining redefined the scope for its development of an underground gold mine within the Tongass National Forest outside of Juneau. This necessitated a new NEPA review, which was completed three years later in December 2004.
• Red Dog Mine: EPA prepared the Supplemental EIS for the expansion of the Red Dog Mine into the Aqqaluk deposit in northwest Alaska. The permitting process started in mid-2007 and the EIS was finished during Fall 2009, taking just over two years. The USACE was a cooperating agency.
• Point Thomson: The USACE was the lead agency for the EIS for the development of ExxonMobil’s Point Thomson oil facility on the North Slope of Alaska. The EIS process began in late 2009 and the final EIS was issued mid-2012, taking approximately two and a half years.
To add additional context about the work undertaken, the independent third-party contractor hired by the USACE to oversee the review process spent more than 100,000 hours evaluating the project and developing the EIS. This doesn’t include the time spent on the project by the federal agencies. To put this figure into perspective, it is approximately 50 man years of effort.
Assertion #5: The “Army Corps ignored input from key experts and constituencies.” This is incorrect. It would actually be nearly impossible for USACE to have been more collaborative in conducting the Pebble EIS process. USACE has designated two Bristol Bay Alaska Native tribal entities as cooperating agencies for the EIS and has consulted with federally recognized Tribes 128 times over the course of their review of Pebble.
USACE also significantly extended the comment periods during scoping and on the draft EIS to ensure all parties had adequate opportunities for input, held numerous public meetings, and engaged a cultural anthropologist to assist with evaluating issues such as subsistence. All total, the public had 210 days to make their views known to the USACE. The USACE held three technical workshops with other participating federal agencies to work through many issues raised via the public comment and agency comment opportunities. The Environmental Protection Agency complimented the USACE’s work with other cooperating agencies in their May 28, 2020 letter to the USACE:
“Since July of 2019 our agencies have been working together on Corps review of this proposed project. Most recently since mid-March, the Corps, EPA, and USFWS have met weekly to discuss issues related to the evaluation of the proposed Pebble Mine pursuant to the CWA Section 404(b)(1) Guidelines. The EPA has found these weekly sessions to be invaluable. We appreciate the Corps’ convening of these discussions...As the very productive interagency discussions conclude, we want to express our appreciation for the Corps’ willingness to engage with both the EPA and Fish and Wildlife Service collectively. Our hope is that this experience lays the groundwork for continuing cooperation between the agencies to resolve substantive concerns on this project or any future projects in Alaska.”
Both EPA and USFWS participated in the identification of the draft LEDPA and 404(b)1 analysis. As part of the NEPA process, the USACE must respond to all comments received during the public comment process. Last, just because a constituency does not like the conclusions reached by the USACE does not mean the USACE’s work is incomplete.
Assertion #6: “This application failed to include essential information regarding mine construction, operation, maintenance, and closure plans necessary to adequately develop an EIS under NEPA or conduct review under the Clean Water Act.” This is incorrect, and your letter provides no basis for this allegation. When we initiated the permitting process with the USACE, we submitted a detailed project description to document our proposed plans. Since that time and throughout the EIS process, USACE has requested technical information and updated plans from the Pebble Partnership and refined its recommendations for alternatives. Both the draft and final EIS are filled with evaluation of these very aspects of the permit application for the Pebble Project. For a more complete understanding about plans for developing a mine at Pebble, we direct you to review Chapter Two of the EIS, Alternatives, and Appendix K2.0, Alternatives. The USACE work has been thorough.
Assertion #7: “In 2019, the U.S. Environmental Protection Agency . . . abruptly dropped its opposition to the mine in order to allow the project to enter the NEPA permitting process.” This is incorrect. The Pebble Partnership applied for a wetlands permit and initiated the NEPA permitting process in December of 2017, thus when EPA withdrew its unprecedented preemptive veto the USACE had been working on its NEPA review for nearly two years. EPA remains an active participant in the federal permitting process. By withdrawing the preemptive veto, EPA was merely allowing the process to proceed according to the statutorily required and established procedure. EPA maintains the authority to restrict or veto the project at the designated time.
Assertion #8: The “final EIS does not significantly differ from the draft EIS.” This is incorrect. The final EIS 3201 C
includes several key differences from the draft, as USACE updated its findings based on information provided by Pebble, cooperating agencies and other key stakeholders. The final EIS even makes several important recommendations that are different from the draft EIS and our original plans, including updated findings on tailings storage and recommending a new transportation corridor option. We would encourage staff to read pages 7-8 of the EIS Executive Summary to see a list of the major changes between the draft and final Pebble EIS documents. What did not change between the draft and final EIS is the central conclusion that a mine at Pebble could operate responsibly without harm to the salmon fishery in Bristol Bay, and that the economic opportunity for the Alaska Native communities around Iliamna Lake would be substantial.
Assertion #9: “In the first three quarters of 2019 alone, the company spent at least $1.22 million in lobbying expenses.” This is false. It repeats an incorrect assertion that double-counts figures in public filings, as the Pebble Partnership in fact spent less than $700,000 on lobbying in the period you identify. It has often been repeated by advocacy groups opposed to the project to paint us in a negative light. The fact of the matter is the previous Administration engaged in an unprecedented attempt to block development of the Pebble Project before the company could even submit a permit application. Given that, it is not surprising that work was necessary to set the record straight in Washington. Underinformed letters like yours to the IG clearly demonstrate this work must continue.
Assertion #10: “...the Army Corps conducted its environmental review on an unusually fast track, without sufficient attention to minimal scientific integrity standards and an alarming lack of transparency.” This particular assertion is one we hope and expect an IG review to address in a comprehensive and objective way. If it does, we are confident the review will conclude that the USACE work on the Pebble Project EIS was undertaken with the utmost integrity and was one of the most transparent permitting processes ever undertaken for a resource development project.
The timeline issue was addressed previously. From the beginning, the USACE staff tasked with administering the NEPA review for the Pebble Project recognized the process would draw much more attention than other projects, and they were determined to be transparent and thorough. They established a project website that was continually update throughout the review process. The website was populated with every request for information when it was received, some 285 in total, as well as the final response. The USACE held monthly roundtable discussions with interested members of the media to explain its process and the issues they were addressing. The minutes of these meetings were also published to the website.
The Pebble Partnership welcomes a robust public debate on the environmental, economic, and social impacts and benefits of its proposed mine. And we welcome an Inspector General review of USACE’s actions as part of that public debate. If you or your staff would like a comprehensive briefing or more information, we are happy to provide one for you.
Respectfully,
Tom Collier, CEO
The Pebble Partnership
CC: The Honorable James R. Comer, Ranking Member Committee on Oversight and Reform
Another attempt at delaying Pebble project. Might it be possible that the Army be told to hold off on the ROD until the IG has completed its review, which could take months?
And copper is up 0.10, back to its one year high of 2.96 and poised to break through $3.
A little late afternoon buying, 300k shares in the last 15 minutes, has the price at 1.57.