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Saturday, 06/30/2018 11:04:00 AM

Saturday, June 30, 2018 11:04:00 AM

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NAK..We are going to be HUGE!>>>>>>>>Before the U.S. Army Corps of Engineers, Alaska District P.O. Box 6898 Joint Base Elmendorf-Richardson, Alaska, 99506-0898

In the matter of:

} Pebble Limited Partnership } DA Permit Application 2017-271 }

Comments of Dave Wilson on Commercial Fishing


EXECUTIVE SUMMARY
The Pebble Mine has the potential to help remove 168 million metric tons of carbon dioxide emissions from the atmosphere every year. The positive environmental impact of this on the Bristol Bay region, on Alaska, and throughout the United States should be a major consideration in its development.
The most significant thing we can do to protect the environment is dramatically increase the use of zero emission sustainable energy. Zero emission sustainable energy means electricity, the type of energy that comes out of solar panels, wind turbines, hydro-electric dams and other energy conversion systems. And electricity requires copper, by far the best element for widespread use in electrical applications.
For electric vehicles and other sustainable energy based products to succeed in the marketplace we need an abundance of resources to help them compete on price with their traditional energy based counterparts. One of these resources is copper. The United States needs to dramatically increase its copper production by millions of tons per year if we are to successfully convert to zero emission sustainable energy. Even at peak capacity our existing mining operations cannot come close to producing the copper we need for this.
It is an abundance of oil that keeps gasoline prices low and thus encourages people to drive carbon-emitting vehicles more and worry less about how efficiently their vehicles use gasoline. We need there to be a similar abundance of copper and other resources for zero emission sustainable energy vehicles so their prices will be lower and people will drive them more.
The proposed Pebble Mine would be a major source of copper. It has the potential to generate 6.7 billion pounds of copper,1 enough to support production of 36.6 million electric cars,

1 See The Pebble Project, Department of the Army Application for Permit (POA-2017-271), Attachment D, Project Description, Table 1-1, p. 14 (December 2017).
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equivalent to one-third of all cars on the road today in the United States.2 We need the copper from the proposed Pebble Mine to help keep the cost of sustainable energy-based products like electric vehicles competitive so consumers will embrace them. The more consumers embrace sustainable energy the better off we and the environment will be.
COPPER IS CRITICAL FOR PROTECTING THE ENVIRONMENT
Copper is a green element.3 It is crucial to reducing carbon emissions from the burning of fossil fuels because of how well it conducts electricity and its relative affordability compared with other metals. It is important that the materials used to produce things like electric vehicles, electric vehicle charging stations, and wind turbines be very affordable so the end products can be more economically appealing than their counterparts using traditional energy sources.
Copper is a critical component in the development of green technology because it conducts electricity well, and is more abundant and therefore lower in price than other elements that also conduct electricity well.
Table 1: Conductivity and price of good conductors
Element Conductivity (S/m) @ 68° F4 Price ($/lb)5 Silver 6.30 x 107 $263 Copper 5.96 x 107 $3 Gold 4.10 x 107 $20,151 Aluminum 3.50 x 107 $1

Table 1 compares the conductivity and price of silver, copper, gold and aluminum. While silver is a slightly better conductor than copper it is also significantly more expensive, making it less desirable in high volume applications such as electric motors. Aluminum is significantly less expensive than copper but is also significantly less conductive, meaning that when aluminum is used as an electrical conductor instead of copper the device or system in which it is used must consume more energy to overcome the higher loss of energy in aluminum versus copper.

