Second External Review Draft  EPA910-R-12-004Bc  April 2013
   United States
   Environmental Protection
   Agency
       An Assessment of Potential Mining Impacts
       on Salmon Ecosystems of Bristol Bay, Alaska
                                           Volume 3 - Appendices E-J
^B

U.S. Environmental Protection Agency, Seattle, WA
www.epa.gov/bristolbay
                Second External Review Draft - Do Not Cite or Quote

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DRAFT                                            EPA910-R-12-004BC
DO NOT CITE OR QUOTE                                 April 2013
                                                 Second External Review Draft
                                                 www.epa.gov/bristolbay
    An Assessment of Potential Mining Impacts on
       Salmon Ecosystems of Bristol Bay, Alaska

                  Volume 3 - Appendices E-J
                               NOTICE
    THIS DOCUMENT IS AN EXTERNAL REVIEW DRAFT. It has not been formally released by
    the U.S. Environmental Protection Agency and should not be construed to represent Agency
    policy. It is being circulated for comment on its technical accuracy and policy implications.
                     U.S. Environmental Protection Agency
                              Seattle, WA

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                                 DISCLAIMER

This document is distributed solely for the purpose of pre-dissemination peer review under
applicable information quality guidelines. It has not been formally disseminated by the U.S.
Environmental Protection Agency (USEPA). It does not represent and should not be
construed to represent any Agency determination or policy. Mention of trade names or
commercial products does not constitute endorsement or recommendation for use.

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                                  CONTENTS


VOLUME 1
An Assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay, Alaska


VOLUME 2
APPENDIX A: Fishery Resources of the Bristol Bay Region

APPENDIX B: Characterizations of Selected Non-Salmon Fishes Harvested in the Fresh
Waters of Bristol Bay

APPENDIX C: Wildlife Resources of the Nushagak and Kvichak River Watersheds

APPENDIX D: Ecological Knowledge and Cultures of the Nushagak and Kvichak Watersheds,
Alaska


VOLUME 3
APPENDIX E: Bristol Bay Wild Salmon Ecosystem: Baseline Levels of Economic Activity and
Values

APPENDIX F: Biological Characterization: Bristol Bay Marine Estuarine Processes, Fish, and
Marine Mammal Assemblages

APPENDIX G: Foreseeable Environmental Impact of Potential Road and Pipeline
Development on Water Quality and Freshwater Fishery Resources of Bristol Bay, Alaska

APPENDIX H: Geologic and Environmental Characteristics of Porphyry Copper Deposits
with Emphasis on Potential Future Development in the Bristol Bay Watershed, Alaska

APPENDIX I: Conventional Water Quality Mitigation Practices for Mine Design,
Construction, Operation, and Closure

APPENDIX J: Compensatory Mitigation and Large-Scale Hardrock Mining in the Bristol Bay
Watershed

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DRAFT                                                 EPA910-R-12-004Bc
DO NOT CITE OR QUOTE                                   April 2013
                                                      Second External Review Draft
                                                      www.epa.gov/bristolbay
      An Assessment of Potential Mining Impacts on Salmon
                  Ecosystems of Bristol Bay, Alaska


                   Volume 3 of 3 -Appendices E-J


    Appendix E: Bristol Bay Wild Salmon Ecosystem: Baseline
               Levels of Economic Activity and Values
                                 NOTICE
   THIS DOCUMENT IS AN EXTERNAL REVIEW DRAFT. It has not been formally released by
   the U.S. Environmental Protection Agency and should not be construed to represent Agency
   policy. It is being circulated for comment on its technical accuracy and policy implications.
                       U.S. Environmental Protection Agency
                                Seattle, WA

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Bristol Bay Wild Salmon Ecosystem
Baseline Levels of Economic Activity and Values
John Duffield
Chris Neher
David Patterson
Bioeconomics, Inc. Mlssoula, MT

Gunnar Knapp
Institute of Social and Economic Research—University of Alaska
Anchorage

Tobias Schworer
Ginny Fay
Oliver Scott Goldsmith
Institute of Social and Economic Research
University of Alaska Anchorage
March 2013
For:
NatureServe
Conservation Services Division
           v Institute of Social
       and Economic Research
       UNIVERSITY 
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Contents

  	i
Contents	2
List of Tables	4
List of Figures	7
Executive Summary	9
  Subsistence and Village Economies	11
  Commercial Fisheries	14
  Recreation	17
  Summary of Economic Significance	17
  Net Economic Values	22
1.0 Introduction and Setting	28
  1.1 Study Objectives and Report Organization	28
  1.2 Definition of Study Area	29
  1.3 Focus of Study-Economic Uses	32
2.0 Bristol Bay Recreation and Subsistence Economics	35
  2.1 Bristol Bay Sportfishing Economics	35
  2.1.1 Bristol Bay Area Trip Characteristics and Angler Attitudes	35
  2.1.2 Bristol Bay Angler Expenditures	38
  2.1.3 Aggregate Direct Sport fishing Expenditures in Bristol Bay	40
2.2 Bristol Bay Subsistence Harvest Economics	42
2.3 Bristol Bay Sport Hunting and Non-consumptive Economics	46
  2.3.1 Sport Hunting	46
  2.3.2 Non-consumptive Wildlife Viewing / Tourism Economics	48
3.0 Bristol Bay Commercial Fisheries	50
  3.1 Introduction	50
  3.2 Overview of the Bristol Bay Salmon Industry	51
  3.3 Bristol Bay Salmon Harvests	56
  3.4 Bristol Bay Salmon Products and Markets	70
  3.5 Bristol Bay Salmon Prices	79
  3.6 Bristol Bay Salmon Ex-Vessel and Wholesale Value	91
  3.7 Bristol Bay Salmon Fishermen	95
  3.8 Bristol Bay Salmon Processors	104
  3.9 Bristol Bay Salmon Industry Employment	108
  3.10 Bristol Bay Salmon Industry Taxes	116
  3.11 Regional Distribution of Bristol Bay Permit Holders, Fishery Earnings, and Processing
  Employment	118
  3.12 Distribution of Salmon Permits and Earnings within The Bristol Bay Region	128
  3.13 Economic Measures of the Bristol Bay Salmon Industry	137
  3.14 Bristol Bay Commercial Fisheries: Summary	144
  3.15 Appendix:  Data Sources	153
4.0 Economic Significance of Healthy Salmon Ecosystems in the Bristol Bay Region: Summary
Findings	171
  4.1 Introduction	173
  4.2 Methods	174

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  4.3 Regional Economic Overview	178
  4.4 Commercial Salmon Fisheries	182
  4.5 Recreation	184
     4.5.1 Non-Consumptive Use	187
     4.5.2 Sport Fishing	188
     4.5.3 Sport Hunting	189
  4.6 Subsistence	190
  4.7 Conclusions	191
  4.8 Key Assumptions and Uncertainties	193
  4.9 Data Sources	196
5.0 Bristol Bay Net Economic Values	199
  5.1 Commercial Fisheries	199
  5.2 Subsistence Harvest	203
  5.3 Sport Fishing Net Economic Value	208
  5.4 Sport Hunting Net Economic Value	210
  5.5 Wildlife Viewing and Tourism Net Economic Value	211
  5.6 Total  Net Economic Value and Present Value and Inter-temporal Issues	211
References	217

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List of Tables

Table 1. Bristol Bay Area Communities, Populations, and Subsistence Harvest	12
Table 2. Selected Economic Measures of the Bristol Bay Commercial Salmon Industry, 2000-
2010	16
Table 3. Summary of Regional Economic Expenditures Based on Wild Salmon Ecosystem
Services (Million 2009 $)	18
Table 4. Total Estimated Recreational Direct Spending in Alaska Attributable to Bristol Bay
Wild Salmon Ecosystems, 2009	19
Table 5. Cash Economy Full-time Equivalent Employment Count by Place of Work in the
Bristol Bay Region, 2009	20
Table 6. Cash Economy Estimated Economic Significance of Bristol Bay Ecosystems	21
Table 7. Summary of Bristol Bay Wild Salmon Ecosystem Services, Net Economic Value per
Year (Million 2009 $)	27
Table 8. Estimated Net Present Value of Bristol Bay Ecosystem Net Economic Use Values and
Alternative Assumed Perpetual Discount Rates	27
Table 9. Demographic and Socioeconomic Characteristics of the Bristol Bay Region	29
Table 10. Bristol Bay Area Communities and Populations	30
Table 11:  Types of Ecosystem Services	33
Table 12. Bristol Bay Angler Distribution across Trip Types, by Residency	36
Table 13:  Bristol Bay Angler Trip Characteristics	37
Table 14:  Bristol Bay Angler Survey, Targeted Species	37
Table 15:  Bristol Bay Angler Rating of Selected Attributes of Fishing Trip	38
Table 16. Nonresident Trips to Bristol Bay Waters, Mean Expenditure Per Trip Estimates By
Trip Type	39
Table 17:  Distribution of Trip Expenditures across Spending Categories, by Residency and Area
	39
Table 18. Estimated 2009 Bristol Bay area angler trips, by Angler Residency	40
Table 19. Estimated Aggregate Spending Associated with Sportfishing in the Bristol Bay Region
(2009 dollars)	41
Table 20. Bristol Bay Sportfishing: Aggregate in and out of Region and State  Spending (2009)41
Table 21.  ADF&G Division of Subsistence Average Per Capita Subsistence Harvest for Bristol
Bay Communities	43
Table 22.  Historical Subsistence Salmon Harvest for Bristol Bay, Alaska: 1975-2007 (ADF&G
Division of Subsistence ASFDB)	44
Table 23.  Bristol Bay Subsistence Salmon Harvests by District and Location Fished, 2007	45
Table 24.  Estimated Total Annual Bristol Bay Area Subsistence-Related Expenditures (2009 $)
	46
Table 25. ADF&G Reported Big Game Hunting in Bristol Bay and Alaska Peninsula Game
Management Units	47
Table 26. Estimated annual big game hunting expenditures for Bristol Bay region	47
Table 27. Comparison of Bristol Bay Drift Gillnet and Set Gillnet Fisheries (2006-10 Average)
	63
Table 28. Sales of Selected Sockeye Salmon Products	72
Table 29. Selected Indicators of Participation in 2009 Drift Gillnet Fishery	98

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Table 30. Estimated Number of 2009 Drift Gillnet Permit Holders who Fished Alone, With
another Permit Holder, or Did Not Fish	98
Table 31. Estimates of Bristol Bay Processor Costs, Prices and Profits	106
Table 32. Indicators and Estimates of Bristol Bay Salmon Industry Fishing Processing
Employment	Ill
Table 33. Monthly Employment in Food Manufacturing, by Borough or Census Area	115
Table 34. Selected Data and Estimates for Bristol Bay Salmon Taxes	117
Table 35. Comparison of Vessels Used in the Bristol Bay Drift Gillnet Fishery, by Residency of
Permit Holder	122
Table 36. Participation and Gross Earnings in Bristol Bay Salmon Fisheries	127
Table 37. Population, Permit Holders, and Salmon Earnings, by Community: 2000 & 2010 ... 129
Table 38. Salmon Permit Holders per 100 Residents, by Community	134
Table 39. Bristol Bay Salmon Fishery Earnings, by Community	136
Table 40. Economic Measures of Bristol Bay Salmon Industry: Sockeye Salmon Harvests	138
Table 41. Economic Measures of Bristol Bay Salmon Industry: Sockeye Value	139
Table 42. Economic Measures of the Bristol Bay Salmon Industry: Export Value	141
Table 43. Economic Measures of the Bristol Bay Salmon Industry: Employment	142
Table 44. Economic Measures of the Bristol Bay Salmon Industry: Permit Prices and Values.
(Source: www.cfec.state.ak.us/bit/MNUSALM.htm )	143
Table 45. Distribution of Harvests for Bristol Bay Fishing Districts, 1986-2010	146
Table 46. Geographic Distribution of Bristol Bay Salmon Industry Employment and Earnings.
	150
Table 47. Relative Indicators of 2010 Salmon Fishery Participation and Earnings	151
Table 48. Selected Economic Measures of the Bristol Bay Salmon Industry, 2000-2010	152
Table 49. Distribution of Selected Economic Measures for the Bristol Bay Commercial Salmon
Fishing Industry, 1980-2010	153
Table 50. Estimated Economic Significance of Bristol Bay Ecosystems	172
Table 51. Annual average jobs associated with $1 million in spending in each sector in
Southwest Alaska, 2009	176
Table 52. Annual payroll associated with $1 million in spending in each sector in Southwest
Alaska, 2009	177
Table 53. Employment Count by Place of Work in the Bristol Bay Region, 2009	179
Table 54. Federal Spending in the Bristol Bay Region, 2009 ($000)	179
Table 55. Estimated Residence of Workers in the Bristol Bay Region 2009	180
Table 56. Estimated Personal Income in the Bristol Bay Region, 2009 (000$)	181
Table 57. Estimated Economic Significance of Commercial Fishing	183
Table 58. Estimated Recreational Visitors and Expenditures in the Bristol Bay Region, 2009. 185
Table 59. Estimated Economic Significance of All Recreation	186
Table 60. Estimated Economic Significance of Non-Consumptive Use	187
Table 61. Estimated Economic Significance of Sport Fishing	188
Table 62. Estimated Economic Significance of Sport Hunting	189
Table 63. Estimated Economic Significance of Subsistence	190
Table 64. Estimated Economic Significance of Bristol Bay Ecosystems	192
Table 65. Current Bristol Bay Salmon Fishing Permit Numbers and sale prices, 2011	200
Table 66. Estimation of Total 2011 Net Income for the Bristol Bay Salmon Harvest and
Processing Sectors based on Reported 1990-2001 Net Income (Link et al. 2003)	202

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Table 67. Estimated Two-Stage Least Squares Wage Compensating Differential Model of
Subsistence Harvest in 90 Alaska Communities (Duffield 1997)	205
Table 68. Estimated Total Annual Bristol Bay Subsistence Harvest (usable pounds of harvest)
	207
Table 69. Estimated Net Economic Annual Value of Bristol Bay Area Subsistence Harvest... 208
Table 71: Estimated Mean Willingness to Pay for Anglers' Recent Trip to Bristol Bay	209
Table 72. Estimated Willingness to Pay for Sportfishing Fishing  in the Bristol Bay Region.... 210
Table 73. Estimated annual big game hunting net economic value for Bristol Bay region	210
Table 74. Summary of Bristol Bay Wild Salmon Ecosystem Services, Net Economic Value per
Year (Million 2009 $)	214
Table 75. Estimated Net Present Value of Bristol Bay Ecosystem Net Economic Use Values and
Alternative Assumed Perpetual Discount Rates	216

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List of Figures

Figure 1. Map of Bristol Bay Study Area	11
Figure 2. Bristol Bay Area Location and Major Communities	13
Figure 3. Bristol Bay Area Commercial Salmon Fishery Management Districts	14
Figure 4. Selected Bristol Bay Salmon Processor Costs: 2001-2009	24
Figure 5. Flows of Ecosystem Services (adapted from (National Research Council 2005))	25
Figure 6. Bristol Bay Area Location and Major Communities	30
Figure 7. Map of Bristol Bay Study Area	32
Figure 8. Comparison of Resident and Nonresident Bristol Bay Angler Trip Types	36
Figure 9. Distribution of Bristol Bay Subsistence Harvest	42
Figure 10. Major Bristol Bay River Systems	52
Figure 11. Bristol Bay Commercial Salmon Harvests	56
Figure 12. Bristol Bay Fishing Districts. Source: ADFG map posted at:	57
Figure 13. Bristol Bay Commercial Sockeye Salmon Harvests, by District	58
Figure 14. Share of Bristol Bay Commercial Sockeye Salmon Harvest, by District	59
Figure 15. Naknek-Kvichak District Sockeye Salmon Harvests, by River of Origin	60
Figure 16. Bristol Bay Salmon Harvests, by Fishery	64
Figure 17. World Sockeye Supply	65
Figure 18. Alaska Salmon Supply	66
Figure 19. World Salmon and Trout Supply	67
Figure 20. Bristol Bay Sockeye Preseason Projection and Actual Commercial Catch	68
Figure 21. Bristol Bay Salmon Harvests, 1985-2009	69
Figure 22. Bristol Bay Sockeye Salmon Production	71
Figure 23. Share of Sockeye Salmon Production in Bristol Bay	71
Figure 24. Bristol Bay Sockeye Salmon Harvests and Production	73
Figure 25. Monthly Sales Volume of Bristol Bay Salmon Products	74
Figure 26. Alaska Frozen Sockeye Production and U.S. Frozen Sockeye Exports	76
Figure 27. Estimated End-Markets for Alaska Frozen Sockeye Salmon	77
Figure 28. Alaska Canned Sockeye Production and U.S. Canned Sockeye Exports	78
Figure 29. Average Ex-Vessel Price of Bristol Bay Sockeye Salmon, 1975-2010	79
Figure 30. Average Wholesale and Ex-Vessel Prices of Bristol Bay Sockeye Salmon	80
Figure 31. Average Monthly First Wholesale Prices	82
Figure 32. Average Wholesale and Ex-Vessel Prices, Bristol Bay and Rest of Alaska	83
Figure 33. Average Ex-Vessel Prices of Sockeye Salmon, Selected Alaska Areas	83
Figure 34. Japanese Red-Fleshed Salmon Imports, May-April	84
Figure 35. Japanese Red-Fleshed Frozen Salmon Imports & Wild Sockeye Wholesale Price.... 85
Figure 36. Japanese Wholesale Prices and Bristol Bay Prices for Sockeye Salmon	86
Figure 37. Average United States Import Prices of Selected Farmed Salmon Products	87
Figure 38. U.S. Wholesale Prices for Selected Wild and Farmed Salmon Products	87
Figure 39. Monthly Average Wholesale Case Prices for Alaska Canned Sockeye Salmon	88
Figure 41. Ex-Vessel and First Wholesale Value: 1984-2010	92
Figure 42. Distribution of Nominal Value of Bristol Bay Sockeye Salmon	93
Figure 43. Distribution of Value of Bristol Bay Sockeye Salmon	94
Figure 44. Number of Limited Entry Permits  Issued and Fished in Bristol Bay	96
Figure 45. Average Gross Earnings of Bristol Bay Drift Gillnet Permit Holders	99