2 This assumes 183 pounds of copper per electric car and 113 million cars on the road today in the United States. See footnotes 6 and 9 for details. 3 Copper is a critical component of environmentally friendly (aka “green”) technology. It also literally is green if it is exposed to the elements long enough to go through the series of chemical reactions that give it a shiny pale green outer layer called a patina. See Why Does Copper Turn Green? Live Science, www.livescience.com, (June 29, 2018). 4 See https://www.thoughtco.com/the-most-conductive-element-606683 (June 29, 2018), https://www.metalsupermarkets.com/which-metals-conduct-electricity/ (June 29, 2018) and https://www.quora.com/Which-metals-are-the-best-conductors-of-electricity (June 29, 2018) for information about the conductivity of various elements. 5 These were the prices for these elements on June 28, 2018, rounded to the nearest US dollar. The specific to-thesecond price is not important for the analysis in these comments. What is important is how significantly different the prices are.
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Copper is the element of choice for the vast majority of applications involving the conduction of electricity.
COPPER’S ROLE IN CONVERTING TO ELECTRIC VEHICLES IS CRITICAL
There are 18-49 pounds of copper in a conventional car with an internal combustion engine.6 Hybrid electric cars contain approximately 85 pounds, plug-in hybrid electric cars contain about 132 pounds, and battery electric cars contain approximately 183 pounds.7 Also, hybrid electric buses contain about 196 pounds and battery electric buses contain about 814 pounds.8
There are approximately 113 million cars, 146 million trucks and 1 million buses registered in the United States.9 Eliminating carbon emissions from vehicles in the United States would require that battery electric versions of all of these vehicles be produced. Table 2 summarizes how much copper would be needed to achieve this.
Table 2: Copper needed to replace all U.S. cars, trucks and buses with battery electric versions
Total units Copper/unit (lbs.) Total copper (lbs.) Cars 113 million 183 20.7 billion Trucks 146 million 81410 118.8 billion Buses 1 million 814 0.8 billion Total copper required to convert all cars, trucks & buses to battery electric 140.3 billion

The 140.3 billion pounds of total copper from Table 2 is equivalent to about 63.6 million metric tons. If we assume that the total conversion to battery electric vehicles will take place over 20 years then that requires about 3.18 million metric tons of copper per year. According to the U.S. Geological Survey (“USGS”) the United States only produced 1.27 million metric tons of copper in 2017.11 Furthermore, also according to the USGS the total capacity of all operating copper mines in the United States is only 1.79 million metric tons per year.12 Thus we are roughly 3.18 – 1.79 = 1.39 million metric tons per year short of where we need to be just to convert all of our cars, trucks and buses to battery electric. This is not even counting the copper

6 See “How Copper Drives Electric Vehicles” Copper Development Association Inc., https://www.copper.org/publications/pub_list/pdf/A6192_ElectricVehicles-Infographic.pdf (June 29, 2018). 7 Ibid. 8 Ibid. 9 See Highway Statistics 2016, U.S Department of Transportation, Federal Highway Administration, Table MV-1 (total automobiles), https://www.fhwa.dot.gov/policyinformation/statistics/2016/mv1.cfm (November 2017). 10 For the purpose of this analysis it is assumed that a battery electric truck will require a similar amount of copper as a battery electric bus. 11 See Copper, U.S. Geological Survey, Mineral Commodity Summaries, https://minerals.usgs.gov/minerals/pubs/commodity/copper/mcs-2018-coppe.pdf, January 2018, p. 52. 12 See 2015 Minerals Yearbook – Copper [Advance Release], https://minerals.usgs.gov/minerals/pubs/commodity/copper/myb1-2015-coppe.pdf, October 2017, Table 2, p. 20.9. The 1.79 million ton figure is obtained by adding together the capacities of each of the 18 listed mines.
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needed for wind turbines, charging stations, and other green energy products. The Pebble Mine is a key part of the solution to this problem. It proposes to produce 150,000 metric tons per year, on average.13
The United States already uses more copper than it mines and is a net importer.14 By mining more copper inside the United States we can create American jobs and facilitate the transition of our transportation infrastructure to zero-emission battery electric vehicles.
THE RELATIONSHIP BETWEEN SUPPLY, DEMAND AND PRICE MEANS A LOT MORE COPPER IS NEEDED
The relationship between supply, demand and price is the most basic principle of a free market economy. The relevant aspect of this relationship with respect to copper and our nation’s conversion to sustainable energy is that for the price of something to remain steady or decrease while demand is rising the supply of the thing must rise. In other words, to make sure the prices of electric vehicles remain affordable as more and more people buy them the supply of vehicles and their components (like copper) must increase at least as fast as the demand.
If the price of electric vehicles comes down people will buy more of them. For the price of electric vehicles to decline the cost of making them has to decline. If the costs involved in making electric vehicles – such as the cost of copper – decline enough to significantly increase demand then the increased demand will naturally result in higher prices unless supply can be increased enough to address the higher demand. The supply of copper and other components needs to rise dramatically to encourage consumer adoption of electric vehicles.
There is a perfect real-world example of the supply-demand principle that involves vehicles using traditional energy. When the supply of gasoline rises faster than demand for gasoline the price of gasoline drops, and the lower price results in an increase in demand.
In the seven-year period from July 2001 to July 2008 the price of gasoline in the United States rose from $1.44 per gallon to $4.16 per gallon, a 189% increase.15 Over the next seven plus years from July 2008 to February 2016 the price of gasoline declined from $4.16 per gallon to $1.83 per gallon, a 56% decrease.16 These gasoline price fluctuations were accompanied by changes in Americans’ driving habits. After steadily increasing for decades annual miles traveled in the United States plateaued in the 2006-2008 timeframe as gasoline prices were peaking,

13 Assuming 1/20th of its 6.7 billion pounds of copper are mined each year over its proposed 20-year mine life, which amounts to 150,000 metric tons per year (6.7 billion ÷ 20 years = 335 million pounds per year. 335 million pounds per year ÷ 2,204.62 pounds per metric ton = 151,954 metric tons per year). 14 See Copper, U.S. Geological Survey, Mineral Commodity Summaries, https://minerals.usgs.gov/minerals/pubs/commodity/copper/mcs-2018-coppe.pdf, January 2018, p. 52. 15 See Weekly U.S. All Grades All Formulations Retail Gasoline Prices, U.S. Energy Information Administration, https://www.eia.gov/dnav/pet/hist/LeafHandler.ashx?n=PET&s=EMM_EPM0_PTE_NUS_DPG&f=W, (June 29, 2018). 16 Ibid.
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and then declined for the first time in decades from 2008 to 2009.17 As time passed and gasoline prices declined and remained lower annual miles driven began growing again – from 2.95 trillion miles in 2010 to 3.17 trillion in 2016.18 Rising gas prices caused people to purchase less gasoline. Declining gas prices caused people to buy more gasoline.
It was increased extraction of a natural resource (oil) in the United States that caused the gasoline supply to increase and price to decline after its peak in 2008.19 American ingenuity and American workers made this happen. They brought enough new product to market to make it more affordable for more people. The increase in supply of gasoline lowered its price, which led to greater consumption. What we need now is something similar to happen for sustainable energy-based transportation. We need to lower the costs associated with electric vehicles in order to increase consumer demand. And to lower the costs we need to increase supply, including the supply of components like copper.
THE PEBBLE MINE WOULD BENEFIT ALASKA’S SALMON
While some have focused on how the proposed Pebble Mine might bring some negative environmental impacts to the immediate local area, it is equally important to focus on how the Pebble Mine can also bring positive environmental impacts not only to the local area but to the United States as a whole.
Most decisions involve trade-offs. We have to give up things to get things. The question that must be considered when it comes to the Pebble Mine is what is it worth to work toward more affordable zero emission sustainable energy options?
According to the U.S. Environmental Protection Agency (“EPA”) cars, trucks and buses put 1,513 million metric tons of carbon dioxide (CO2) into the atmosphere each year.20 Also according to EPA a typical passenger vehicle emits about 4.6 metric tons of CO2 each year.21 As noted earlier the Pebble Mine has the potential to generate 6.7 billion pounds of copper,22 enough to