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Figure 46. Average Gross Earnings of Bristol Bay Set Gillnet Permit Holders	100
Figure 47. Average Prices Paid for Bristol Bay Limited Entry Permits	101
Figure 48. Average Permit Prices and Total Earnings: Bristol Bay Drift Gillnet Fishery	102
Figure 49. Average Prices and Earnings: Bristol Bay Set Gillnet Fishery	102
Figure 50. Northern Economies' Estimates of the Breakdown of Operating Costs	103
Figure 51. Number of Companies Reporting Salmon Production in Bristol Bay, by Product... 105
Figure 52. Selected Bristol Bay Salmon Processor Costs, 2001-2009	107
Figure 53. Selected Estimates of Bristol Bay Salmon Fishing and Processing Workers	112
Figure 54. Monthly Employment in Food Manufacturing, Bristol Bay Region	114
Figure 55. Bristol Bay Region Local Communities Source:
www.visitbristolbay.org/bbvc/images/bbjnap large.jpg	119
Figure 56. Number of Bristol Bay Permit Holders by Residency	120
Figure 57. Permit Holders Average Earnings, by Residency	121
Figure 58. Share of Total Earnings of Bristol Bay Drift  Gillnet Permit Holders, by Residency 123
Figure 59. Share of Total Earnings of Bristol Bay Set Gillnet Permit Holders, by Residency.. 124
Figure 60. Share of Bristol Bay Seafood Processing Employment, by Residency	125
Figure 61. Local Bristol Bay Resident Share of Salmon Fisheries: Selected Measures	126
Figure 62. Estimated Bristol Bay Area Population, by Area	130
Figure 63. Estimated Population by Region	130
Figure 64. Number of Drift Gillnet Holders, by Region	131
Figure 65. Number of Drift Gillnet Holders per 100 Residents, by Region	131
Figure 66. Number of Set Gillnet Holders, by Region	132
Figure 67. Number of Set Gillnet Permit Holders per 100 Residents, by Region	132
Figure 68. Total Salmon Fishery Earnings, by Region	135
Figure 69. Per Capita Salmon Fisheries Earnings, by Region	135
Figure 70. Bristol Bay Commercial Salmon Harvests	138
Figure 71. Ex-Vessel and Wholesale Value of Bristol Bay Sockeye Salmon	140
Figure 72. Estimated Value of US Exports of Bristol Bay Salmon Products	141
Figure 73. Estimated Total Value of Bristol Bay  Limited Entry Permits	144
Figure 74. Bristol Bay Commercial Salmon Harvests	145
Figure 75. Estimated Shares of Bristol Bay Sockeye Salmon Production, 2010	147
Figure 76. Average Ex-Vessel and Wholesale Prices of Bristol Bay Sockeye Salmon	148
Figure 77. Ex-Vessel and First Wholesale Value 1980-2010	149
Figure 78. Local Bristol Bay Resident Share of Bristol Bay Salmon Fisheries	150
Figure 79. Selected Bristol Bay Salmon Processor Costs: 2001-2009	212
Figure 80. Flows of Ecosystem Services (adapted from  (National Research Council 2005)) ... 213

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Executive Summary

The objective of this report is to characterize the baseline levels of economic activity and related
ecosystem services values for the Bristol Bay wild salmon ecosystem. The overarching purpose
of this report is to provide baseline economic information to the Environmental Protection
Agency in order to inform review of mining proposals in the Nushugak and Kvichak drainages.
Both regional economic significance and social net economic accounting frameworks are
described in this report. This study reviews and summarizes existing economic research on the
key sectors in this area and reports findings based on original survey data on expenditures and
net benefits. This report combines efforts on the part of Bioeconomics, Inc. and the University
of Alaska Institute of Social and Economic Research. John Duffield and Chris Neher compiled
the report and authored the executive summary, Sections 1, 2, and 5. Gunnar Knapp wrote
Section 3 (commercial fisheries), and Tobias Schworer, Ginny Fey and Scott Goldsmith wrote
Section 4.

The major components  of the total value of the Bristol Bay area watersheds include subsistence
use, commercial fishing, sport fishing and other recreation, and the preservation values (or
indirect values) held by users and the U.S.  resident population. The overall objectives of this
study is to estimate the  share of the total regional economy (expenditures, income, and jobs) that
is dependent on these essentially pristine wild salmon ecosystems and to provide a preliminary
but relatively comprehensive estimate of the total economic value (from an applied welfare
economics perspective) that relies on a healthy ecosystem.

It is important to note that while the geographic scope of this economic characterization report is
targeted to the Bristol Bay wild salmon ecosystem, the scope of the proposed mining activity is
somewhat narrower, including the Nushugak and Kvichak drainages.  Values tied to, and specific
to, the proposed mining activity (and discharges) in the Nushugak and Kvichak Drainages would
be a subset of those reported here, and have not been identified in this general characterization
analysis. This  report uses existing information and data to target this economic characterization
report to ecosystem services and associated economic activity and values, specific to the Bristol
Bay Region. However, data on different economic sectors vary in quality, and available data on
some economic activities (such as non-consumptive tourism) make it more difficult to identify
activities and associated economic values narrowly targeted to the Bristol Bay area. The overall
intent of this report is to provide a general picture of the full range of economic values associated
with ecosystem services supplied by the entire Bristol Bay region.

Following this executive summary, the report is organized into five main sections. Section 1
provides a brief introduction to the report. Section 2 addresses economic visitation and
expenditures related to sport fishing, subsistence harvests, hunting, and non-consumptive
recreation. Section 3 focuses on commercial fishing.  Section 4 combines the regional economic
activity associated with recreation and commercial fishing into an analysis of regional economic
significance of these activities.  Finally,  Section 5 focuses on the net economic values associated
with recreation and commercial fisheries in the Bristol Bay ecosystem.

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For purposes of a baseline year, the most recent generally available data year is used (2009).
Where available, (primarily in the commercial fisheries discussion) data on 2010 is also shown.
Summary values are presented for 2009 data and in 2009 dollars.

The rivers that flow into the Bristol Bay comprise some of the last great wild salmon ecosystems
in North America (Figure 1). The Kvichak River system supports the world's largest run of
sockeye salmon. While these are primarily sockeye systems, all five species of Pacific salmon
are abundant, and the rich salmon-based ecology also supports many other species, including
Alaska brown bears and healthy populations of rainbow trout. The Naknek, Nushugak, Kvichak,
Igushik, Egegik, Ugashik, and Togiak watersheds are all relatively pristine with very few roads
or extractive resource development. Additionally, these watersheds include several very large
and pristine lakes, including Lake Iliamna and Lake Becherof Lake Iliamna is one of only two
lakes in the world that supports a resident population of freshwater seals (the other is Lake
Baikal in Russia). Additionally, there are nationally-important public lands in the headwaters,
including Lake Clark National Park and Preserve, Katmai National Park and Preserve, Togiak
National Wildlife Refuge, and Wood-Tikchick State Park (the largest state park in the  U.S.).
The existing mainstays of the economy in this region are all wilderness-compatible and
sustainable in the long run: subsistence use, commercial fishing, and wilderness sport fishing,
hunting, and wildlife viewing and other non-consumptive recreation. Commercial fishing is
largely in the salt water outside of the rivers themselves and is closely managed for
sustainability. The subsistence, sport fish and other recreation sectors are relatively low impact
(primarily personal use and catch and release fishing, respectively).
                                           10

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                                                  Nushagak
                                                      Kvichak
                                                   Noknok
                                ^,-     UgasNK
                             '- - ^
                                                   *"  ^
                                                  ^      I
                                                
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ago. Three primary indigenous cultures are represented here: Alutiiq, Sugpiaq, Yupik Eskimos,
and the Dena'ina Athabascan Indians. The share of the population that is Alaska Native is
relatively high at 70 percent, compared to Alaska as a whole, with 16 percent.
Table 1. Bristol Bay Area Communities, Populations, and Subsistence Harvest
Bristol Bay Area
Community /year of
AKF&G survey
Aleknagik 2008
Clark's Point 2008
Dillingham 1984
Egegik 1984
Ekwok 1987
Igiugig2005
Iliamna 2004
King Salmon 2008
Kokhanok 2005
Koliganek 2005
Levelock 2005
Manokotak 2008
Naknek 2008
New Stuyahok 2005
Newhalen 2004
Nondalton 2004
Pedro Bay 2004
Pilot Point 1987
Port Alsworth 2004
Port Heiden 1987
South Naknek 2008
Ugashik 1987
Togiak City 2000
Twin Hills 2000
Un-surveyed communities
Total
Population
(2010 census)
219
62
2,329
109
115
50
109
374
170
209
69
442
544
510
190
164
42
68
159
102
79
12
817
74
457
7,475
Per Capita Harvest
(AKF&G Surveys)
296
1210
242
384
797
542
469
313
680
899
527
298
264
389
692
358
306
384
133
408
268
814
246
499

343
Total Annual
Harvest (Ibs)
64,824
75,020
563,618
41,856
91,655
27,100
51,121
117,062
115,600
187,891
36,363
131,716
143,616
198,390
131,480
58,712
12,852
26,112
21,147
41,616
21,172
9,768
200,982
36,926
-
2,563,313
% Native Population
(2000 census)
81.9%
90.7%
52.6%
57.8%
91.5%
71.7%
50.0%
29.0%
86.8%
87.4%
89.3%
94.7%
45.3%
92.8%
85.0%
89.1%
40.0%
86.0%
4.8%
65.6%
83.9%
72.7%
86.3%
84.1%


Sources: US Census Bureau (2010 census statistics), and ADF&G Division of Subsistence Community Profile Data Base; Personal Comm. David
Holen, ADF&G Oct 25, 2011.
Wild renewable resources are important to the people of this region and many residents rely on
wild fish, game, and plants for food and other products for subsistence use. Total harvest for
these 25 communities is on the order of 2.6 million pounds based largely on surveys undertaken
from the late 1980s through 2008, as summarized in the Alaska Division of Subsistence
community profile data base. A new round of surveys is now underway to update this data.
Estimates for the 2004-2008 study years (Fall et al. 2006; 2008; 2009) are included in the data
presented in Table 1. Additionally, as yet unpublished  data from 2009 for Alegnagik, Clarks
Point and Manokotak are included in the table (Per. Com. David Holen, ADF&G, Oct. 25, 2011).
Per capita harvests average about 343 pounds. Primary  resources harvested include salmon, other
freshwater fish, caribou, and moose. Based on recent surveys, subsistence use continues to be
very important for communities of this region and participation in subsistence activity, including

                                            12

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harvesting, processing, giving and receiving is quite high. Compared to other regions of Alaska,
the Bristol Bay area has many features characteristic of an unique subsistence economy,
including the great time depth of its cultural traditions, its high reliance on fish and game, the
domination of the region's market economy by the commercial salmon fishery, and the extensive
land areas used by the region's population for fishing, hunting, trapping and gathering. (Wright,
Morris, and Schroeder, 1985; Fall, Krieg, and Holen, 2009).
                                                             Pacific
Figure 2.  Bristol Bay Area Location and Major Communities
The primary private source of cash employment for participants in Bristol Bay's mixed cash-
subsistence economy is the commercial salmon fishery. The compressed timing of this fishery's
harvesting activity makes it a good fit with subsistence in the overall Bristol Bay cash-
subsistence economy. Participation in the Bristol Bay salmon fishery is limited to holders of
limited entry permits and their crew.  There are approximately 1,860 drift gillnet permits for
fishing from boats and approximately 1,000 set net permits for fishing from the shore. The
driftnet fishery accounts for about 80% of the harvest.  Most of the harvest is processed by about
ten large processing companies in both land-based and floating processing operations which
employ mostly non-resident seasonal workers.

Many commercial fishing permit holders and crew members, as well as some employees in the
processing sector, are residents of Bristol Bay's dominantly-native Alaskan villages. An
ADF&G summary of subsistence activity in Bristol Bay (Wright, Morris, and Schroeder 1985)
                                           13

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noted that as of the mid-1980's traditional patterns of hunting, fishing, and gathering activities
had for the most part been retained, along with accommodations to participate in the commercial
fishery and other cash-generating activities. In the abstract to this 1985 paper, the authors
characterize the commercial salmon fishery as "a preferred source of cash income because of its
many similarities to traditional hunting and fishing, and because it is a short, intense venture that
causes little disruption in the traditional round of seasonal activities while offering the potential
for earning sufficient income for an entire year." Commercial fishing is a form of self-
employment requiring many of the same skills, and allowing nearly the same freedom of choice
as traditional subsistence hunting and fishing (Wright, Morris, Schroeder 1985; p. 89).
    Brhtol Bay Area Commercial
    Sfihnoii Fhher\' Maiiagemeju Districts

      Alaska Department offish and Game
        J.Hvs?jn 3/ Cvwin frcia! ^^kffrfs
Figure 3.  Bristol Bay Area Commercial Salmon Fishery Management Districts
Commercial Fisheries

The Bristol Bay commercial salmon fishery harvests salmon which spawn in and return to
numerous rivers over a broad area. The Bristol Bay commercial fishery management area
encompasses all coastal and inland waters east of a line from Cape Menshikof to Cape
Newhenham (Figure 3). This area includes eight major river systems: Naknek, Kvichak, Egegik,
Ugashik, Wood, Nushagak, Igushik and Togiak. Collectively these rivers support the largest
commercial sockeye salmon fishery in the world (ADF&G, 2005). This is an interesting and
unique fishery, both because of its scale and significance to the local economy, but also because
it is one of the very few major commercial fisheries in the world that has been managed on a
                                           14

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sustainable basis.  The substantial diversity in this system, both across species and within species
(population diversity or the "portfolio effect"), leads to relatively stable populations. Schindler
(2010) estimated that variability in annual Bristol Bay salmon runs is 2.2 times lower than if the
system consisted of a single population, and that a single homogeneous population of salmon
would lead to 10 times more frequent fisheries closures.  These findings indicate the importance
of maintaining population diversity in order to protect the ecosystem and the economy that
depends on it.

The five species of pacific salmon found in Bristol Bay are the focus of the major commercial
fisheries. Sockeye salmon account for about 94% of the volume of Bristol Bay salmon harvests
and an even greater share of the value. The fishery is organized into five major districts (Figure
3) including Togiak, Nushagak, Naknek-Kvichak, Egegik, and Ugashik. Catches in each district
vary widely from year to year and over longer time periods of time, reflecting wide variation in
returns to river systems within each district. Currently there is particular interest in the
significance of fisheries resources of river systems in the Nushagak and Kvichak districts,
because of potential future resource development in these watersheds.  Over the period 1986-
2010, the Naknek-Kvichak catches ranged from as low as 5% to as high as 52% of total Bristol
Bay catches; Nushagak district catches ranged from as low as 9% to as high as 45% of total
Bristol Bay catches. For most of the past decade, the combined Nushagak and Naknek-Kvichak
districts have accounted for about 60% of the  total Bristol Bay commercial sockeye harvest.1

Management is focused on discrete stocks with harvests directed at terminal areas  at the mouths
of the major river systems (ADF&G, 2005). The stocks are managed to achieve an escapement
goal based on maximum sustained yield. The  returning salmon are closely monitored and
counted and the openings are adjusted on a daily basis to achieve desired escapement. Having the
fisheries near the mouths of the rivers controls the harvest on each  stock, which is  a good
strategy for protection of the discrete stocks and their genetic resources.  The trade-off is that the
fishery is more congested and less orderly, and the harvest is necessarily more of a short pulse
fishery, with most activity in June and early July. This has implications for the economic value
of the fish harvest, both through effects on the timing of supply, but also on the quality of the
fish. Most fish are canned or frozen, rather than sold fresh.  Total catches vary widely from year
to year. Between 1980 and 2010, Bristol Bay  sockeye salmon harvests ranged from as low as 10
million fish to as high as 44 million fish. Harvests can vary widely from year to year and annual
pre-season forecasts are subject to a wide margin of error.

Strong Japanese demand for frozen sockeye salmon drove a sharp rise in Bristol Bay salmon
prices during the 1980s.  Competition from rapidly increasing farmed salmon production drove a
protracted and dramatic decline in prices between  1988 and 2001, which led to an  economic
crisis in the industry. However, growing world salmon demand, a slowing of farmed salmon
production growth, diversification of Bristol Bay salmon products and markets, and
improvements in quality have driven a strong recovery in prices over the past decade. The real
ex-vessel value paid to fishermen fell from $359 million in 1988 to $39 million in  2002, and rose
1  Bristol Bay salmon harvest statistics can be found at
http://www.adfg.alaska.gov/index.cfm7adfg=commercialbyareabristolbay.salmon
                                           15

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to $181 million in 2010 (values in 2010 dollars).   The real first wholesale value of Bristol Bay
salmon production fell from $616 million in 1988 to $124 million in 2002, and then rose to $390
million in 2010. In 2009, the ex-vessel value of Bristol Bay salmon harvest was approximately
$300 million. Many other factors, such as changes in wild salmon harvests, exchange rates,
diseases in Chilean farmed salmon, and global economic conditions have also affected prices. In
general, changes in ex-vessel prices paid to fishermen have reflected changes in first wholesale
prices paid to processors.

There are many potential economic measures of the Bristol Bay salmon industry (Table 2).
Which measure is most useful depends upon the question being asked. For example, if we want
to know how the Bristol Bay salmon fishery compares in scale with other fisheries, we should
look at total harvests or ex-vessel or wholesale value. If we want to know how it affects the
United States balance of payments, we should look at estimated net exports attributable to the
fishery. If we want to know how much employment the industry provides for residents of the
local Bristol Bay region, Alaska or the United States, we should look at estimated employment in
fishing and processing for residents of these regions. If we want to know the net economic value
attributable to the fishery, we should look at estimated profits of Bristol Bay fishermen and
processors.  These different measures (Table 2) vary widely in units, in scale, and in the measure
of how economically "important" the fishery is. For example, for the period 2000-2010, Bristol
Bay harvests were 62% of all Alaska sockeye salmon harvests and 45% of total world production
for the species.
Table 2. Selected Economic Measures of the Bristol Bay Commercial Salmon Industry,
2000-2010.
Measure
Sockeye Salmon Havests
Millions offish
Millions of pounds
Bristol Bay harvest
volume as a share of:
Alaska sockeye salmon
World sockeye salmon
Alaska wild salmon (all species)
World wild salmon (all species)
World wild & farmed salmon
(all species)
Gross Value ($ mllions)
Ex-vessel value
First wholesale value
Total value of US exports of
Bristol Bay salmon products
2000

21
125

61%
45%
18%
7%
3%

80
175
150
2001

14
96

56%
40%
12%
5%
2%

40
115
137
2002

11
65

48%
28%
10%
4%
1%

32
100
97
2003

15
93

50%
38%
13%
5%
2%

48
114
111
2004

26
152

59%
47%
19%
8%
3%

76
176
172
2005

25
155

58%
47%
16%
7%
3%

95
220
193
2006

28
165

69%
49%
22%
8%
3%

109
237
173
2007

30
173

62%
47%
18%
7%
3%

116
249
183
2008

28
160

71%
52%
23%
9%
3%

117
262
206
2009

31
183

71%
55%
25%
7%
3%

144
293
230
2010

29
170

74%





181
390
254
Avg.