17 See Annual Vehicle Miles Traveled in the U.S., U.S. Department of Energy, https://www.afdc.energy.gov/data/10315, (June 29, 2018). 18 Ibid. 19 See Hydraulic fracturing accounts for about half of current U.S. crude oil production, U.S. Energy Information Administration, https://www.eia.gov/todayinenergy/detail.php?id=25372, March 15, 2016. 20 See Sources of Greenhouse Gas Emissions, https://www.epa.gov/ghgemissions/sources-greenhouse-gasemissions (June 29, 2018), which says there were 6,511 million metric tons of CO2 equivalent emissions in the United States in 2016 and that the transportation sector made up 28% or 1,823 million metric tons of the total. See also Fast Facts on Transportation Greenhouse Gas Emissions, https://www.epa.gov/greenvehicles/fast-factstransportation-greenhouse-gas-emissions (June 29, 2018), which says light-duty vehicles, medium- and heavy-duty trucks account for 83% of CO2 emissions in the transportation sector in the U.S. Eighty three percent of 1,823 million metric tons is 1,513 million metric tons. 21 See Greenhouse Gas Emissions from a Typical Passenger Vehicle, https://www.epa.gov/greenvehicles/greenhouse-gas-emissions-typical-passenger-vehicle (June 29, 2018). 22 See The Pebble Project, Department of the Army Application for Permit (POA-2017-271), Attachment D, Project Description, Table 1-1, p. 14 (December 2017).
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support production of 36.6 million electric cars.23 Thus the Pebble Mine has the potential to support production of enough electric cars to remove 168 million metric tons of CO2 emissions each year.24
A 2016 report from The West Coast Ocean Acidification and Hypoxia Science Panel concluded that “Global carbon dioxide (CO2) emissions over the past two centuries have altered the chemistry of the world’s oceans, threatening the health of coastal ecosystems and industries that depend on the marine environment. This fundamental chemical alteration is known as ocean acidification (OA), a phenomenon driven by the oceans absorbing approximately onethird of atmospheric CO2 generated through human activities.”25
The EPA has recognized ocean acidification as an issue that must be addressed. It says, “The carbon dioxide that humans are releasing to the atmosphere by burning fossil fuels (oil, coal, and natural gas) is changing the chemistry of the ocean by increasing its acidity.”26 EPA goes on to say, “Ocean and coastal acidification can harm plants and animals. Shell-forming animals like clams and oysters are particularly vulnerable. Impacts to sensitive species will likely have a ripple effect on all kinds of life in the ocean. Ultimately, key resources like seafood that humans rely on will be affected. Because of this serious issue, EPA is working to address ocean and coastal acidification.”27
A 2015 research report, Responses of pink salmon to CO2-induced aquatic acidification, concludes CO2-induced acidification causes reductions in growth, yolk-to-tissue conversion and maximal oxygen (O2) uptake capacity in pink salmon during their development in fresh water and following early seawater entry. It also concludes that CO2-induced acidification significantly alters olfactory responses, anti-predator behavior and anxiety at this critical and sensitive life stage.28
According to the World Wildlife Fund (“WWF”) “climate change is arguably the most desperate threat to sockeye salmon.”29 WWF says, “the increase of carbon dioxide in the atmosphere, and

23 This assumes 183 pounds of copper per electric car and 113 million cars on the road today in the United States. See footnotes 6 and 9 for details. 24 Calculated by multiplying 4.6 metric tons of CO2 per year per car by 36.6 million cars. 25Chan, F., Boehm, A.B., Barth, J.A., Chornesky, E.A., Dickson, A.G., Feely, R.A., Hales, B., Hill, T.M., Hofmann, G., Ianson, D., Klinger, T., Largier, J., Newton, J., Pedersen, T.F., Somero, G.N., Sutula, M., Wakefield, W.W., Waldbusser, G.G., Weisberg, S.B., and Whiteman, E.A. The West Coast Ocean Acidification and Hypoxia Science Panel: Major Findings, Recommendations, and Actions. California Ocean Science Trust, Oakland, California, USA. April 2016. p.4. 26 See “An Introduction to Ocean and Coastal Acidification,” U.S. Environmental Protection Agency, https://www.epa.gov/ocean-acidification/introduction-ocean-and-coastal-acidification, (June 29, 2018). 27 Ibid. 28 Michelle Ou, Trevor J. Hamilton, Junho Eom, Emily M. Lyall, Joshua Gallup, Amy Jiang, Jason Lee, David A. Close, Sang-Seon Yun & Colin J. Brauner; “Responses of pink salmon to CO2-induced aquatic acidification;” Nature Climate Change volume 5, pages 950–955 (2015). 29 See Sockeye salmon and climate change, https://www.worldwildlife.org/stories/sockeye-salmon-and-climatechange (June 29, 2018).
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in the ocean as a result, is causing ocean acidification, which significantly impacts the salmon’s food chain.”30 Importantly while WWF expresses its belief that the proposed Pebble Mine might be a threat to Bristol Bay’s sockeye salmon,31 it says climate change is the most desperate threat.
The Natural Resources Defense Council (“NRDC”) says ocean acidification “may devastate some marine ecosystems and threaten the productivity of our fisheries.”32 NRDC specifically addresses the impact on Alaska’s pink salmon, saying “shellfish will be affected directly, thus impacting finfish who feed on them. For example, pteropods – tiny marine snails that are particularly sensitive to rises in acidity – comprise 60 percent of the diet for Alaska’s juvenile pink salmon. And this affects diets farther up the food chain, as a diminished salmon population would lead to less fish on our tables.”33
By helping to facilitate our conversion to zero emission sustainable energy the Pebble Mine could help us address these issues.
Research has found the ocean off the West Coast of the United States to have an increasing level of acidity. Research has also found that increasing levels of acidity in the ocean negatively affect salmon populations. The NRDC and the WWF have recognized increasing levels of acidity as the most desperate threat to Bristol Bay’s sockeye salmon. To address this problem in Bristol Bay, in Alaska, and throughout the United States we need to transition to zero emission sustainable energy, which for all practical purposes means electricity. To support all of the new electric power generation systems, transmission systems, and end user systems needed to make this transition we need to mine a lot more copper.
THE UPSIDE POTENTIAL TO REDUCE LEVELS OF ACIDITY IN WATERS OF THE UNITED STATES DWARFS THE DOWNSIDE RISK
When it comes to the level of acidity in waters of the United States the main potential hazards posed by the proposed Pebble Mine are the potentially acid generating waste rock and the pyritic tailings. Waste rock is material that contains minerals in concentrations considered too low to be extracted at a profit. Tailings are finely ground rock and mineral waste products of mineral processing operations. Not all waste rock is potentially acid generating, and not all tailings are pyritic. In the proposed Pebble Mine the potentially acid generating waste rock would be stored in the lined low-grade ore stockpile.34 The pyritic tailings would be placed in a lined storage cell in the tailings storage facility.35 The quantity of potentially acid generating

30 Ibid. 31 Ibid. 32 See Ocean Acidification: The Other CO2 Problem, https://www.nrdc.org/sites/default/files/NRDCOceanAcidFSWeb.pdf (2009) p. 1. 33 Ibid. 34 See The Pebble Project, Department of the Army Application for Permit (POA-2017-271), Tab 18.2.1, p. 5 (December 2017). 35 Ibid.
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waste rock and pyritic tailings anticipated in the Pebble Mine proposal are summarized in Table 3.
Table 3: Quantity of materials in proposed Pebble Mine with potential to impact levels of acidity in waters of the United States
Material Total weight Storage facility volume
Storage facility liner thickness
Potentially acid generating waste rock in growth medium stockpile – low grade ore facility


28 million tons36


3,373,000 CY37


0.5 ft.38
Pyritic tailings in growth medium stockpile – pyritic tailings storage facility