23
140

62%
45%
18%
7%
2%

94
212
173
Range

11- 31
65 - 183

48%- 74%
28%- 55%
10%- 25%
4%- 9%
1%- 3%

32 - 181
100 - 390
97 - 254
 The ex-vessel value is the total post-season adjusted price paid to fishermen for the first purchase of commercial
harvest.
                                           16

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Recreation

Next to commercial fishing and processing, recreation is the most important private economic
sector in the Bristol Bay region. This recreational use includes sport fishing, sport hunting, and
other tourism/wildlife viewing recreational trips to the Bristol Bay Region.  The 2005 Bristol
Bay Angler Survey (Duffield et al. 2007) confirmed that the fresh water rivers, streams, and
lakes of the region are a recreational resource equal or superior in quality to other world
renowned sport fisheries.

In survey responses Bristol Bay anglers consistently emphasize the importance of Bristol Bay's
un-crowded, remote, wild setting in their decisions to fish the area. Additionally, a significant
proportion of these anglers specifically traveled to the region to fish the world-class rainbow
trout fisheries. These findings indicate that Bristol Bay sport fishing is a relatively unique
market segment, paralleling the findings of Romberg (1999) and Duffield, Merritt and Neher
(2002) that angler motivation, characteristics, and values vary significantly across Alaska sport
fisheries.

Recreational fishing use of the Bristol Bay region is roughly divided between 58% trips to the
area by Alaska residents and 42% trips by non-residents.  These non-residents (approximately
12,500 trips in 2009 (personal communication, ADF&G, 2011)) account for the large majority of
total recreational fishing spending in the region.  It is estimated that in 2009 approximately $50
million was spent in Alaska by nonresidents specifically for the purpose of fishing in the Bristol
Bay region.  In total, it is estimated that $60  million was spent in Alaska in 2009 on Bristol Bay
fishing trips.

While sport fishing within the Bristol Bay region comprises a large and well-recognized share of
recreational use and associated visitor expenditures, thousands of trips to the region each year are
also made for the primary purpose of sport hunting and wildlife viewing. Lake Clark and Katmai
National Parks are nationally significant protected lands and are important visitor destinations
attracting around 65,000 recreational visitors in 2010 (NFS public visitation statistics).
Additionally, rivers within Katmai NP provide the best locations in North America to view wild
brown bears.
Summary of Economic Significance

Table 3 through 7 detail the summary results of the analysis of economic values. Table 3 shows
estimated direct expenditures in Alaska related to harvest or use of Bristol Bay area renewable
resources. Total estimated direct expenditures (that drive the basic sector of the economy) were
estimated to be $479 million in 2009. The largest component is commercial fishing harvesting
and processing. These estimates were obtained from the Alaska Department of Revenue and the
Commercial Fishing Entry Commission. The next most significant component is wildlife
viewing/tourism  at $104 million in 2009. Sport fishing is estimated to constitute another $60
million in spending. This estimate is derived from the 2005 Bristol Bay Angler survey data as
well as AK F&G use estimates. Sport hunting is less important economically.
                                           17

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The direct economic spending and sales shown in part A of the table supports an estimated
14,200 direct full and part-time jobs in the Bristol Bay region during peak season.
Table 3. Summary of Regional Economic Expenditures Based on Wild Salmon Ecosystem
Services (Million 2009 $)
Ecosystem Service
Estimated direct expenditures / sales per year
(A) Direct Expenditures and Sales
Commercial fish wholesale value3
Sport fisheries
Sport hunting
Wildlife viewing / tourism
Subsistence harvest expenditures
Total direct annual economic impact
300.2
60.5
8.2
104.4
6.3
479.6
(B) Estimated Direct Full & Part-Time Jobs at Peak Season
Commercial fish Sector
Sport fisheries
Sport hunting
Wildlife viewing / tourism
Subsistence harvest expenditures
Total direct annual economic impact
11,572
854
132
1,669
Not Captured by the Market
14,227
Table 4 provides additional detail on recreation expenditures, including number of trips and
spending by residence of the participants. A large share of total recreation expenditures is by
nonresident anglers ($49.8 million) and nonresident non-consumptive (tourism/wildlife viewing)
visitors ($92.9 million). This reflects the high quality of this fishery and other recreational
opportunities in the region, in that the area is able to attract  participants from a considerable
distance in the lower 48 states as well as foreign countries.  Subsistence harvest expenditures are
based on limited data and are likely to be conservative. (Goldsmith, 1998)
3 Estimates of some year-specific commercial fishery total harvest and total sales vary slightly within this report.
This is due to differences in how these data are aggregated and reported by the Alaska Fish and Game, and the point
in time these statistics were accessed during the preparation of this report.
                                             18

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Table 4. Total Estimated Recreational Direct Spending in Alaska Attributable to Bristol
Bay Wild Salmon Ecosystems, 2009
                             Local       Non-local         Non-
                           residents       residents       residents
Visitors
Non-consumptive
Sport fishing
Sport hunting

4,506
13,076 3,827
1,319

36,458
12,464
1,323

40,964
29,367
2,642
  Total                     13,076           9,652           50,245           72,973

Spending per visitor
  Non-consumptive                -         $2,548           $2,548
  Sport fishing                 $373         $1,582           $3,995
  Sport hunting                    -         $1,068           $5,170
Spending (Sniillion)
Non-consumptive
Sport fishing
Sport hunting
Total

-
$4.9
-
$4.9

$11.5
$6.0
$1.4
$18.9

$92.9
$49.8
$6.8
$149.5

$104.4
$60.7
$8.2
$173.3
Table 5 summarizes the full time equivalent employment (annual average) for the cash
component of the economy associated with the major economic sectors of the Bristol Bay
economy, those dependent on wild salmon ecosystems—recreation, commercial fishing, and
subsistence, as well as other major employment sectors. The economy of the Bristol Bay Region
depends on three main activities or sectors—publicly funded services through government and
non-profits, commercial activity associated with the use of natural resources (mainly commercial
fishing and recreation), and subsistence. Subsistence is a non-market activity in the sense that
there is no exchange of money associated with the subsistence harvest. However, local
participants invest a significant portion of their income to participate in subsistence and the
harvest has considerable economic value and their expenditures have significant economic
effects.

Public services and commercial activities bring money into the economy (basic sectors) and
provide the basis for a modest support sector. The support sector (non-basic sector) consists of
local businesses that sell goods  and services to the basic sectors including the commercial fishing
industry, the recreation industry, the government and non-profit sectors. The support sector also
sells goods and services to participants in subsistence activities.

The relative importance within the regional economy of government as contrasted with
commercial fishing and recreation can be measured by the annual average employment in each
sector. In 2009, more than two thousand jobs were directly associated with government spending
from federal,  state, and local sources. Commercial fishing and recreation accounted for

                                           19

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approximately three thousand or 57 percent of total basic sector jobs. Since much of the
recreation is using public lands and resources, a share of the government sector; for example
administration of the federal and state parks and wildlife refuges, is directly related to providing
jobs and opportunities in the recreation sector. Accordingly, the estimate of recreation-dependent
jobs is conservative.

The support sector depends on money coming into the regional economy from outside mainly
through government, commercial fishing, and recreation. The relative dependence of the support
sector on the three main sectors is difficult to measure. One reason for this is that government
employment is stable throughout the year, while employment in commercial fisheries and
recreation vary seasonally. Due to the seasonal stability of government jobs, the payroll spending
of people employed in government is likely to contribute more to the stability of support sector
jobs in the region than their share of basic sector jobs indicates.
Table 5. Cash Economy Full-time Equivalent Employment Count by Place of Work in the
Bristol Bay Region, 2009
                                  Annual
                                 Average
             Summer
              Winter
               Swing
Total jobs count

Basic
  Fish harvesting
  Fish processing
  Recreation
  Government & Health
  Mineral Exploration

Non-basic
  Construction

Trade/Transportation/Leisure
  Finance
  Other wage & salary
  Non-basic self employed

Resident jobs count
6,648

5,490
1,409
1,374
  432
2,039
  197

1,406
   61
  634

  155
  239
  317

4,675
16,386

14,877
 6,909
 4,480
 1,297
 1,712
   450

 1,509
    92
   717

   142
   241
   317

10,351
3,792

2,430

  354

2,056
   70

1,362
   55
  593

  162
  235
  317

3,225
12,594

12,447
 6,909
 4,126
 1,297
 (344)
   380

   147
    37
   124

  (20)
     6
 7,126
Note, estimates based on ISER Input-Output modeling described in section below. Fish harvesting and processing
include other fisheries besides salmon, thus employment numbers cannot be compared with other tables shown in
this report. Summer and winter employment shown, are point estimates that either show the maximum or minimum
job count. Swing refers to the difference between maximum and minimum.
                                           20

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Subsistence users are not the only hunter-gatherers in this economy. Essentially the entire private
economy is "following the game" (or in this case fish), with many commercial fishermen,
processors, sport anglers, sport hunters, and wildlife viewers coming from elsewhere in Alaska
or outside the state to be part of this unique economy at the time that fish and game are available.
The estimated earnings associated with the salmon ecosystem-dependent jobs are shown in Table
6. The total of $283 million was divided among $78 million for residents of the Bristol Bay
region, $104 million to residents of the rest of Alaska, and $100 million to residents of other
states.

Table 6. Cash Economy Estimated Economic Significance of Bristol Bay Ecosystems



Direct jobs
Peak
Commercial fish
Recreation
Subsistence

Annual average
Commercial fish
Recreation
Subsistence

Multiplier Jobs
Total jobs
(annual average)
Direct wages
($000)
Commercial fish
Recreation
Subsistence

Multiplier wages
Total wages

Total
i Ul
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(besides those associated with expenditures for tools, equipment, and supplies in Table 3) can be
approximated through either a top-down or bottom-up estimation approach.

Population levels in Bristol Bay were 7,475 in 2010 (Table 1). Based on 2010 census counts, the
number of Bristol Bay residents aged 16 and over was 5,448.  The cash economy and equivalent
full-time employment of Alaskans in the Bristol Bay region is estimated at 4,675 (Table 5). The
estimated cash economy employment for local Bristol Bay residents only is 2,032 (Table 6).  By
not choosing to move elsewhere, Bristol Bay residents reveal  their preference for the livelihood
presented by the mixed  cash-subsistence economy.  This is supported by the findings in Boraas
and Knott (2011). For example, several local interviewees were quoted as saying "But I
wouldn't trade this place for anything. This is home; this is where I find clean water to drink."
And "We love this  place. Moving is not an option to me."  (Boraas & Knott (2011) p. 3.)

Data in Holen et al. (2011) indicate that for Bristol Bay communities participation in subsistence
activities is very high. In the towns of King Salmon, Naknek and South Naknek 90% or more of
residents reported participation in subsistence harvest activities (p. 20). One estimate of
participation (employment) in the subsistence livelihood (full-time equivalent jobs) would be to
attribute the residual of the adult (16 and over) population less the cash economy jobs  (Table
5)—or around 3,400 jobs to this sector. Therefore, the non-cash economy jobs  associated with
the subsistence sector may be roughly 3,400.

Another approach would be to examine the effort levels (days in subsistence activities) based on
subsistence fishing permit data. Fall et al. (2009) indicates that the harvest levels per day are
actually constrained not by potential daily harvest, but by the  processing capacity of the family
unit (or extended family).

The total number of full-time equivalent jobs directly dependent on the wild salmon ecosystem is
the sum of the cash economy jobs (6,266) plus the subsistence sector livelihoods (roughly
estimated at (3,400 jobs), or about 9,600 jobs.
Net Economic Values

The preceding discussion has focused on a regional economic accounting framework and job and
wage-related measures of economic significance. This section introduces the net economic value
measures for evaluation of the renewable Bristol Bay resources. The framework for this
accounting perspective is the standard federal guidelines for estimating net economic benefits in
a system of national accounts (Principles and Standards, U.S. Water Resources Council 1985).
EPA (2010) is a more recent and complementary set of guidelines.

The Alaskan subsistence harvest is not traditionally valued in the marketplace. Because the
subsistence resources are not sold, no price exists to reveal the value placed on these resources
within the subsistence economy. The prices in external markets, such as Anchorage, are not
really relevant measures  of subsistence harvest value. The supply/demand conditions are unique
to the villages, many of which are quite isolated.  Native preferences for food are strongly held

                                          22

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and often differ from preferences in mainstream society. Additionally, because these are highly
vertically integrated economies, substantial value-added may occur before final consumption
(such as drying, or smoking fish and meats).  In their research on estimating the economic value
of subsistence harvests, Brown and Burch (1992) suggest that these subsistence harvests have
two components of value, a product value, and what they call an "activity value." The product
value is essentially the market value of replacing the raw subsistence harvest.  The activity value
would primarily include the cultural value of participating in a subsistence livelihood. The
activity value component is also associated with the value of engaging in subsistence harvest and
food processing activities.  This activity value would include maintaining cultural traditions
associated with a subsistence livelihood.  Duffield (1997) estimated a hedonic model of
subsistence harvest of 90 Alaskan communities. This model was updated to incorporate current
subsistence harvest data, and education and income data, and estimated a total NEV per pound of
usable subsistence harvest of between $60.24 and $86.06.

Based on an estimated 2.6  million pounds of subsistence harvest per year in the Bristol Bay
region, and valued at an estimated range of $60.24 to $86.06 per pound, this harvest results in  an
estimated net economic value annually of subsistence harvest of between $154.4 and $220.6
million.

The net economic value of commercial fisheries is estimated based on data on salmon fishery
permit sales prices for Bristol Bay. The Commercial Fish Entry Commission reports average
permit transfer prices annually (and monthly) for the Bristol Bay salmon fishery.4  Over the
period from 1991-2011 the average sales price for Bristol Bay drift net permits has been
$149,000 (in 2011  dollars). The average price for set net permits over the same period has been
$42,200. The 95% confidence interval on the mean drift net price for this period is from
$105,500 to $192,700. For the set net permit transfers, the 95% C.I. on the mean sales price was
between $28,700 and $55,700.5 For both types of permits combined, it is estimated that the total
market value of the permits ranges from approximately $225 million  to $414 million.

In order to be comparable to other annual net economic values in this analysis (such as sport
fishing or sport hunting) the net present value of commercial fishing permits, as represented by
the market value, must be converted into an annual value reflecting expected annual permit net
income  The permit total value can be annualized using an appropriate amortization (or discount)
rate. The decision to sell a commercial fishing permit at a given price is an individual (or
private) decision. In deciding on an acceptable sales price, a permit holder considers past profits
from operating the permit,  risk associated with future operation of the permit (both physical and
financial), and many other factors.  All these  considerations weigh on how heavily a permit seller
discounts (reduces) potential future profits from fishing the permit in order to arrive at a lump-
sum value for the permit. Huppert et al. (1996) specifically looked at Alaska commercial salmon
permit operations and sales and estimated the individual discount rate on drift net permit  sales  in
the Bristol Bay and surrounding fisheries. This discount rate was  estimated from both
profitability and permit sales price data. Huppert et al. estimated the  implied discount rate
4 A long time series of monthly and annual permit transfer prices is continuously updated at,
http://www.cfec.state.ak.us/pmtvalue/mnusalm.htm
5 Over the period 1991-2011, a total of 3,246 Bristol Bay drift net salmon permits and 1,867 set net salmon permits
were reported sold by the Commercial Fish Entry Commission.

                                           23

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appropriate for annualizing permit sales prices in this setting at 13.52%.  This estimate was
consistent with previous estimates for the fishery.6 Use of the 13.52% discount rate from
Huppert results in an estimated average annual permit net income associated with Bristol Bay
commercial salmon fishing of between $30.4 million and $55.9 million.

Net income for the processing sector is more difficult to estimate. Relative to the fishing sector,
with ex-vessel value of $181 million in 2010, the processing sector provides an approximately
equal value added of $209 million in 2010 (first wholesale value  of $390 million in 2010 less the
cost of buying fish at the ex-vessel cost of $181 million. (Figure 4) However, information on
profits or net income for this sector are difficult to obtain.  As with permit prices, processor
profits are highly variable year-to-year. The average value added associated with salmon
processing for the Bristol Bay fishery is generally equal to or more than the  ex-vessel value.
Salmon processors in the Bristol Bay fishery have an "oligopsony" market structure, in that a
small number of buyers of raw fish exist in the market.  Additionally, these buyers are largely
"price makers" in that they set the price paid per pound to fishermen each season.  Given the
unique relationship between fisherman that the small number of processors in the Bristol Bay, it
is estimated that processors derive profits (net economic value) equal to that earned by
fishermen. Therefore, for the purposes of this report it is estimated that the NEV for salmon
producers is equal to that for the fishing fleet. Estimation of harvest and processing sector net
income using a second independent set of net income estimates and assumptions supports the
result that a range of annual NEV commercial fisheries estimates from $60.8 to $111.8 million
provides a conservative estimate for this sector.
                          Selected Bristol Bay Salmon Processor Costs, 2001-2009
              300
              250
              200
              150
              100
                                                                   I Other costs
                                                                    and profits
ESCost of labor
 (fish processing
 earnings)
                                                                   I Cost of fish
                                                                    (ex-vessel
                                                                    value)
                                      Source: ADFG, ADLWD
             Figure 4. Selected Bristol Bay Salmon Processor Costs: 2001-2009
6 Huppert, Ellis and Nobel (1996) estimated the real discount rate associated with sales of Alaska drift gill-net
commercial permits of 13.52%. Karpoff (1984) estimated the discount rate from sales of Alaska limited entry
permits at 13.95%.
                                            24

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The sportfish net economic values are angler recreational benefits (consumer surplus) in Duffield
et al. (2007). These estimates are consistent with values from the extensive economic literature
on the value of sportfishing trips (for example Duffield, Merritt and Neher 2002). Sport hunting
values are based on studies conducted in Alaska McCollum and Miller (1994). Direct use values
for all uses total from $237 million to $354 million per year. In addition to recreationist's net
benefits, net income (producer's surplus) is recognized by the recreation and tourism industry.
This is a component that remains to be estimated.
Based on the National Research Council panel on guidelines for valuation of ecosystem services
(NRC 2005), it is important to include intrinsic or passive use values (aka "non-use" values) in
any net economic accounting of benefits (Figure 5).
                                      ECOSYSTiM
  HUMAN ACTIONS
  (PRIVATBPUBLIC)
                                     ECOSYSTEM GOODS
                                         & SERVICES
                                                  L
                             Use vafues |
Pa;;ive Use Value
e y. cuScrcp,
              e g  "nrvwl ng «ralw
                               Direct
                               1 ^ '
                               ;-••>* tr •':-'
Indirect
Figure 5. Flows of Ecosystem Services (adapted from (National Research Council 2005))
                                           25

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A major unknown is the total value related to existence and bequest motivations for passive use
values. Goldsmith et al. (1998) estimated the existence and bequest value for the federal wildlife
refuges in Bristol Bay at $2.3 to $4.6 billion per year (1997 dollars).  There is considerable
uncertainty in these estimates, as indicated by the large range of values. Goldsmith's estimates
for the federal wildlife refuges are based on the economics literature concerning what resident
household populations in various areas (Alberta, Colorado) (Adamowicz et al. 1991; Walsh et al.
1984; Walsh et al. 1985) are willing to pay to protect substantial tracts of wilderness. Similar
literature related to rare and endangered fisheries, including salmon,  could  also be applied here.
It is possible that from a national perspective the Bristol Bay wild salmon ecosystems and the
associated economic and cultural uses are sufficiently unique and important to be valued as
highly as wilderness in other regions of the U.S.. Goldsmith et al.'s (1998)  estimates assume that
a significant share of U.S. households (91 million such households) would  be willing to pay on
the order of $25 to $50 per year to protect the natural environment of the Bristol Bay federal
wildlife refuges.  The number of these households used in Goldsmith's analysis is based on a
willingness to pay study (the specific methodology used was contingent valuation) conducted by
the State of Alaska Trustees in the Exxon Valdez oil spill case (Carson et al. 1992). These
methods are somewhat controversial among economists, but when certain guidelines are
followed, such studies are recommended for use in natural resource damage regulations (for
example, see Ward and Duffield 1992). The findings of the Exxon Valdez study were the basis
for the $1 billion settlement between the State and Exxon in this case. Willingness-to-pay
analyses have also been upheld in court (Ohio v. United States Department of Interior, 880 F.2d
432-474 (D.C. Cir.1989)) and specifically endorsed by a NOAA-appointed blue ribbon panel
(led by several Nobel laureates in economics) (Arrow et al. 1993).