135 million tons39


3,644,000 CY40


0.5 ft.41

The Pebble Mine proposal indicates that the pyritic tailings will be thickened, mixed with water treatment plant sludge, and pumped to the pyritic tailings storage facility42 where they will be discharged underwater to prevent oxidation and potential acid generation.43 Thickening the tailings reduces their propensity to seep. To further insure against seepage the Pebble Mine proposal indicates that the pyritic tailings storage facility will be lined with a 0.5 ft. thick liner.44 Plus, in the event there is any seepage from the thickened tailings that somehow makes it through the 0.5 ft. liner the Pebble Mine proposal includes subsurface drains to convey any such seepage to the north and south based on topography.45 Thus the proposed mine includes protection against pyritic tailings becoming acidic and triple protection against them making it

36 See The Pebble Project, Department of the Army Application for Permit (POA-2017-271), Attachment D, Table 3-2 and Table 3-3, p. 30 (December 2017). One million tons plus 27 million tons equals 28 million tons. 37 See The Pebble Project, Department of the Army Application for Permit (POA-2017-271), Table 21-4, p. 13 (December 2017). 38 Id., p. 14. 39 See The Pebble Project, Department of the Army Application for Permit (POA-2017-271), Attachment D, Table 3-1, p. 28 (December 2017). 40 See The Pebble Project, Department of the Army Application for Permit (POA-2017-271), Table 21-4, p. 13 (December 2017). 41 Id., p. 15. 42 See The Pebble Project, Department of the Army Application for Permit (POA-2017-271), Attachment D, section 3.3.6, p. 40 (December 2017). 43 Id., section 3.4.3, p. 42. 44 See The Pebble Project, Department of the Army Application for Permit (POA-2017-271), Table 21-4, p. 15 (December 2017). 45 See The Pebble Project, Department of the Army Application for Permit (POA-2017-271), Attachment D, section 3.4, p. 40 (December 2017).
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into nearby waters. Water associated with the processing of the pyritic tailings will be returned to the waste treatment plant where it will either be re-used or treated before discharge.46
The potentially acid generating waste rock would be stored with other waste rock in the lowgrade ore stockpile, which like the pyritic tailings storage facility would be lined with a 0.5 ft. liner.47 It is conceivable that at some time during the operation of the proposed mine it might become economical to extract minerals from the waste rock. Whether this happens or not, when the mine is closed any remaining waste rock would be returned to the pit from which it was excavated.48
The Pebble Mine is expected to generate 6.8 million tons of pyritic tailings per year on average over the 20-year life of the mine.49 It is also expected to generate 1.4 million tons of potentially acid generating waste rock per year over the life of the mine.50 Importantly, there is a finite amount of pyritic tailings and waste rock that would be generated by the mine, meaning that the potential risk associated with the tailings or the waste rock affecting the level of acidity in nearby water is limited.
In contrast the benefits that could be realized by using the copper from the proposed Pebble Mine to convert to zero emission sustainable energy are virtually unlimited because the electric machines and systems that the copper could support would be operating year after year, and thus eliminating CO2 emissions year after year. Even after these machines are taken out of service most of the copper in them will be recycled, enabling the production of new machines that can avoid even more CO2 emissions.
According to the Copper Development Association, “each year in the U.S.A., nearly as much copper is recovered from recycled material as is derived from newly mined ore... and when you exclude wire production, most of which uses newly refined copper, the amount of copper used by copper and brass mills, ingot makers, foundries, powder plants and other industries shows that nearly three-fourths (72%) comes from recycled copper scrap.”51 There are two very important points in that statement. First, most of the copper extracted from the proposed Pebble Mine can be expected to be recycled after its first use, so it could help replace CO2 emitting machines with zero emission electric machines for many years to come, well beyond