While the primary source of passive use values for Bristol Bay are likely to be with national
households (lower 48), it is important to note that the Alaska natives living in Bristol Bay also
likely have significant passive use values for the wild salmon ecosystem. For example,  Boraas &
Knott (2011) quotes Bristol Bay natives in saying "We want to give to our  children the fish, and
we want to keep  the water clean for them.. .It was a gift to us from our ancestors, which will then
be given to our children.) (Boraas & Knott p. 33).

Goldsmith's estimates for just the federal refuges may be indicative of the range of passive use
values for the unprotected portions of the study area. However, there are several caveats to this
interpretation.  First, Goldsmith et al. estimates are not based on any actual surveys to calculate
the contingent value specific to the resource at issue in Bristol Bay. Rather, they are based on
inferences from other studies, a method referred to as benefits transfer. Second, these other
studies date from the 1980's and early 1990's and the implications of new literature and methods
have not been examined.  Additionally, the assumptions used to make the benefits transfer for
the wildlife refuges may not be appropriate for the larger Bristol Bay study area which includes
not only the wildlife refuge, but also two large national parks. This topic is an area for  future
research.
                                           26

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Table 7. Summary of Bristol Bay Wild Salmon Ecosystem Services, Net Economic Value
per Year (Million 2009 $)
Ecosystem Service
Commercial salmon fishery
Fishing Fleet
Fish Processing
Sport fishing
Sport hunting
Wildlife viewing / tourism
Subsistence harvest and activity
Total Direct Use Value
Low estimate

$30.4
$30.4
$12.2
$1.4
$8.1
$154.4
$236.90
High estimate

$55.9
$55.9
$12.2
$1.4
$8.1
$220.6
$354.10
Table 7 provides a summary of annual net economic values. Since these are values for renewable
resource services that in principle should be available in perpetuity, it is of interest to also
consider their present value (e.g. total discounted value of their use into the foreseeable future).
The controlling guidance document for discounting in cost benefit analysis, OMB Circular A-4
(2003), generally requires use of discount rates of 3% and 7%, but allows for lower, positive
consumption discount rates, perhaps in the 1 percent to 3 percent range, if there are important
intergenerational values. Weitzman (2001), conducted an extensive survey of members of the
American Economic Association, and suggests a declining rate schedule, which may be on the
order of 4 percent (real) in the near term and declining to near zero in the long term. He suggests
a constant rate of 1.75% as an equivalent to his rate schedule. Weitzman's work is  cited both in
the EPA guidance (EPA 2000) and in OMB guidance (Circular A-4 (2003)). Table 8 shows the
estimated net present value in perpetuity of direct use values within the Bristol Bay Ecosystem.
The table shows a range of alternative discount rates from the standard "intragenerational" rates
of 7% and 3% to the more appropriate "intergenerational" rates for the Bristol Bay case of 1.75%
and 1.0%. The entire range of NPV estimates in the table is from $3.4  to $35.4 billion. The range
of estimated direct use NPV of the resource using the more appropriate intergenerational
discount rates is from $13.5 to $35.4 billion.  These estimates are likely quite conservative as
they do not include estimates of passive use values, but are limited to direct economic uses of the
wild salmon ecosystem services.
Table 8. Estimated Net Present Value of Bristol Bay Ecosystem Net Economic Use Values
and Alternative Assumed Perpetual Discount Rates
Estimate

Low Estimate
High Estimate
                                              Net Present Value (million 2009 $)
Annual Value  7% Discount  3% Discount 1.75% Discount    1% Discount
   $236.9
   $354.1
$3,384
$5,059
 $7,897
$11,803
$13,537
$20,234
$23,690
$35,410
                                           27

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1.0 Introduction and Setting
This report provides information on the importance of wild fisheries and the natural environment
in the Bristol Bay region to the economies of the Bristol Bay region, the State of Alaska and the
U.S. as a whole.
1.1 Study Objectives and Report Organization

The primary purpose of this report is to estimate baseline levels of economic activity and values
associated with the current Bristol Bay Region wild salmon resource.  This comprehensive report
includes and synthesizes individual reports on separate components of economic activity and
values linked to the Bristol Bay Ecosystem. Economic activity linked to Bristol Bay includes
sportfishing, subsistence harvest, sport hunting, and commercial  fishing. Additionally, an
analysis of the structure of the Bristol Bay economy and the significance of these ecosystem-
related economic activities to the economy is presented.

This report on the baseline levels of economic activities (as of 2009) within the Bristol Bay
Ecosystem is organized as follows:

Section 1: Introduction and Setting
Section 2: Baseline Recreation and Subsistence Economics
Section 3: Baseline Commercial Fisheries Activity
Section 4: Economic Significance Analysis (Schworer et al.)
Section 5: Baseline Net Economic Values

The major components of the total value of the Bristol Bay area wild salmon ecosystems include
subsistence use, commercial fishing and processing, sportfishing, and the preservation values (or
indirect values) held by users and the U.S. resident population. The overall objectives of this
work are to estimate the share of the total regional economy (expenditures, income and jobs) that
is dependent on these essentially pristine wild salmon ecosystems, and to provide a preliminary
but relatively comprehensive estimate of the total economic value associated with the ecosystem.

It is important to note that while the geographic scope of this economic characterization report is
targeted to the Bristol Bay wild salmon ecosystem, the scope of the proposed mining activity is
somewhat narrower, including the Nushugak and Kvichak drainages.  Values tied to, and specific
to, the proposed mining activity (and discharges) in the Nushugk and Kvichak Drainages would
be a subset of those reported here, and have not been identified in this general characterization
analysis.

This report used existing information and data to target this economic characterization report to
ecosystem services and associated economic activity and values, specific to the Bristol Bay
Region. However, data on different economic sectors vary in quality, and available data on some

                                          28

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economic activities (such as non-consumptive tourism) make it more difficult to identify
activities and associated economic values narrowly targeted to the Bristol Bay area. The overall
intent of this report is to provide a general picture of the full range of economic values associated
with ecosystem services supplied by the entire Bristol Bay region.
1.2 Definition of Study Area

The Bristol Bay region is located in southwestern Alaska. The region, which includes Bristol
Bay Borough, the Dillingham Census Area, and a large portion of Lake and Peninsula Borough,
contains a relatively small number of communities, the largest of which are shown in Figure 6.
The area is very sparsely populated and the large majority of its population is comprised of
Alaskan Natives (Table 9). Although median household income varies among census areas
within the region, outside of the relatively small Bristol Bay Borough, income is somewhat lower
than for the state of Alaska as a whole.  As noted, Alaskan Natives make up over two-thirds of
the total population within the region as compared to approximately 15% for the entire state
(Table 9)

Table 9. Demographic and Socioeconomic Characteristics of the Bristol Bay Region
Area


Bristol Bay Borough
Dillingham Census Area
Lake & Peninsula Borough
Total Bristol Bay Region
State of Alaska
Population
2010

997
4,847
1,631
7,745
710,231
Percent
Alaska
Native
48.2%
80.4%
74.6%
73.8%
14.8%
Percent 18
or over

77.4%
67.1%
69.8%
66.7%
73.6%
Number of
households

423
1,563
553
2,539
234,779
Median household
income 2009

$ 64,418
$ 46,580
$ 42,234
$ 48,010
$ 66,712
Source: US Census Quickfacts.  Quickfacts.census.gov
                                          29

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Table 10. Bristol Bay Area Communities and Populations
Bristol Bay Area Community
Aleknagik
Clark's Point
Dillingham
Egegik
Ekwok
Igiugig
Iliamna
King Salmon
Kokhanok
Koliganek
Levelock
Manokotak
Naknek
New Stuyahok
Newhalen
Nondalton
Pedro Bay
Pilot Point
Port Alsworth
Port Heiden
South Naknek
Ugashik
Togiak City
Portage Creek
Twin Hills
 Population
(2010 census)
    219
    62
   2,329
    109
    115
    50
    109
    374
    170
    209
    69
    442
    544
    510
    190
    164
    42
    68
    159
    102
    79
    12
    817
     2
    74
                                                                    Pacific Ocean
Figure 6. Bristol Bay Area Location and Major Communities
                                               30

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This study focuses on the economic contributions of the Bristol Bay ecosystem. The rivers that
flow into the Bristol Bay comprise some of the last great wild salmon ecosystems in North
America (Figure 7).  All five species of Pacific salmon are abundant, and the rich salmon-based
ecology also supports many other fish species, including healthy populations of rainbow trout.
The Naknek, Nushagak-Mulchatna, and Kvichak-Lake Iliamna watersheds are relatively pristine
with very little reading or extractive resource development. The existing mainstays of the
economy in this region are  all wilderness-compatible and sustainable in the long run: subsistence
use, commercial fishing, and  wilderness sportfishing.  Commercial fishing largely takes place in
the salt water outside of the rivers themselves and is closely managed for sustainability. The
subsistence and sportfish sectors are relatively low impact; primarily personal use and catch and
release fishing, respectively. Additionally, there are important public lands in the headwaters,
including Lake Clark National Park and Preserve, Katmai National Park and Preserve, and
Togiak National Wildlife Refuge.

The Bristol Bay area includes the political designations of Bristol Bay Borough, the Dillingham
census area, and most of Lake and Peninsula Borough. The largest town in the area is
Dillingham. In 2010 the Dillingham census area had an estimated population of 4,847 (US
Census, Quick Facts).
                                           31

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                                                   Nushagak
                                                        Kvichah
Figure 7. Map of Bristol Bay Study Area
1.3 Focus of Study-Economic Uses

As noted, this report focuses on estimating baseline levels of ecosystem services provided by the
Bristol Bay Region. These services are broad and substantial and include, but are not limited to
commercial, aesthetic, recreational, cultural, natural history, wildlife and bird life, and ecosystem
services.

A primary dichotomy of economic value is the division of values into those that are, or can be
traded within existing economic markets, and those for which no developed market exists.
Examples of ecosystem services specific to the Bristol Bay  region that are traded in markets  are
commercial fish harvests and guided fishing trips.  While a  number of services provided by
Bristol Bay natural resources can be classified as market services (with associated market-
derived values), there are many services provided by this area that are classified as non-market
services. These non-market resource services include noncommercial fishing, wildlife watching,
subsistence harvests, protection of cultural sites, and aesthetic services.

A second dichotomy of resource services and associated values is that of direct use and passive
use services and values.  The most obvious type, direct use  services, relates to direct onsite uses.
The second type of resource  services are so-called passive use services. These services have
values that derive from a given resource and are not dependent on direct on-site use. Several
types of passive use values were first described by Weisbrod (1964) and Krutilla (1967), and
                                           32

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include existence and bequest values. Existence values can derive from merely knowing that a
given natural environment or population exists in a viable condition. For example, if there were
a proposal to significantly alter the Bristol Bay natural ecosystem, many individuals could
experience a real loss, even though they may have no expectation of ever personally visiting the
area.  Bequest values are associated with the value derived from preserving a given natural
environment or population for future generations. While use values may or may not have
associated developed markets for them, passive use services are exclusively non-market services.

When passive use and use values are estimated together, the estimate is referred to as total
valuation. This concept was first introduced by Randall and Stoll (1983) and has been further
developed by Hoehn and Randall (1989).

The National Research Council in their 2005 publication "Valuing Ecosystem Services:  Toward
Better Environmental Decision Making" provided an outline of ecosystem services. Table 11
provides an application of the NRC outline to Bristol Bay resources, and details examples of the
ecosystem services, both use and passive use, that are produced by natural resources such as
those found in the Bristol Bay region.
Table 11: Types of Ecosystem Services
                        Use Values
                             Nonuse Values
Direct



Commercial and recreational
fishing

Aquaculture

Transportation

Wild resources

Potable water

Recreation

Genetic material

Scientific and educational
opportunities	
Indirect



Nutrient retention and cycling

Flood control

Storm protection

Habitat function

Shoreline and river bank
stabilization
Existence and Bequest
Values
Cultural heritage

Resources for future
generations

Existence of charismatic
species

Existence of wild places
A comprehensive economic evaluation of these Bristol Bay wild salmon ecosystems needs to
include two distinct accounting frameworks. One is regional economics or economic
significance, focused on identifying cash expenditures that drive income and job levels in the
regional economy. The other is a net economic value framework that includes all potential costs
                                           33

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and benefits from a broader social perspective. The latter necessarily includes non-market and
indirect benefits, such as the benefits anglers derive from their recreational activity, over and
above their actual expenditure. Both perspectives are important for policy discussions and
generally both accounting frameworks are utilized in evaluating public decisions.
                                            34

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2.0 Bristol Bay Recreation and Subsistence Economics

Section 2 of this report addresses the regional economic activity associated with the recreation
and subsistence sectors.  Primary recreational activities examined include sportfishing, sport
hunting, and tourism/wildlife viewing.
2.1 Bristol Bay Sportfishing Economics

Sportfishing is a consistently economically significant economic activity in the Bristol Bay
Region. Information sources for this section are the Duffield et al. (2007) report on Bristol Bay
Salmon Ecosystem economics (referred to hereafter as the 2005 Bristol Bay Study), and Alaska
Department of Fish and Game estimates of the total populations of anglers fishing the Bristol
Bay Area waters, (pers. Comm. G. Jennings, August 2011)

The sport angler and trip characteristics, expenditures, and values are presented using several
sub-sample breakouts. Comparisons of sub-samples are presented to highlight similarities as
well as differences between sample groups.  Primary sub-samples examined include non-resident
anglers, non-local Alaska resident anglers, and Bristol Bay resident anglers.

The 2005 Bristol Bay study examined angler responses  to a wide range of questions on their
opinions, preferences, and experiences relating to fishing in the Bristol Bay area.  The following
sportfishing results focus on key characteristics of Bristol Bay sportfishing. Estimates of angler
spending and net economic values have been adjusted from the original 2005 dollars to 2009
dollars using the Consumer Price Index-Urban (CPI-U).
2.1.1 Bristol Bay Area Trip Characteristics and Angler Attitudes

The 2005 Bristol Bay Study reported several differences between how nonresident anglers and
Alaska anglers access Bristol Bay fisheries and the types of accommodations they use when
there. For non-resident anglers the most common trip included staying at a remote lodge and
flying or boating with a guide (35.2%). Resident anglers accessed the Bristol Bay area with their
own plane or boat (49.9%), driving to area by motor vehicle (11.3%), and "other" type of trips
(24%). Those who reported driving to access Bristol Bay fisheries were primarily residents and
nonresidents staying in the King Salmon and Dillingham area, where a few local roads exist and
provide some access to nearby fisheries.
                                         35

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Table 12. Bristol Bay Angler Distribution across Trip Types, by Residency
Trip Type
Stayed at a remote lodge and flew or boated with a guide to fishing
Stayed at a tent or cabin camp and fished waters accessible from camp
Hired other lodging in an area community and either fished on own or
contracted for travel on a daily basis
Floated a section of river with a guided party
Hired a drop-off service and fished and camped on our own
Accessed the area with my own airplane or boat
Drove to the area by motor vehicle
Other
Sample Size
Non-residents
(%)
35.2
23.7
6.4

3.9
4.3
8.3
4.3
14.0
246
Alaska
Residents (%)
-
7.8
4.2

2.8
2.2
49.9
11.3
24.0
55
Note: sample size for resident sample is not large enough to divide into local and non-local sub-samples

Other
Drove to area
Accessed area with own
boat or plane
Hired float, drop off, or
other lodging
Stayed at a tent or cabin
camp
Stayed at a remote
lodge



M


|H°/{
	 1 4%


1 24%
4%




[8


%
3%
I
1 8°
'o

0%
15%

1 24%





1 35%

0.00% 10.00%



50%

20.00% 30.00% 40.00% 50.00% 60.00%
Percent of respondents
D Nonresidents • Residents


Figure 8. Comparison of Resident and Nonresident Bristol Bay Angler Trip Types
Respondents to the 2005 Bristol Bay survey were asked what was the primary purpose of their
trip to the Bristol Bay area. A majority of nonresidents (73%) reported fishing as their major
purpose; 30% of resident anglers reported fishing as the main purpose of their most recent
Bristol Bay trip. Table 13  also shows that a much larger proportion of non-residents (45%) than
residents (11.4%) were on  their first trip to their primary fishing destination.

                                           36

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Table 13: Bristol Bay Angler Trip Characteristics.
Statistic
Major purpose of trip
was for fishing
Trip was first trip to
primary destination
Nonresidents
(sample size)
72.7%
(246)
45.2%
(245)
Alaska Residents
29.5%
(54)
1 1 .4%
(48)
Survey respondents in the 2005 study were asked what fish species they targeted on their most
recent trip to Bristol Bay. Table 14 reports these results.  Overall, king salmon and rainbow trout
were the most frequently targeted species for both residents and non-residents.

Table 14: Bristol Bay Angler Survey, Targeted Species.

Primary species targeted on
trip / statistic
Rainbow Trout
King Salmon
Silver Salmon
Sockeye Salmon
Other Species
Sample size
Bristol Bay Anglers
Nonresidents
30.6%
35.2%
16.3%
9.1%
8.8%
235
Alaska Residents
31.3%
29.8%
16.5%
0%
22.4%
48
Respondents to the 2005 Bristol Bay angler survey were presented with a series of statements
regarding fishing conditions on their Bristol Bay area trip. They were asked to indicate their
level of agreement or disagreement with each statement.  Table 15 shows the percent of residents
and non-residents who either "agreed" or "strongly agreed" with each statement. Across all of
the statements presented in the survey, majorities of both resident and non-resident respondents
agreed with the positive statements about their fishing experience. The highest levels of
agreement for both nonresidents and Alaska resident anglers were with the statements "there was
a reasonable opportunity to  catch fish", "there was minimal conflict with other anglers", and
"fishing was in a wilderness setting."
                                           37

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Table 15: Bristol Bay Angler Rating of Selected Attributes of Fishing Trip
Statement
Fishing conditions were un-crowded
There was a reasonable opportunity to catch fish
There was minimal conflict with other anglers
Fishing was in a wilderness setting
There was opportunity to catch trophy-sized fish
There was opportunity to catch and release large # of fish
Sample Size
% of respondents who either
"agree" or "strongly agree"
Nonresidents Alaska Residents
87.2% 75.4%
96.5% 93.0%
93.3% 90.7%
92.4% 95.0%
81 .4% 70.0%
87.3% 76.6%
235 47
2.1.2 Bristol Bay Angler Expenditures

Respondents to the 2005 Bristol Bay angler survey were asked a series of questions relating to
the amount of money they spent on their fishing trips. Average spending per trip was estimated
for three types of anglers: local Bristol Bay Area residents, Alaska residents from outside the
Bristol Bay region, and nonresidents.  Adjusted to 2009 price levels, nonresidents reported
spending the most for their sportfishing trips to Bristol Bay ($3,995). Alaska resident anglers,
those from outside Bristol Bay spent an average of $1,582 per trip and those living within the
Bristol Bay region reported spending an average of $373 per sportfishing trip.

Table 16 breaks out average expenditures by impact region and type of fishing trip for the
nonresident angler sample. Where money is spent on a trip determines local economic impacts.
For instance, a given amount of money spent within the very small Bristol Bay economy has a
much greater relative impact than the same amount of money spent in a larger economy, such as
Anchorage. Table 16 shows that the largest per-trip spending is made by nonresident anglers
who  stay at a remote lodge with daily guiding services ($6,950/trip). This compares to the
lowest spending levels  per trip of about $1,400 for driving to the fishing site, accessing the area
with  own plane or boat, and hiring a drop-off service and fishing or camping on own.

The first two rows of Table 16 show that a large portion of Alaska trip costs for remote lodge or
tent or cabin camp trips is associated with  the cost of a sport-fishing package or tour.  This sport-
fishing package spending is assumed to be spent in the Bristol Bay region.
                                          38

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Table 16. Nonresident Trips to Bristol Bay Waters, Mean Expenditure Per Trip Estimates
By Trip Type
Trip type
Stayed at a remote lodge and flew or boated with a
guide to fishing sites most days
Stayed at a tent or cabin camp and fished waters
accessible from this base camp
Hired other lodging in an area community and either
fished on own or contracted for travel on a daily
basis
Floated a section of river with a guided party
Hired a drop-off service and fished and camped on
our own
Accessed the area with my own airplane or boat
Drove to the area by motor vehicle
Other
Total Reported
Trip Spending

$6,950

$4,158


$2,643
$2,187

$1,515
$1,437
$1,453
$2,233
Bristol Bay
spending11

$1,900

$1,357


$1,818


$1,145
$1,291
$1,062
$1,047
Package sport-
fishing trip
spending

$6,089

$3,517


$2,576





$2,422
a all spending in Bristol Bay except package sportfishing trip expenditures (package trip expenditures are also assumed spent in
the Bristol Bay Region)
Note: cells with less than 5 observations are left blank. Category values are the average values for those respondents reporting an
expense in that category. Bristol Bay spending and Package sport-fishing tour spending will not necessarily sum to Total spending
due to varying sample sizes.	
Table 17 details the distribution of Bristol Bay trip spending across expenditure categories. For
non-residents visitors, the largest three spending categories within the Bristol Bay area were for
commercial and air taxi service and for lodging or camping fees (totaling about 66% of all
spending in Bristol Bay).  For non-local Alaska residents the three largest categories of spending
were "gas and other Alaska travel costs," camping fees, and commercial air travel (totaling about
58% of all Bristol Bay spending by non-local Alaska residents).
Table 17: Distribution of Trip Expenditures across Spending Categories, by Residency and
Area

Expenditure category
Commercial air travel
Air taxi service
Transportation by boat
Boat or vehicle rental
Gas or other travel costs in AK
Lodging or camping fees
food or beverages
Guide fees
Fishing supplies
Other non-fish package tours
Other
Nonresidents
In Bristol Bay
31.1%
20.5%
0.0%
5.3%
4.1%
13.9%
9.2%
6.2%
4.1%
0.1%
5.4%
In rest of AK
51 .9%
1.3%
0.0%
4.8%
1 .4%
1 1 .9%
19.3%
0.6%
5.2%
0.7%
2.9%
non-local AK
residents
In Bristol Bay
18.1%
11.1%
0.0%
7.5%
16.3%
23.6%
16.7%
0.0%
6.7%
0.0%
0.0%
                                              39

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2.1.3 Aggregate Direct Sport fishing Expenditures in Bristol Bay

In order to derive estimated aggregate angler expenditures related to sportfishing in the Bristol
Bay region, two primary pieces of information were needed: 1) the number of angler trips per
year to the region by Alaska residents and nonresidents, and 2) the  average spending per trip by
resident and nonresident anglers.  A trip is defined here as a roundtrip visit from home, and
return. Estimates of the number of anglers who fished in the Bristol Bay region in 2009 were
derived by ADF&G staff (Table 18). The average number of trips per angler, estimated from
responses to the 2005 Bristol Bay angler survey, is also shown in Table 18.  In total
approximately 29,000 sport fishing trips were taken in 2009 to Bristol Bay freshwater fisheries.
These trips are roughly split between 12,000 nonresident trips, 13,000 Bristol Bay resident trips,
and 4,000 trips by Alaskans living outside of the Bristol Bay area.
Table 18. Estimated 2009 Bristol Bay area angler trips, by Angler Residency
Statistic
Annual Anglers
fishing Bristol Bay
waters
Average trips per
angler for 2005
Estimated total
trips
Nonresidents Out-of-area AK
residents
9,572 2,561

1.30 1.49
12,464 3,827

BB Residents
1,133

11.54
13,076

Table 19 presents the aggregation of total angler expenditures within the Bristol Bay region.
This table shows average and aggregate estimated expenditures for three angler groups: 1)
nonresident anglers, 2) local-area resident anglers (those who live in the Bristol Bay area), and 3)
non-local resident anglers (those Alaska residents living outside of the Bristol Bay region). This
table also shows average and total annual spending by nonresident anglers for package
sportfishing trips in the Bristol Bay region.

Overall, the large majority of angler spending in the region is attributable to nonresident anglers.
Additionally, the majority of nonresident spending is due to the purchase of sportfishing
packages such as accommodation and angling at one of the areas remote fishing lodges.
Estimates of variability were derived for average expenditure levels, and total visitation
estimates. It is estimated that annually Bristol Bay anglers spend approximately $58 million
within the Bristol Bay economy. Given the variability in the components of this estimate, the
95% confidence interval  for Bristol Bay area spending by anglers from outside the area ranges
from $0 to $130 million annually.  The vast majority of this spending (approximately $47 million
annually) is spent by nonresident anglers.

                                           40

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Table 19. Estimated Aggregate Spending Associated with Sportfishing in the Bristol Bay
Region (2009 dollars)


Mean expenditures in Bristol
Bay region
Estimated trips
Total Bristol Bay direct
expenditures
Nonresidents
All Non Residents
$ 1,471
12,464
$ 18,333,187
Remote Lodge
Increment
$4,698
6,187
$ 29,068,303
out-of-area AK
residents

$ 1,582
3,827
$ 6,053,700
BB Residents

$ 373
13,076
$ 4,874,848
Total

29,367
$ 58,330,039
Table 20 presents total estimated direct angler expenditures by residency, and location of
spending. Again, among all direct spending related to Bristol Bay angling, the large majority is
associated with nonresidents traveling to Alaska. Additionally, the large majority of this
spending is reported to have occurred within the Bristol Bay economy. This table categorizes
spending by origin and destination. This classification is then used in the regional economic
significance analysis presented in Section 4.
Table 20. Bristol Bay Sportfishing: Aggregate in and out of Region and State Spending
(2009)
Population

NONRESIDENT Base trip spending
NONRESIDENT Sportfish package
spending
NONRESIDENT TOTAL
RESIDENTS
OUT-OF-BB RESIDENT base trip
spending
BB RESIDENT base trip spending
ALASKA RESIDENT TOTAL
TOTAL
In Bristol Bay Spending
Total spending in
Bristol Bay
$ 18,333,187
$ 29,068,303
$ 47,401,490

$ 6,053,700
$ 4,874,848
$ 10,928,549
S 58,330,039
Total spending
from outside
Bristol Bay
$ 18,333,187
$ 29,068,303
$ 47,401,490

$ 6,053,700
$
$ 6,053,700
S 53,455,190
In Alaska Spending
Total in- state
spending
$ 20,727,318
$ 29,068,303
$ 49,795,621

$ 6,053,700
$ 4,874,848
$ 10,928,549
S 60,724,170

Spending from
outside Alaska
$ 20,727,318
$ 29,068,303
$ 49,795,621

$
$
$
S 49,795,621
                                           41

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2.2 Bristol  Bay Subsistence  Harvest  Economics

The subsistence harvest within the Bristol Bay region generates regional economic impacts when
Alaskan households spend money on subsistence-related supplies. Goldsmith (1998) estimated
that Alaskan Native households that use Bristol Bay wildlife refuges for subsistence harvesting
spend an average of $2,300 per year on subsistence-related equipment to aid in their harvesting
activities. Additionally, Goldsmith estimated that Non-Native households spend $600 annually
for this purpose.  Correcting for inflation from 1998 to 2009 implies annual spending for
subsistence harvest of about $3,054 for Native households and $796 for Non-Native
households.7

Figure 9 shows the general distribution of subsistence harvest by Bristol Bay residents. Overall,
salmon make up  the largest share of all harvest (on a basis of usable pounds), and accounts for
over one-half of  all harvest. Another nearly  one third of harvest come from land mammals
(31%), and non-salmon fish comprise another  10% of harvest.
                      Salmon
                       52%
                                                                     Land Mammals
                                                                         31%
                                                 Y
                                                  \
Non-Salmon Fish^/    \
    10%      Birds and Eggs
                  2%
                       Vegetation   v-
                          3%
Marine Invertebrates
      0%
                                                   \  Marine Mammals
                                                          2%
Figure 9. Distribution of Bristol Bay Subsistence Harvest
7 A 1998-99 survey of the village of Atyqasuk (North Slope Borough) found that 3 3% of households spent between
$4,000 and $10,000 on subsistence activities and 9% spent more than $10,000 per year (US DOI, BLM and MMS
2005). The simple parametric mean for this inland community that harvested no whales was $3,740 per year per
household (1999 dollars). The use of the adjusted Goldsmith estimates therefore likely provides a conservative
estimate of subsistence expenditures.
                                           42

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Table 21 shows average per capita and total estimated community subsistence harvest for the
Bristol Bay communities.  In total, individuals in these Bristol Bay communities harvest about
2.6 million pounds of subsistence harvest per year for an average of 343 pounds per person
annually. Table 22 and Table 23 detail Bristol Bay area subsistence harvest by salmon species
and location.
Table 21. ADF&G Division of Subsistence Average Per Capita Subsistence Harvest for
Bristol Bay Communities
Bristol Bay Area Community /year
of AKF&G harvest data survey



Aleknagik 2008
Clark's Point 2008
Dillingham 1984
Egegik 1984
Ekwok 1987
Igiugig 2005
Iliamna 2004
King Salmon 2008
Kokhanok 2005
Koliganek 2005
Levelock 2005
Manokotak 2008
Naknek 2008
New Stuyahok 2005
Newhalen 2004
Nondalton 2004
Pedro Bay 2004
Pilot Point 1987
Port Alsworth 2004
Port Heiden 1987
South Naknek 2008
Ugashik 1987
Togiak City 2000
Twin Hills 2000
Total surveyed communities
Un-surveyed communities
Total including un-surveyed areas
Population
(2010 census)



219
62
2,329
109
115
50
109
374
170
209
69
442
544
510
190
164
42
68
159
102
79
12
817
74
7,018
457
7,475
Per Capita Harvest
(raw pounds of
harvest)(AKF&G
Subsistence
Surveys)
296
1210
242
384
797
542
469
313
680
899
527
298
264
389
692
358
306
384
133
408
268
814
246
499


343
Total Annual
Harvest



64,824
75,020
563,618
41,856
91,655
27,100
51,121
117,062
115,600
187,891
36,363
131,716
143,616
198,390
131,480
58,712
12,852
26,112
21,147
41,616
21,172
9,768
200,982
36,926

-
2,563,313
                                          43

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Table 22. Historical Subsistence Salmon Harvest for Bristol Bay, Alaska: 1975-2007
(ADF&G Division of Subsistence ASFDB)
Year
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
Average
Permits
686
716
738
773
829
1,243
1,112
806
829
882
1,015
930
996
938
955
1,042
1,194
1,203
1,206
1,193
1,119
1,110
1,166
1,234
1,219
1,219
1,226
1,093
1,182
1,100
1,076
1,050
1,063
1,035
Number of Fish Harvested
Chinook
8,600
8,400
7,000
8,100
10,300
14,100
13,000
13,700
13,268
11,537
9,737
14,893
14,424
11,848
9,678
13,462
15,245
16,425
20,527
18,873
15,921
18,072
19,074
15,621
13,009
11,547
14,412
12,936
21,231
18,012
15,212
12,617
15,444
13,825
Sockeye
175,400
120,900
127,900
127,600
116,500
168,600
132,100
110,800
143,639
168,803
142,755
129,487
135,782
125,556
125,243
128,343
137,837
133,605
134,050
120,782
107,717
107,737
118,250
113,289
122,281
92,050
92,041
81,088
95,690
93,819
98,511
95,201
99,549
121,906
Coho
8,500
3,500
6,600
4,400
7,300
7,300
12,200
11,500
7,477
16,035
8,122
11,005
8,854
7,333
12,069
8,389
14,024
10,722
8,915
9,279
7,423
7,519
6,196
8,126
6,143
7,991
8,406
6,565
7,816
6,667
7,889
5,697
4,880
8,329
Chum
7,500
9,100
9,100
16,200
7,700
13,100
11,500
12,400
11,646
13,009
5,776
11,268
8,161
9,575
7,283
9,224
6,574
10,661
6,539
6,144
4,566
5,813
2,962
3,869
3,653
4,637
4,158
6,658
5,868
5,141
6,102
5,321
3,991
7,733
Pink
1,300
4,400
300
12,700
500
10,000
2,600
8,600
1,073
8,228
825
7,458
673
7,341
801
4,455
572
5,325
1,051
2,708
691
2,434
674
2,424
420
2,599
839
2,341
1,062
3,225
1,098
2,726
815
3,099
Total
192,700
137,900
143,900
160,900
132,000
199,000
158,400
143,300
177,104
217,612
167,215
174,112
167,894
161,652
155,074
163,874
174,251
176,739
171,082
157,787
136,319
141,575
147,156
143,330
145,506
118,824
119,856
109,587
131,667
126,865
128,812
121,564
124,679
152,371
Harvest
per permit
280.9
192.6
195
208.2
159.2
160.1
142.4
177.8
213.6
246.7
164.7
187.2
168.6
172.3
162.4
157.3
145.9
146.9
141.9
132.3
121.8
127.5
126.2
116.2
119.4
97.5
97.8
100.3
111.4
115.3
119.7
115.8
117.3
153
                                       44

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Table 23. Bristol Bay Subsistence Salmon Harvests by District and Location Fished, 2007.
(Fall et al. 2009)
Area and river syscem
>~aJmek- Kiiehak District
Nakiiek River subdistric:
Kvichak River- Eiarma Lake
subdistrict:
Chekok
Igiugie
Hiamnsi Lake-general
Kijik
Kokbauok
Kvichafc River
Lake Clark
Levelock
Kewhalen River
Pedro Bay
Sixmile Lake
Egegik District
Ugashik District
Nushagak District
Wood River
Nushagak River
Nushagak Bay
noncommercial
Nushagak Bay commercial
Igu-ihtk-'Suake River
Niiahagak. sice unspecified
Togiak District
Total
Number of
permits
issued*
4SO
287
196

1
4
31
4
30
12
34
1
39
20
26
28
17
496
135
117
228

33
25
1
48
LOO
Estimated salmon harvest
Chinook
612
664
8

0
1
0
0
6
0
0
1
0
0
0
165
43
13,330
1.793
5,479
5.138

418
500
1
1,234
15,444
Sock eye
69,837
22.364
47,473

3m
1,419
5,017
769
15,540
1,203
3,604
102
8,732
5,569
5,208
980
1,056
25,127
6,813
5.879
9,545

887
2,000
3
2,548
99,549
Coho
L104
1.078
26

0
0
0
0
26
0
0
0
0
0
0
334
281
3.050
293
1.127
1,467

113
36
15
110
4,880
Chum
•405
375
30

*0
i
0
0
~>1
0
0
6
0
0
0
-71
ss
3.006
249
1,572
1:009

119
'^I ~
0
420
3,991
Pink
262
260
1

0
0
0
0
1
0
0
0
0
0
0
26
ig
430
36
213
163

1.2
6
0
19
815
Total
72.210
24.742
47.538

310
1.422
5.017
769
15.595
1.203
3.604
109
S.732
5.569
5.208
1.577
1.546
44.944
5.184
14.270
17.322

1.550
2.599
19
4.332
124,679
   Note: Harvests are extrapolated for all permite issued, based oa taose returned and os da area fished as reported 02
     tbe penuit. Due to rounding, the sum of columns and rows may not equal tba estimated total O£ 1.063 permits
     issued for the management am. 917 ware returned (&6.3?-b).
   a. Sum of sites may exceed district totals,  and ami of districts may exceed area total, because permittees may use
     more than oaa s:te.
   Source  ADF&G Division -of Subsistence ASEDB.
                                                 45

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In 2010 the US Census reported an estimated 1,873 Native and 666 non-native households in the
Bristol Bay Region (Bristol Bay Borough, Lake and Peninsula Borough, and Dillingham). Based
on the Goldsmith (1998) estimate of direct expenditures related to subsistence harvest, this
implies an annual direct subsistence-related expenditure of approximately $6.3 million in the
Bristol Bay region.
Table 24. Estimated Total Annual Bristol Bay Area Subsistence-Related Expenditures
(2009 $)
Area
Bristol Bay Borough
Dillingham Census Area
Lake & Peninsula Borough
Total Bristol Bay Region
Annual Spending/ household
Total Estimated
Subsistence Spending
Total
Population
2010
997
4847
1631
7,475