46 See The Pebble Project, Department of the Army Application for Permit (POA-2017-271), Attachment D, section 3.3.6, p. 40 (December 2017). 47 See The Pebble Project, Department of the Army Application for Permit (POA-2017-271), Table 21-4, p. 14 (December 2017). 48 Id., section 6, p. 79. 49 See The Pebble Project, Department of the Army Application for Permit (POA-2017-271), Attachment D, Table 3-1, p. 28 (December 2017). Divide 135 million tons of pyritic tailings over 20 years to get an average of 6.8 million tons per year. 50 Id., Table 3-2 and Table 3-3, p. 30. One million tons plus 27 million tons equals 28 million tons, divided by 20 years results in 1.4 tons per year on average. 51 See Copper - the World's Most Reusable Resource, https://www.copper.org/environment/lifecycle/g_recycl.html, (June 29, 2018).
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the life of a single vehicle or machine. Second, most wire production uses newly refined copper, so wires like the windings in the motors of electric vehicles and the power cables in electric vehicles generally come from newly mined ore, meaning that sources of new copper like the proposed Pebble Mine are critical if our nation is to convert to zero emission sustainable energy. Recycling helps because it enables the demand for copper for applications like pipes, brass fixtures, or bronze to be addressed with recycled material while wiring makes use of mostly newly mined copper. Newly mined copper is critical for wiring, and therefore for transitioning to zero emission sustainable energy.
In summary, with respect to possible impacts on the levels of acidity in waters of the United States the upside versus downside analysis is clear. The downside risk is that the Pebble Mine could generate 6.8 million tons of pyritic tailings per year for 20 years, and 1.4 million tons of potentially acid generating waste rock per year for 20 years, and that some very small percentage of this material could make it past the multiple layers of protection designed into the mine to prevent it from reaching waters of the United States. The upside potential is that 40 percent52 of 168 million metric tons53 – or 67 million metric tons – of CO2 could be kept out of the ocean every year indefinitely.
The downside risk is limited and known when it comes to the Pebble Mine’s potential impact on levels of acidity in our waters, and this limited downside risk pales in comparison to the massive upside potential of the mine to help reduce the amount of CO2 absorbed in our waters for years to come. Plus there is the additional upside of eliminating the remaining 60 percent of eliminated vehicle emissions that are not absorbed by the oceans, which amounts to 101 million metric tons of CO2 from the atmosphere every year, too.


52 Tim DeVries, Mark Holzer & Francois Primeau; “Recent increase in oceanic carbon uptake driven by weaker upper-ocean overturning,” Nature, volume 542, pages 215–218 (February 9, 2017). “The ocean is the largest sink for anthropogenic carbon dioxide (CO2), having absorbed roughly 40 per cent of CO2 emissions since the beginning of the industrial era.” 53 As noted earlier the Pebble Mine has the potential to generate 6.7 billion pounds of copper (see footnote 22), enough to support production of 36.6 million electric cars (see footnote 23), with the potential to eliminate 168 million metric tons of CO2 emissions each year (see footnote 24).
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CONCLUSION
Most decisions involve trade-offs. The decisions that need to be made regarding the proposed Pebble Mine are no different. Dramatically increasing the affordability and use of electric vehicles is worth a few sacrifices because the end result would be enormous improvements to the environment in Bristol Bay, in Alaska, and throughout the United States. In summary: • The environment in Bristol Bay, in Alaska, and throughout the United States will be dramatically improved if CO2 emitting equipment is replaced with zero emission electric equipment. • To replace CO2 emitting equipment with electric equipment we need the cost of electric equipment to be affordable. • To keep the cost of electric equipment affordable we need to make sure the cost of the materials used to make electric equipment remains affordable, and copper is one of the critical components used to make electric equipment. • To keep the cost of copper affordable we need to mine a lot more of it. The United States needs to at least double the amount of copper it is producing for there to be any hope of replacing all cars, trucks and buses with battery electric versions. • The proposed Pebble Mine is critical to making this happen.


Respectfully submitted, Dave Wilson
Dave Wilson 1400 N. 12th Street Arlington, VA 22209

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