Percent Alaska
native
48.2%
74.6%
80.4%
73.8%

Number of
households
423
553
1563
2539

Number of
Native
Households
204
413
1257
1873
$ 3,054
$ 5,720,054
Number of
non-native
Households
219
140
306
666
$ 796
$ 530,350
$ 6,250,404
2.3 Bristol  Bay Sport Hunting and Non-consumptive
Economics
2.3.1 Sport Hunting

In addition to sport fishing, sport hunting also plays a significant (but smaller) role in the local
economy of the Bristol Bay region. While not a large share of the economy, sport hunting in the
Bristol Bay area offers high quality hunting opportunities for highly valued species.  Bristol Bay
sport hunting provides hunting opportunities for caribou, moose, and brown bear, among other
species.  Table 25 shows reported hunter numbers for the most recently reported representative
years for several species hunted in the region.  The big game hunting numbers are reported for
the two Game Management Units (GMUs) that comprise the Bristol Bay Region. GMUs are
spatial areas delineated by AKF&G to more closely correspond to wildlife habitat and population
ranges than do other geographical or political boundaries.
                                        46

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Table 25. ADF&G Reported Big Game Hunting in Bristol Bay and Alaska Peninsula Game
Management Units
Most recent Big
(Number of nun
Moose
Caribou
Brown bear
The caribou estii
Shaded cells
Sources: AKDF&C
Game Hunting Estimates from ADF&G Wildlife Management Reports
ters)
Alaska Peninsula
(GMU 9)
Non-local
Residents
91
0
600
691
Nonreside
nts
157
0
624
781
Bristol Bay
(GMU 17)
Non-local
Residents Nonresidents
200 195
311 230
117 117
628 542
nate for GMU 17 is for the Mulchatna herd and extends beyond GMU 17 borders
include both non-local residents and local residents
j Species-specific Wildlife Management Reports
Table 26 outlines the estimation of total annual expenditures for big game hunting within the
Bristol Bay region. These estimates are based on an assumption of one trip per hunter per year
for a species, and utilize estimates of hunter expenditures per trip developed by Miller and
McCollum (1994) adjusted to 2009 price levels.
Table 26. Estimated annual big game hunting expenditures for Bristol Bay region
Statistic
Non-local Residents
                Nonresidents
Estimated trips
Expenditure per trip
Total estimated direct
expenditure	
               1,319
               1,068

           1,408,351
                         1,323
                         5,170

                     6,839,301
Total
            $
8,247,652.52
In total, it is estimated that Bristol Bay area big game hunters living outside of the area spend
about $8.2 million per year in direct hunting-related expenditures. The expenditure estimate
above may include some caribou hunting of the Mulchatna herd outside of the closely defined
Bristol Bay region game management units, resulting in an overestimate of spending for hunting
this species.
                                          47

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2.3.2 Non-consumptive Wildlife Viewing / Tourism Economics

Many of the sport fishing and sport hunting visitors to the Bristol Bay region also engage in
other activities  such as kayaking, canoeing, wildlife viewing or bird watching. These activities
are typically referred to as non-consumptive because unlike hunting or fishing, no resource is
"consumed," rather the goal is to leave the resource (flora and fauna) unchanged.

The Bristol Bay region has a number of nationally-recognized special management areas for
wildlife.  These include Katmai and Lake Clark National Parks, the Togiak and Becherof
National Wildlife Refuges, and Wood-Tikchick State Park. The most accessible and popular
destination for visitors interested in non-consumptive recreation activities is Katmai National
Park, and in particular Brooks Camp on Naknek Lake which is world famous as a site for bear
viewing.  The camp accommodates both day and overnight visitors who are there to view the
bears, as well as sport fishermen.

Information on the number of non-consumptive use visitors, their itineraries and activities while
in the region, and their expenditures is somewhat limited. Unlike sport fishing and sport hunting,
no license is required for these other activities so there is no consistent and comprehensive
record documenting these trips.

The visitation estimates that form the basis for the analysis of non-consumptive use in Southwest
Alaska are primarily based on McDowell Group's (2006) Alaska Visitor Statistics Program
(AVSP) estimate . The AVSP is a comprehensive State of Alaska research program initiated in
1982 and follows a strict and proven methodology. The methodology utilizes an exit survey to
intercept visitors.  As a result of the concentration of visitors in urban parts of the state, the
survey method tends to oversample urban visitors and undersample rural visitors. Based on a
separate stratified rural sample conducted during the 2001 AVSP, it is known that the survey
methodology tends to underestimate visitation to remote rural parts of the state such as
Southwest Alaska. Thus, the overall visitation used for this analysis can be considered
conservative. In addition to McDowell Group (2006), Fay and Christensen (201 l)'s 2007
estimate of visitation to Katmai was utilized.

For this analysis non-consumptive users are defined as those who reported wildlife viewing,
camping, kayaking, hiking, or photography as their primary purpose of their visit. We adjust the
most recent 2006  summer and winter visitor estimate for Southwest Alaska excluding Kodiak by
applying the 2006-2009 percent difference in air travelers for Alaska overall (McDowell Group,
2007a & 2007b). The trend in air travelers to Alaska serves as the best indicator for changes  to
visitation in Southwest Alaska for two reasons. First,  visitors to rural Alaska are mainly
independent travelers,  and second they primarily arrive by air in comparison to the statewide
largest share of visitors who arrive by cruise ship. The Southwest Alaska region closely matches
the Bristol Bay study region with the exception of Kodiak and the Aleutian Islands. Our analysis
excludes Kodiak but includes an insignificant portion of visitors to the Aleutian Islands.

Since the Alaska Visitor Statistics Program counts out-of-state visitors only, we calculate visitor
volume originating within the state based on Littlejohn and Hollenhorst (2007) and Colt and
Dugan (2005) resident share of between ten and eleven percent. We treat visitation to Katmai

                                           48

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NPP separate from other areas of the Bristol Bay region. Visitor volume and expenditure for
Katmai NPP are from Fay and Christensen (2010) and for the remaining Bristol Bay area are
from McDowell Group (2007a). We net out  sport fishing and hunting visitation in Katmai NPP
using Littlejohn and Hollenhorst (2007) and for the rest of the region by applying the McDowell
Group  (2007a and 2007b) estimate. We assume equal expenditures for residents and non-
residents because the non-resident per person expenditure estimate in both cases does not include
the cost of travel to and from Alaska. For most non-residents all in-state travel expenditures are
included, based on the assumption that the primary reason for the travel to Alaska is the visit the
Bristol Bay region. For all of these estimates, we paid special attention to the potential for double
counting and addressed those issues.

Based on the most recent studies of non-resident visitors to the state and two studies that
estimated visitation and economic impacts related to Katmai National Park and Preserve, we
estimate that on an annual basis including summer and winter visitation, approximately 2,300
residents and 18,900 non-residents visited Katmai NPP. Other areas in the Bristol Bay region
received approximately 2,300 resident visitors and 19,000 non-resident visitors. Note, these
estimates exclude visitation where sport fishing or sport hunting was in part or the primary
activity of choice. After adjusting the per capita expenditures to 2009 dollars we estimate per
person expenditures to amount to $2,245 annually for Katmai NPP and $2,873 per person
annually for visiting other destinations in the Bristol Bay region.

To be consistent with the expenditure data for sport fishing and hunting, we assume that the visit
to the Bristol Bay region was the primary reason for their visit to Alaska. Based on these
assumptions, 2009 total expenditure for this  group is estimated to be $104.2 million.

It should be noted that an earlier estimate of Bristol Bay non-consumptive (wildlife watching)
visitor expenditures (Duffield et al. 2007) reported a much lower spending level by this group
($17.1  million). As noted in that report, the  estimate was based on extremely limited and dated
information from one location within the region (Brooks Camp). The estimate was derived and
presented as an approximation, as was also noted in the report, "This is an approximate estimate
based on limited and outdated information, and is an area for further research."(Duffield et al.
2007, p. 91).

The estimates derived in this later, current report utilizes both visitation and expenditure
estimates that were not available when the earlier report was drafted.
                                           49

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3.0 Bristol  Bay Commercial Fisheries
3.1 Introduction

This section provides an economic overview of Alaska's Bristol Bay commercial salmon
industry. The report begins with a brief overview of the industry.  Subsequent sections discuss
harvests, products and markets, prices, harvest and wholesale value, fishermen, processors,
employment, taxes, the regional distribution of permit holders, fishery earnings and processing
employment, and the role of the industry in the Bristol Bay regional economy. The final section
discusses selected economic measures of the Bristol Bay salmon industry.

A challenge in characterizing the Bristol Bay fishery is that there is wide variation from year to
year in catches, prices, earnings, employment and other measures of the fishery. No single
recent year or period is necessarily "representative"  of the fishery or what it will look like in the
future. To illustrate the range of historical variation in the fishery, wherever possible this report
provides data or graphs for at least the years since 2000, and in many cases for longer periods.

This report focuses on the economic significance of the entire Bristol Bay commercial salmon
fishery. The fishery harvests salmon returning to several major river systems, including the
Nushagak and Kvichak. Currently, because of potential future resource development in these
watersheds, there is particular interest in the fisheries resources and economic significance of
these two river system. As discussed in greater below, historically the relative contribution of
these river systems to total Bristol Bay commercial salmon harvests has varied widely from  year
to year and over longer-term periods. There is no simple way to characterize what share of the
Bristol Bay commercial fishery is attributable to the Nushagak and Kvichak river systems, or
what this share will be in the future.

Some of the prices and values presented in this report are presented as nominal prices and values
(not adjusted for inflation), and others are presented as real prices and values (adjusted for
inflation). In general, we used nominal prices where our primary purpose was to show actual
prices and values over time  (and as they appeared to people over time), and we used real prices
where our primary purpose was to compare prices and values over time. Prices and values are
expressed in nominal dollars except where the report specifically notes that they are real dollars.
All real prices are expressed in 2010 dollars, as calculated using the Anchorage Consumer Price
Index. This is far from an ideal measure, but it is the only long-term measure of inflation
                              o
available for any Alaska location.
 In theory, it may appear more technically accurate to express all prices in real dollars.  In
practice, there are several reasons why nominal prices are preferable for much of the data
presented in this report.  First, it is far from obvious what the measure of inflation should be:
while the Anchorage CPI is the best available measure, it is not necessarily a good
characterization of the inflation actually experienced by Bristol Bay fishermen or processors.
Secondly, when price or value data are converted to "real" values it is harder to compare them to
other data unless those data have been converted to real values for the same year. Data
converted to real dollars quickly use their utility as a reference source.  Third, people familiar

                                           50

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The report presents a wide variety of data for the Bristol Bay salmon industry in graphs and
tables as well as in the text of the report.  Detailed information on the data sources for all graphs ,
tables and text are provided in the data appendix at the end of the report. The report is based on
data available as of October 2011.

We've included pictures in the report to help readers who haven't had the opportunity to visit
Bristol Bay to have a sense of what the industry looks like. Except where otherwise noted,
pictures in the report were taken by Gunnar Knapp.
3.2 Overview of the Bristol Bay Salmon Industry

The Bristol Bay salmon fishery is one of the world's largest and most valuable wild salmon
fisheries. Between 2006 and 2010, the Bristol Bay salmon industry averaged:

    •   Annual harvests of 31 million salmon (including 29 million sockeye salmon)
    •   51% of world sockeye salmon harvests
    •   Annual "ex-vessel" value (the value earned by fishermen) of $129 million
    •   Annual first wholesale value after processing of $268 million.
    •   26% of the "ex-vessel" value to fishermen of the entire Alaska salmon harvest.
    •   Seasonal employment of more than 6800 fishermen and 3700 processing workers.

Bristol Bay is located in southwestern Alaska. Each year tens of millions of sockeye salmon
return to the major river systems which flow into Bristol Bay, of which the most significant (in
numbers of returning salmon) are the Nushagak, Kvichak, Naknek and Egegik Rivers.  Sockeye
salmon spend a year or more in freshwater lakes before migrating to saltwater. The large lakes
of the Bristol Bay region provide habitat for sockeye salmon during this life stage.
with the Bristol Bay fishing industry remember what fish and permit prices actually were in any
given year: it is harder for them to recognize and believe prices or values converted to real
dollars.

                                          51

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                             Egegik
                                                                       ^
                                                                     m
                                                           --
                      Figure 10. Major Bristol Bay River Systems
     Map source: www.purebristolbay.com/images/layout/BBNC_Base_Map-800.jpg
Almost all Bristol Bay commercial fish harvests occur during a brief four-week season from
mid-June to mid-July. At the peak of the season, millions of salmon may be harvested in a single
day.
                             The Naknek River near Kins Salmon
                                          52

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Two kinds of fishing gear are used in the Bristol Bay fishery:  drift gillnets (operated from
fishing boats) and set gillnets (operated from shore).  Drift gillnets account for most of the total
catch.  Technically, the drift gillnet fishery and the set gillnet fishery are managed as separate
fisheries.

Both the drift gillnet  fishery and the set gillnet fishery are managed under a "limited entry"
management system which was implemented for all of Alaska's twenty-seven salmon fisheries in
the mid-1970s.  The basic purpose of the limited entry system is to limit the number of boats
fishing in  each fishery, which makes it easier for managers to control the total fishing effort and
makes the fishery more profitable for participants than it would be if entry (participation) were
unrestricted and more boats could fish. Every drift gillnet fishing boat or set net operation must
have a permit holder on board or present—so the number of boats or set net operations cannot
exceed the number of permit holders. There are approximately 1860 drift gillnet permits and
approximately 1000 set net permits.  Section 3.7 below (Bristol Bay Salmon Fishermen)
provides more details about the limited entry system and Bristol Bay management regulations.
                          Drift Gillnet Boats Fishing in the Naknek River
The Bristol Bay salmon harvest is processed by about 10 large processing companies and 20
smaller companies employing about 3700 processing workers at the peak of the season in both
land-based and floating processing operations. Most of the land-based processors operate only
during the short summer salmon season.  Most of the workers are flown in from outside the
region and live in bunkhouse facilities at the processing plants.
                                           53

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The Ekuk Processing Plant in the Nushagak District near Dillingham, photographed at low tide. Extreme tides
complicate logistics for land processing facilities in Bristol Bay. At many plants, fish can be delivered only when
the tide is in.
Most Bristol Bay salmon is processed into either frozen headed and gutted salmon or canned
salmon. Formerly almost all Bristol Bay frozen salmon was exported to Japan. In recent years
exports to Japan have declined sharply while shipments to the U.S. domestic market have
increased and exports have increased to Europe and to China (for reprocessing into fillets sold in
Europe, Japan and the United States).  Most canned salmon is exported, primarily to the United
Kingdom, Canada, and other markets.
        Fish on a Bristol Bay fishing boat
         Photograph by Gabe Dunham
Bristol Bay salmon catches vary widely from year
to year and over longer periods of time. Catches
set all-time records in the early 1990s, fell sharply
after 1995, and then rose again after 2002.  The
2011 catch was about 25% lower than the average
for the previous five years.

Wholesale prices for Bristol Bay salmon products
and "ex-vessel" prices paid to fishermen increased
during the 1980s, peaked in 1988, and then
declined dramatically during the 1990s. The main
cause of the decline in prices was competition in
world markets from dramatically increasing world
production of farmed salmon, although many
other factors also contributed. Since 2001,
wholesale and ex-vessel prices have been
increasing, as the growth of farmed salmon
production has slowed and new markets for
Bristol Bay sockeye salmon have been developed.

The decline in catches and prices during the 1990s
led to a drastic decline in value in the Bristol Bay
                                           54

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salmon fishery. The ex-vessel value paid to fishermen fell from a peak of $214 million in 1990
to just $32 million in 2002. The loss in value led to a severe economic crisis in the Bristol Bay
salmon industry. Many land-based salmon processing operations closed and many floating
processors left Bristol Bay. Many fishing permit holders stopped fishing, and permit prices fell
drastically.

As catches and prices have improved since 2002, the Bristol Bay salmon industry has
experienced a significant economic recovery.  The ex-vessel value paid to fishermen increased
to $149 million in 2010.  Participation in the fishery has increased and permit prices have
strengthened. Among both fishermen and processors there is a renewed sense of optimism about
the economic future of the Bristol Bay salmon industry, taking advantage of growing world
demand for wild salmon. This optimism is tempered by recognition of the variability of harvests
and value associated with fluctuations in salmon returns and markets.
               A tender, floating processor, and freighter anchored in the Nushagak district
                                 Photograph by Gabe Dunham
                      A Bristol Bay processing worker holding a sockeye salmon
                                  Photograph by Gabe Dunham

-------
3.3 Bristol Bay Salmon Harvests

Although all five species of Pacific salmon are caught in Bristol Bay, commercial salmon
harvests are overwhelmingly sockeye salmon. Between 2001 and 2010, sockeye accounted for
94% of total Bristol Bay salmon catches.  Except where otherwise noted, references in this report
to harvests, production, prices, etc. are specifically for Bristol Bay sockeye salmon.

Between 1975 and 2010, annual Bristol Bay commercial sockeye salmon harvests ranged from 5
million to 44 million fish, with an annual average of 22.5 million fish. Harvests increased from
depressed levels of less than 6 million fish in the mid-1970s to more than 15 million fish for
most of the 1980s and more than 25 million fish annually for the years 1989-1996. Sockeye
salmon harvests peaked at 44 million fish in 1995. Harvests then fell off sharply to lows of 10
million fish in 1998 and 2002 before rebounding to 29 million fish in 2007 and 31 million fish in
2009—the highest sockeye harvest since 1995.  The 2011 harvest of 22 million fish was
significantly lower than the previous five years  and the  lowest since 2003.
Bristol Bay Commercial Salmon Harvests
^n
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/in
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co LO r^ o>
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Source: Commercial Fisheries Entry Commission; Alaska
























D Other
Species
• Sockeye


T- ro in r^ cj> T-
o o o o o T-
o o o o o o
CM CM CM CM CM CM
Department of Fish and Game
                  Figure 11. Bristol Bay Commercial Salmon Harvests.
                                         56

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The average weight of a Bristol Bay sockeye salmon is typically about 6 pounds. Between 1975
and 2010 average weights varied from as low as 5.3 pounds to as high as 6.7 pounds. .  There
was no significant trend in average fish weight over this period.  Fish weight tended to be
slightly lower in years when more fish were harvested.9

Bristol Bay sockeye salmon harvests may be expressed either in fish, pounds, or metric tons.
Over the period 1975-2010, sockeye salmon harvests averaged:
              22.7 million sockeye
              133 million pounds
              60,200 metric tons
@ average weight of 5.9 pounds per fish)
@ 2204.6 pounds per metric ton)
For commercial fishery management purposes, Bristol Bay is divided into five different fishing
districts: Naknek-Kvichak, Egegik, Nushagak, Ugashik, and Togiak, which correspond to
different major Bristol Bay river systems.
                l

           Numbers in boxes are average annual
           harvests for each district in millions of
                fish for the years 1991-2010
           Figure 12. Bristol Bay Fishing Districts. Source: ADFG map posted at:
    www. adfg. alaska.go vfindex. cfm ? adfg=CommercialByFish erySalmon. salmonmaps_districts_bristolbay
 The correlation between fish weight and the number of fish harvested was -.433, which is statistically significant at
the 1% level in a one-tailed t-test (N = 36).
                                           57

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Annual harvests within each district vary widely from year to year, as does the relative share of
each district in the total catch.  Most of the record Bristol Bay catches of the mid-1990s were
caught in the Naknek-Kvichak and Egegik districts.  Similarly, most of the decline in catches
after the mid-1990s resulted from a decline in catches in these two districts—particularly the
Naknek-Kvichak.  Most of the recovery in catches since 2002 has also occurred in these two
districts,  as well as in the Nushagak district, where catches have been very strong.
                  Bristol Bay Commercial Sockeye Salmon Harvests, by District
                                                                              •Naknek-
                                                                               Kvichak

                                                                              •Egegik


                                                                              •Nushagak


                                                                               Ugashik


                                                                              •Togiak
                                            OOOOOOOOOOT-T-
                                            000000000000
                                            CNCNCNCNCNCNCNCNCNCNCNCN
                                       Source: ADFG
         Figure 13. Bristol Bay Commercial Sockeye Salmon Harvests, by District.
                                            58

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Currently, there is particular interest in the fisheries resources and economic significance of the
Nushagak and Kvichak watersheds because of potential future resource development in these
watersheds, Given the wide variation in catches by district from year to year and over longer
time periods of time, there no obvious way to characterize the relative share of the Bristol Bay
commercial salmon fishery attributable to these river systems or to the rivers, streams and lakes
that make up each river system.

In general, over most of the past decade, the Nushagak and Naknek-Kvichak districts have
accounted for about 60% of the total Bristol Bay commercial sockeye harvest (Figure 14).
               Share of Bristol Bay Commercial Sockeye Salmon Harvest, by District
        100%
         80% -
         60%
         40%
         20%
          0%
  Togiak


SUgashik


• Egegik


SNushagak
 I Naknek-
  Kvichak
              ooooooooa>a>a>a>a>a>a>a>a>a>oooooooooc>T-T-
              (J>(J>(J>(J>(J>(J>(J>(J>(J>(J>(J>(J>(J>(J>OOOOOOOOOOOO
                                         Source: ADFG
     Figure 14. Share of Bristol Bay Commercial Sockeye Salmon Harvest, by District.
Note however that both districts include other major rivers beside the Nushagak and Kvijak
rivers. For example, the Kvichak River generally accounts for less than half of Naknek-Kvichak
district harvests (Figure 15).
                                            59

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            Naknek-Kwijak District Sockeye Salmon Harvests, by River of Origin
                                                                          INaknek
                                                                           River
                                                                           Branch River
                                                                          IKvichak
                                                                           River
                                      Source: ADFG
    Figure 15. Naknek-Kvichak District Sockeye Salmon Harvests, by River of Origin.
As discussed more below, economic measures of the Bristol Bay commercial fishery are not
necessarily proportional to fish harvests.  If total fish harvests were to change by a given
percentage, the value of the fishery, employment, and other measures would not change by the
same percentage amount.

Bristol Bay Gear Types

All Bristol Bay salmon are harvested using gillnets. Gillnets hang in the water perpendicular to
the direction in which returning salmon are swimming.  The fish get their heads stuck in the nets
and are "picked" from the net as it is pulled from the water.

There are two types of gillnet fishing operations in Bristol Bay: drift gillnets and set gillnets.
Drift gillnets hang in the water behind the fishing boat.  After a period of time, the nets are
pulled back into the boat for picking.
                                           60

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Gillnetters catch salmon by setting curtain-like nets
perpendicular to the direction in which the fish are traveling
as they migrate along the coast toward their natal streams.
The net has afloat line on the top and a weighted lead line
on the bottom.  The mesh openings are designed to be just
large enough to allow the . . . fish to get their heads stuck
("gilled") in the mesh. . . . Net retrieval is by hydraulic
power which turns the drum.  Fish are removed from the net
by hand "picking" them from the mesh as the net is reeled
onboard.
         Gillnetter,
                                                    Source: Alaska Department of Fish and
                                                    Game, "What kind of fishing boat is that? "
                                                    www. cf.adfg. state, ak. us/geninfo/pubs/fv_n_a
                                                    k/fv_aklpg.pdf.
                     Picking salmon from the net on a Bristol Bay drift gillnet boat
Bristol Bay fishing boats stored in a Naknek boatyard
                  for the winter
Most Bristol Bay drift gillnet fishing boats
are used only during the short, intense
summer salmon season  (although some are
used to fish for herring in the spring) and are
stored in boat yards for  the rest of the year.
The fact that fishing boats and processing
plants are idle for much of the  year adds to
costs in the fishery.
                                              61

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Crowded fishing near the boundary of a Bristol
           Bay fishing district
        Photograph by Bart Eaton
Drift gillnet fishermen have the advantage of
being able to move to where the fishing is best—
and the disadvantage that other fishermen are
likely to want to fish in the same places.  Bristol
Bay drift gillnet fishing boats are often crowded
along the "lines" which are the boundaries of
legal fishing districts, established by GPS
coordinates. Often fishing is best when fishermen
are able to place their nets along the line, catching
fish as they  swim into the district.

Bristol Bay  drift gillnet fishing boats are  limited
to 32 feet in length.  Over time, wider and taller
boats have been built as fishermen try to  get more
working space and hold capacity.
                 Drift gillnet boats waiting for an opening in the Nushagak district
                                               vifej^. V...c'-^Vf* ^4i^±v -v-
                                  —  »-—•*•'*             *•
                                Photograph by Gabe Dunham
                                           62

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In set gillnet fishing, one end of the net is attached to the shore, while the other is attached to an
anchor in the water. Fishermen pick the fish from a skiff or from the beach at low tide.
 A set-net fishing operation on the Nushagak River
                                                       There are more drift gillnet permits
                                                       fished than set gillnet permits, and
                                                       average catches are higher for drift
                                                       gillnet permits than for set gillnet
                                                       permits.  As a result, drift gillnet
                                                       permits account for about four-fifths of
                                                       the Bristol Bay sockeye salmon catch.
Table 27. Comparison of Bristol Bay Drift Gillnet and Set Gillnet Fisheries (2006-10
Average)
               Comparison of Bristol Bay Drift Gillnet and Set Gillnet Fisheries (2006-10 Averages)



Total Permits Fished
Average Pounds
Total Pounds

Drift
Gillnet
1,470
102,109
150,053

Set
Gillnet
847
37,575
31,813


Total
2,317
139,684
181,866
Ratio,
Drift Gillnet
to Set Gillnet
1.7
2.7
4/7

Drift
Gillnet %
63%

83%

Set
Gillnet %
37%

17%
 Source: Commercial Fisheries Entry Commission, Basic Information Tables.
                                             63

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                       Bristol Bay Salmon Harvests, by Fishery
      250
           h-h-h-OOOOOOOOOOCDCDCDCDCDOOOOO
                      Source:  CFEC Basic Information Tables
                  Figure 16. Bristol Bay Salmon Harvests, by Fishery
Relative Scale of Bristol Bay Sockeye Salmon Harvests

There are several ways to measure the relative scale of Bristol Bay sockeye salmon harvests in
comparison with other sources of supply, which are illustrated by the three graphs below:

Sockeye salmon fisheries.  Bristol Bay is by far the largest sockeye salmon fishery in the world.
Between 1980 and 2009 Bristol Bay averaged 59% of total Alaska sockeye salmon supply and
44% of total world sockeye salmon supply.
                                         64

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                            World Sockeye Salmon Supply
     250,000
                                                                         Uapan


                                                                         I Lower 48


                                                                          Canada


                                                                          Russia


                                                                         I Other
                                                                          Alaska

                                                                         I Bristol
                                                                          Bay
               OCNl'vJ-CDOOOCNl'vJ-CDOOOCNl'vJ-CDOO
               oooooooooocncncncncnooooo
               (J>(J>(J>O)O)O)O)O)OOOOO
               •f-t-t-t-t-t-t-t-t-t-CNCNCNCNCN

                                 Source: ADF&G, NMFS, FAO
                           Figure 17. World Sockeye Supply
Alaska salmon fisheries.  In most years, Bristol Bay sockeye is the single largest fishery in

Alaska. Between 1980 and 2009, Bristol Bay sockeye salmon averaged 20% of Alaska salmon

supply for all species combined.
                                          65

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                                Alaska Salmon Supply
                             Source: ADF&G, FAO, NMFS
                                                                     I Total Alaska
                                                                      coho &
                                                                      Chinook

                                                                     I Total Alaska
                                                                      chum
                                                                     I Total Alaska
                                                                      pink


                                                                     I Other Alaska
                                                                      sockeye
                                                                     I Bristol Bay
                                                                      sockeye
                          Figure 18. Alaska Salmon Supply
World salmon supply. World farmed salmon and trout production has grown extremely rapidly
since the early 1980s.  As farmed salmon and trout production increased, Bristol Bay's share of
total world salmon supply fell from 11% in 1980 to just 3% in 2009.
               Mending gillnets at the historic Peter Pan processing plant in Dillingham
                                        66

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World Salmon and Trout Supply
3cnn
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-------
             Bristol Bay Sockeye Salmon Preseason Projection and Actual Commercial Catch
        50,000

        45,000

        40,000

        35,000

     -c  30,000
     ^
     o  25,000
     w
     ro  20,000
     in
     |  15,000

        10,000

         5,000

            0
                          I Preseason Projection
                                     I Actual
        MM
ifiiiiinnni
              o
              05
              05
      CM
      05
      05
05
05
CD
05
05
CO
05
05
O
O
O
CM
CM
O
O
CM
O
O
CM
CD
O
O
CM
CO
O
O
CM
                                                                    O
                                                                    CM
                                 Source: ADF&G
   Figure 20. Bristol Bay Sockeye Preseason Projection and Actual Commercial Catch
There are no formal projections of how Bristol Bay salmon harvests may change over the longer
term future.  As shown by the graph on the following page, historically harvests have varied
widely from decade to decade. Analysis of lake-bed sediments has also shown significant
historical variation in salmon returns in previous centuries prior to commercial harvesting.

Long-term changes in salmon returns have been shown to be associated with periodic changes in
ocean conditions such as water temperature and currents, known as "regime shifts." The much
lower average harvests from the 1950s through the 1970s are thought to have resulted in part
from a different ocean regime (although other factors, such as interceptions of Bristol Bay
salmon by foreign fishing fleets, likely also played a role).

The potential for significant future changes in ocean conditions associated with not only regime
shifts but also global climate change could significantly affect future Bristol Bay salmon returns
and harvests—but it is very difficult to predict what changes might occur or when they might
occur.
                                      68

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                       Bristol Bay Sockeye Salmon Harvests, 1895-2009
     .,000
              Note: The black line
               shows the average
              annual catch for the
              preceding 10-years.
tn
•f^
!   15,000
o
.c
    10,000

     5,000

        0
          LOOLOOLOOLOOLOOLOOl^)OLOOLOOLOOLOOLOO

          OOO5O5O5O5O5O5O5O5O5O5O5O5O5O5O5O5O5O5O5O5OOO
                                     Source: ADF&G
                 Figure 21. Bristol Bay Salmon Harvests, 1985-2009
            Until the 1950s, only sailboats were allowed to harvest salmon in Bristol Bay
            Source:  "Sailing for Salmon " exhibition of historic Bristol Bay photographs
             at Anchorage Museum, summer 2011 (http://www.anchoragemuseum.org)
                                           69

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3.4 Bristol Bay Salmon Products and Markets

The major products produced from Bristol Bay sockeye salmon are canned salmon, frozen
headed and gutted (H&G) salmon, frozen salmon fillets, fresh H&G salmon, and salmon roe.
Frozen H&G salmon and canned salmon account for most of the product volume.
            Bristol Bay canned salmon
Headed and gutted salmon on trays for freezint
        Bristol Bay sockeye salmon fillet
  Processing Bristol Bay sockeye salmon roe
For most of the more than one-hundred year history of the Bristol Bay salmon fishery,
production was overwhelmingly canned salmon. Processing plants were called "canneries" and
processing companies were called "canners."

However, in the 1970s frozen salmon production increased rapidly, as technologies for freezing
salmon and shipping frozen salmon developed, and as Japanese demand for frozen Bristol Bay
salmon expanded with the end of Japanese salmon fishing in international waters and within the
U.S. 200-mile limit. By the mid-1980s, more than 80% of Bristol Bay salmon production was
                                         70

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frozen, almost entirely for export to Japan. The shares of different product forms in Bristol Bay
production over time reflect changes in changes in relative prices and total harvests.  From the
mid-1990s to the mid-2000s, as frozen sockeye salmon prices fell due to increased competition
in the Japanese market from farmed salmon, and as harvest volumes fell, the frozen share of
production declined and the canned share increased. Since the mid-2000s, as frozen sockeye and
harvest volumes have increased, the frozen share of production has risen (Figure 22 and Figure
23).
                            Bristol Bay Sockeye Salmon Production
            180.0

            160.0

            140.0

            120.0

            100.0

             80.0

             60.0

             40.0

             20.0

              0.0
inn
                     MM
imn
                                      CDCOOCN-^-CDCOO
                                      8?8?000000
                      Source: ADFG Commercial Operator Annual Report database
                  Figure 22. Bristol Bay Sockeye Salmon Production
Share of Sockeye Salmon Production in Bristol Bay
-innox, .
•tmrnnn m™
60%
40%
20%






• Roe
Fresh
• Canned
• Frozen


T-T-T-T-T-T-T-T-CMCMCMCMCMCM
Source: ADFG, COAR
             Figure 23. Share of Sockeye Salmon Production in Bristol Bay
                                        71

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Table 28 provides more detail about product forms for canned and frozen Bristol Bay salmon in
recent years. In 2010, about one-third of canned salmon production was "tails" (14.75 ounce
cans) and about two-thirds "halves" (7.5 ounce cans).  Between 2006 and 2010, the share of
frozen fillets in total frozen production increased from about 6% to about 18%.
Table 28. Sales of Selected Sockeye Salmon Products.

                      Sales of Selected Sockeye Salmon Products
                  by Major Bristol Bay Salmon Processors (pounds)
Type
Canned
Frozen
Fresh
Roe
Form
Canned Halves
Canned Tails
Frozen Fillet
Frozen H&G
Fresh H&G
Roe
2006
23,349,893
*
3,939,220
61,270,959
2,958,201
2,902,082
2008
23,672,655
*
7,930,710
53,590,871
1,904,051
3,186,876
2010
23,486,265
10,592,344
13,788,359
63,720,557
*
3,657,859
 * Not reported due to confidentiality restrictions
 Note:  Includes only sales reported by processors with more than 1 million pounds of sales of
 salmon products in the previous year.
 Source: Alaska Department of Revenue, Annual Salmon Price Reports
In any given year, the total volume of Bristol Bay salmon products is less than the annual harvest
volume, because part of the weight (25%-35%) is lost in processing as the fish heads and guts are
removed, and also because some fish are shipped to plants outside the Bristol Bay region for
processing.  Between 1984 and 2010, the reported volume of processed salmon products sold by
Bristol Bay salmon processors, or production, averaged 67% of the volume of harvests, and
ranged from as low as 59% to as high as 75%. The annual variation in the ratio of production
weight to harvest weight results from several factors including changes in average fish size,
changes in the mix of products produced, and changes in the share of the catch shipped outside
the region for processing.
                                          72

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               Bristol Bay Sockeye Salmon Harvests and Production
300.0
250.0
  0.0
      -3-COOOOCN-3-COOOOCN-3-COOOO
      O5O5O5O5O5O5O5O5OOOOOO
                          Source: CFEC, ADFG
   Figure 24. Bristol Bay Sockeye Salmon Harvests and Production

-------
                              Monthly Sales Volume, Bristol Bay Frozen H&G Sockeye Salmon
                    20,000
                     5,000
                         May-08
                                                May-09                 May-10

                                         Source: Alaska Department of Revenue Salmon Price Reports
                                                                                             May-11
                           Monthly Sales Volume, Bristol Bay Sockeye Sa mon Fillets, Fresh & H&G and Roe
                                                                                           Frozen and
                                                                                           Fresh
                                                                                           Fillets
                        May-08             May-09             May-10              May-11

                                  Source: Alaska Department of Revenue Salmon Price Reports
                                        Monthly Sales Volume, Bristol Bay Canned Salmon
                                     Source: Alaska Department of Revenue Salmon Price Reports
Figure 25. Monthly Sales Volume of Bristol Bay Salmon Products
                                                       74

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The timing of processors' sales of Bristol Bay salmon reflects the highly seasonal character of
the industry. Sales of products for which storage costs are relatively high—including frozen
H&G salmon, frozen and fresh fillets, fresh H&G and roe—are concentrated in the summer in
the months during and immediately after the season. Sales of canned salmon are distributed
more evenly over the year. For some products, no data are available for sales for some months
(to preserve confidentiality, sales are only reported if at least three processors report sales).

Bristol Bay Salmon Markets

Data are not available on the end-markets to which Bristol Bay sockeye salmon products are
shipped.  However, because Bristol Bay represents such a large share of Alaska and United
States sockeye salmon production, we can make reasonable inferences about end markets for
Bristol Bay sockeye salmon by comparing U.S. export data with Alaska statewide production
data.

Prior to about 1998, almost all U.S. frozen sockeye  salmon production (including Bristol Bay
production) was exported, and almost all exports were to Japan. Beginning in about 1999, this
pattern changed in two important ways.  First, exports declined relative to production—
indicating that significant volumes of Alaska frozen sockeye were beginning to be sold in the
U.S. market rather than exported. Secondly, significant volumes of frozen sockeye began to be
exported to countries other than Japan—particularly EU countries and China—substantially
reducing the Japanese share of U.S. sockeye salmon exports (Figure 26).

These two trends together resulted in a dramatic decline in the volume of Alaska sockeye salmon
shipped to Japan—from more than 100,000 metric tons in 1993 to 20,000 Ibs or less since
2006—and a corresponding dramatic decline in the  dependence of Alaska (and Bristol Bay)
sockeye on the Japanese frozen salmon market.
                                           75

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              Alaska Frozen Sockeye Production & U.S. Frozen Sockeye Exports
  120,000
                     Sources: ADFG COAR database; NMFS trade data
Note: Export data
are for the period
   May of the
production year to
   April of the
 following year.
Figure 26. Alaska Frozen Sockeye Production and U.S. Frozen Sockeye Exports.
                                         76

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The volume of Alaska frozen sockeye salmon sold to U.S. domestic markets may be estimated as
total production minus exports.  This in turn allows estimation of the end-market shares of the
United States and export markets.  End-market shares have changed dramatically from the early
1990s, when almost all production was estimated to Japan. Between 2006 and 2010, 27-39% of
production was exported to Japan, 20-31% was sold in the United States, 10-21% was exported
to China, 11-16% was exported to the European Union, and 7-13% was exported to other
countries.
1 nno/, -_
pnoA
eno/
AC\Q/n
ono/
no/, .

Estimated End-Markets for Alaska Frozen Sockeye Salmon (%)


































































































a>t-coLOh-a>t-coLOh-a>
ooa>a>a>a>a>ooooo
O5O5O5O5O5O5OOOOO
T-T-T-T-T-T-CNCNCNCNCN

• USA
0 Other export
• China
0 European
Union
• Japan
Note: USA
estimated as
Alaska
production
minus exports.
          Figure 27. Estimated End-Markets for Alaska Frozen Sockeye Salmon
Note that most of the frozen sockeye exported to China are not consumed in China. Rather, they
are thawed and reprocessed—using much cheaper Chinese labor—into fillet and other value-
added products which are then re-exported to end-markets in Europe, the United States and
Japan. Thus the final end-market shares for Europe, the United States and Japan are larger than
are shown in the graph (but data are not available to indicate how much larger.)
                                          77

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                    Boxes of frozen Bristol Bay sockeye in the cold storage
                             of a Chinese reprocessing plant, 2007
Most Alaska canned sockeye—including Bristol Bay canned sockeye—is exported. Total
reported U.S. exports are approximately equal to total Alaska production (Figure 28).10
Historically the United Kingdom was by far the most important market for canned sockeye.
recent years, exports of canned sockeye to Canada have grown dramatically—from which
significant volumes are likely re-exported to the UK and other markets.
                In
                     Alaska Canned Sockeye Production & U.S. Canned Sockeye Exports
          30,000
          25,000
                                                 So    o    o
                                                 o    o    o
                                             CM   CM    CM    CM
                          Sources: ADFG COAR database; NMFS trade data
                                                                             All other
                                                                             exports
                                                                             Exports to
                                                                             Australia
                                                                             Exports to
                                                                             Canada
                                                                             I Exports to
                                                                             UK
                                                                            -Alaska
                                                                             canned
                                                                             production
Wofe: Export data
are for the period
  May of the
production year to
  April of the
 following year.
     Figure 28. Alaska Canned Sockeye Production and U.S. Canned Sockeye Exports
10 In some years reported US exports of canned sockeye salmon exceed reported Alaska production. The reasons for
this are not entirely clear. One likely contributing factor is that in years of large sockeye production, significant
volumes may be kept in inventory and sold during a later year.
                                              78

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Relatively small volumes of fresh salmon are produced in Bristol Bay. It is difficult for Bristol
Bay to compete with other areas of Alaska in supplying fresh markets because of the greater
distance and cost required to transport fish to the United States market.

Salmon roe accounts for a relatively small share of total Bristol Bay product volume—typically
less than 3%-but accounts for a higher share of product value because it commands a higher
price per pound than other product forms.  Most Bristol Bay sockeye salmon roe is exported as
sujiko (roe in whole skeins) to Japan.
3.5 Bristol Bay Salmon Prices
Between the late 1980s and 2001, Bristol Bay fishermen and processors experienced a dramatic
decline in prices paid for Bristol Bay salmon. The "ex-vessel price" paid to fishermen fell from
a peak of $2.10/lb in 1988 to $.42/lb in 2001. After 2001 the ex-vessel price recovered gradually
to $.66/lb in 2006 and $.80/lb in 2009 and then rose sharply to $1.07/lb in 2010.  Final data for
Bristol Bay ex-vessel prices in 2011 were not available when this report was prepared but were
expected to be similar to 2010.

In nominal terms 2010 ex-vessel prices were similar to prices for much of the 1990s. In "real"
prices adjusted for inflation they remained lower than any year except 1993.
                    Average Ex-Vessel Price of Bristol Bay Sockeye Salmon, 1975-2010
         $3.50


         $3.00


         $2.50


         $2.00


         $1.50


         $1.00


         $0.50


         $0.00
    Real price
(adjusted for inflation,
 expressed in 2010
     dollars)
                        Nominal price
                    (not adjusted for inflation)
               O5O5O5O5O5O5O5O5O5O5O5O5
                                              i-   co  in  r-   CD
                                              o   o  o  o   o
                                              o   o  o  o   o
                                              CM   CM  CM  CM   CM
                                Source: ADFG, Commercial Operator Annual Reports
       Figure 29. Average Ex-Vessel Price of Bristol Bay Sockeye Salmon, 1975-2010
                                            79

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                        Cannery at Clark's Point, Nushagak District
                               Photograph by Gabe Dunham
The decline in ex-vessel prices during the 1990s reflects a decline in first wholesale prices paid
to processors for both canned and frozen salmon.  Similarly, the increase in ex-vessel prices after
2001 reflects in first wholesale prices for both canned and frozen salmon—particularly for frozen
salmon (Figure 30).
            Average Ex-Vessel and Wholesale Prices of Bristol Bay Sockeye Salmon
    $6.00
    $5.00
                                                                   •Frozen
                                                                    wholesale
                                                                    price


                                                                   •Canned
                                                                    wholesale
                                                                    price


                                                                   •Ex-vessel
                                                                    price
    $0.00
COCOCOG)G)G)G)G)OOO

T-T-T-T-T-T-T-T-CSICSICSI

              Source: Alaska Department of Fish and Game
                                                             CD    CO   O
                                                             OOi-
                                                             000
                                                             (XI    (SI   (SI
    Figure 30. Average Wholesale and Ex-Vessel Prices of Bristol Bay Sockeye Salmon
                                            80

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                                 A loaded Bristol Bay gillnetter
                                 Photograph by Gabe Dunham
Monthly wholesale price data, available for years since 2001, provide more detail about
wholesale price trends. Wholesale prices may fluctuate widely over the course of a year due to
changes in supply and other market factors.

Wholesale prices for frozen headed and gutted (H&G) salmon increased from about $1.75/lb in
2001 to about $3.00/lb in early 2011. Wholesale prices for canned salmon halves increased from
an average of about $2.50/lb in 2001  to about $3.50/lb in early 2011.  Wholesale prices for
canned salmon tails fell from an average of about $2.30/lb in 2001 to  about $2.10/lb in 2005
before increasing to $3.30/lb in early 2011.
                                            81

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                               Average Monthly First Wholesale Prices,
                         Bristol Bay Canned and Frozen H&G Sockeye Salmon
       $4
                                                                           -Canned
                                                                            Halves
                                                                           -Canned
                                                                            Tails
                                                                           •Frozen H&G
       $0.00
           May-  May- May- May-  May-  May-  May- May- May-  May-  May-  May-
            01    02   03   04   05    06    07   08   09    10    11    12
                          Source: Alaska Department of Revenue Salmon Price Reports
                    Figure 31. Average Monthly First Wholesale Prices.
In general, wholesale prices paid to processors for canned Bristol Bay sockeye salmon are
similar to wholesale prices for canned sockeye salmon from other regions of Alaska.  In contrast,
wholesale prices paid to processors for frozen Bristol Bay sockeye salmon are typically lower
than wholesale prices for frozen sockeye salmon from other regions of Alaska (Figure 32). This
may reflect differences in product mix and/or differences in the perceived quality of Bristol Bay
frozen sockeye compared with frozen sockeye from other parts of Alaska.

In turn, Bristol Bay ex-vessel price for sockeye salmon are typically lower than ex-vessel prices
for sockeye salmon in southcentral and southeast Alaska (Figure 33).  This may reflect the fact
that processors receive lower wholesale prices for frozen sockeye, as well as the fact that
processors face higher operating costs in Bristol Bay than in less remote regions of southcentral
and southeast Alaska, as well as generally higher costs for transporting products to market.
                                            82

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 .Q

 5}
     $6.00
     $5.00
     $4.00
     $3.00
     $2.00
     $1.00 -
     $0.00
                  Average Wholesale and Ex-Vessel Prices of Sockeye Salmon:
                              Bristol Bay and the Rest of Alaska
            O5O5O5O5O5O5O5O5
-€i--Rest-of-Alaska
    canned
    wholesale

-•—Bristol  Bay
    canned
    wholesale

••A--Rest-of-Alaska
    frozen
    wholesale

-A—Bristol  Bay
    frozen
    wholesale

•*  -Rest of Alaska
    ex-vessel
    •Bristol Bay ex-
    vessel
                        Source: Alaska Department of Fish and Game
Figure 32. Average Wholesale and Ex-Vessel Prices, Bristol Bay and Rest of Alaska
               Average Ex-Vessel Prices of Sockeye Salmon, Selected Alaska Areas
    $2.50
    $2.00
    $1.50
 .Q
 Si $1.00
    $0.50  -
    $0.00
      Prince
      William
      Sound

     -Southeast
                                                                               -Cook Inlet
                                                                               •Kodiak
     •Bristol Bay
            a>a>O)a)Oooooooooot-
            a>a>a>a>ooooooooooo
            t-t-t-t-c\ic\ic\ic\ic\ic\ic\ic\ic\ic\ic\i
               Source: ADFG, 1984-2010 Salmon Exvessel Pice Time Series by Species
  Figure 33. Average Ex-Vessel Prices of Sockeye Salmon, Selected Alaska Areas.


                                             83

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Factors Affecting Bristol Bay Salmon Prices

Changes in Bristol Bay salmon prices over the past three decades reflect dramatic changes in
world salmon markets over this period.  The most important change was a dramatic increase in
world salmon supply resulting from rapid growth in farmed salmon production, mostly in
Norway, Chile, the United Kingdom and Canada.

In particular, during the 1990s, Japan—where the market for "red-fleshed salmon has previously
been dominated by Alaska sockeye—began to import large volumes of farmed coho salmon
from Chile and farmed trout from Chile and Norway. This, together with lower Bristol Bay
salmon harvests, led to a dramatic decline in the share of Bristol Bay sockeye salmon in its most
important market.
                      Japanese "Red-Fleshed" Salmon Imports, May-April
       250,000
                                                                       I Frozen trout
                                                                       fillets
                                                                      Ed Frozen trout
                                                                       (excl. fillets)
                                                                       I Frozen coho
                                                                       I Frozen sockeye
                                                            ro
                                                            o
                                                        ooo
                                                        CM   CM   CM
              Figure 34. Japanese Red-Fleshed Salmon Imports, May-April

The effects of growing supply were compounded by an economic recession in Japan, changes in
the Japanese fish distribution system which increased the market power of retailers, and long-
term changes in Japanese food consumption patterns. The combined result was a sharp decline
in Japanese wholesale prices paid for Bristol Bay sockeye salmon as well as farmed salmon
(Figure 35). This in turn was reflected in a sharp decline in prices paid to Alaska processors and
fishermen (Figure 36).
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                       Bristol Bay headed and gutted sockeye salmon
           Japanese "Red-Fleshed" Frozen Salmon Imports & Wild Sockeye Wholesale Price
     250,000
                 Sockeye wholesale price
           0
              OOOOOOO)O)O)O)O)O)O)O)O)O)




              OOOOOOOOO)So)O)O)O)O)O)O)O)
                                                              OOOOO
Figure 35. Japanese Red-Fleshed Frozen Salmon Imports & Wild Sockeye Wholesale Price
                                           85

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                Japanese Wholesale Prices and Bristol Bay Prices for Sockeye Salmon
     $6.00
     $5.00
     $1.00
     $0.00
•August
 Japanese
 wholesale
 price, Bristol
 Bay frozen
 sockeye


•Average first
 wholesale
 price, Bristol
 Bay frozen
 sockeye
                                                                            •Average
                                                                            Bristol Bay ex-
                                                                            vessel price
          oo   oo   oo   oo
                             88S8888S88?
          O5O5O5O5O5O5O5O5O5O5OOOOOO
                                                CM   CM   CM   CM  CM   CM
     Figure 36. Japanese Wholesale Prices and Bristol Bay Prices for Sockeye Salmon
Just as multiple factors contributed to the fall in Bristol Bay salmon prices during the 1990s,
multiple factors contributed to the recovery in prices after 2001. Probably the most important
factors was a strong recovery in world market prices for farmed salmon, driven by rapidly rising
world demand and a slowing of the growth in world salmon production (Figure III-9),
exacerbated by major disease problems in the Chilean salmon industry which greatly reduced
Chilean production. Prices of farmed Atlantic salmon in particular rose dramatically from 2002
through 2010 (Figure 37 and Figure 38).
                                           86

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                Average United States Import Prices of Selected Farmed Salmon Products$/lb)
     $7.00
     $6.00
     $5.00
     $4.00
     $3.00
     $2.00
     $1.00
     $0.00
                 -US average import
                  price, Canadian fresh
                  Atlantic fillets
                                                                          -US average import
                                                                           price, Chilean fresh
                                                                           Atlantic fillets
                                                                          -US average import
                                                                           price,Chilean frozen
                                                                           Atlantic fillets
                                                                           Source: NMFS
Figure 37. Average United States Import Prices of Selected Farmed Salmon Products
                  U.S. Wholesale Prices for Selected Wild and Farmed Salmon Products
                            reported in Urner Barry's Seafood Price Current
               — Fresh farmed Atlantic, pinbone-out fillets

             •*— Frozen H&G wild sockeye
Fresh farmed Atlantic, whole fish
         $6.00
               03030303030303030303030303030303030303030303
         $0.00
                             Source: Urner Barry Publications, Inc., Seafood Price Current.
  Figure 38. U.S. Wholesale Prices for Selected Wild and Farmed Salmon Products
                                               87

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Other factors which contributed to the increase in prices for Bristol Bay sockeye salmon after
2001 include the strengthening of exchange rates between the yen and the dollar and between the
euro and the dollar, diversification of markets for frozen sockeye, and the development of new
product forms, particularly fillets.

Unlike frozen salmon markets, canned salmon markets have not been directly affected by
competition from farmed salmon—because relatively little farmed salmon is canned. However,
canned salmon markets are influenced by frozen market conditions—and thus indirectly by
farmed salmon. When frozen prices are high, processors tend to freeze relatively more salmon
and can relatively less, which reduces the supply of canned salmon, causing canned salmon
prices to rise. When frozen prices are low, processors tend to freeze relatively less salmon and
can relatively more, which increases the supply of canned salmon, causing canned salmon prices
to fall. Put differently, the ability of processors to shift between freezing and canning salmon
causes frozen and canned salmon prices to tend to move together.

This can be seen in the decline in the downward trend in canned salmon prices in the early
1990s, and the upward trend since the early 2000s (Figure 37). However, many other factors
affect canned salmon prices, including in particular wild salmon harvests, exchange rates
between the dollar and the UK pound, and changing demand patterns for canned salmon.
               Monthly Average Wholesale Case Prices for Alaska Canned Sockeye Salmon
     0)
     en
     ro
     o
        $250
        $200
        $150
        $100
         $50
                                                                             •48 tails
•48
 halves
             OOOOOOOOOOO)O)O)O)O)O)O)O)O)O)OOOOOOOOOO^—  ^~
                  Source: Alaska Department of Revenue salmon price reports. Data prior to August 2000 are
                 statewide average canned sockeye prices; later data are average prices for Bristol Bay canned
                                         sockeye.
Figure 39. Monthly Average Wholesale Case Prices for Alaska Canned Sockeye Salmon.
                                            88

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Future Bristol Bay Salmon Prices
Since the beginning of 2011 prices of farmed Atlantic salmon have fallen sharply, in response to
oversupply of world markets as Chilean production has recovered (Figure 37 and Figure 38,
above).  Of great importance for the Bristol Bay salmon industry will be the extent to which
prices of Bristol sockeye salmon remain high, or alternatively follow the recent downward trend
in farmed salmon prices. At the time this report was written, it was too soon to tell how deep or
long the decline in farmed  salmon prices may be, or how much it may affect sockeye salmon
markets.

More generally, the future  outlook for Bristol Bay salmon prices is promising but uncertain.
There are several reasons for optimism, including growing demand for wild sockeye salmon in
the United States and Europe, the development of new higher-valued product forms (particularly
fillets), and improvements  in the quality of Bristol Bay salmon (discussed below). However, the
Bristol Bay salmon industry will face challenges in taking advantage of these new market
opportunities.  These include continued competition from farmed salmon and other new farmed
species, the logistical difficulties of market development given the wide variation in  annual
Bristol Bay catches, high costs of transportation and labor, and highly  concentrated seasonal
production which adds to costs and makes it difficult to slow down production and improve
quality.  These factors make it relatively easier for other regions of Alaska than for Bristol Bay to
take advantage of growing market opportunities for wild sockeye salmon.

Bristol Bay Salmon Quality

In an increasingly competitive world seafood industry, quality is of increasing importance.  An
important challenge for the Bristol Bay salmon industry has been a reputation for quality
problems. Many people in the industry believe these problems have historically kept wholesale
and ex-vessel prices lower than they would have been with better quality—although  it is difficult
to quantify how important  the effect of quality on prices has been.

Quality problems in the Bristol Bay fishery derive in part from handling practices such as those
depicted in these pictures posted on the internet. During the short, hectic and fast-paced Bristol
Bay season, fishermen have historically been focused on catching large volumes offish fast than
on handling fish carefully.  (In the highly quality-conscious salmon farming industry, it would be
unthinkable to step on fish.)
     Source: http://bbda. org/Stern_Load06.jpg
                 Source:
www. adn. com/static/includes/highliner/cowboys.jpg
                                           89

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Quality problems in the Bristol Bay fishery have been compounded by the absence of ice or
chilling capacity on many fishing boats; the logistics of tendering salmon long distances from
fishing grounds to processors, which makes it more difficult to separate fish which have been
handled carefully from those which have not (and to pay quality-conscious fisherman a
corresponding price premium); and the difficulty of processing salmon soon after they are
caught, especially during peak fishing periods.

Improving quality has been a primary focus of the Bristol Bay Regional Seafood Development
Association (BBRSDA), u a fishermen's marketing association for the drift gillnet fishery
financed by permit holders by means of a 1% assessment on the ex-vessel value of landings
(harvests). BBRDSA has undertaken a number of projects focused on encouraging chilling
(through icing and/or refrigerated sea water) as well as improved handling practices.  Annual
processor surveys funded by BBRDSA suggest that the share  offish which are delivered chilling
is increasing (Figure V-12).12
                  Estimated Chilled and Unchilled Shares of Bristol Bay Salmon Harvests
                                                                           Unchilled
                                                                          I Chilled
                      2008              2009             2010
                   Source: Northern Economics, 2010 Bristol Bay Processor Survey
    Figure 40. Estimated Chilled and Un-chilled Shares of Bristol Bay Salmon Harvests
11 BBRSDA was established in 2005. Fishermen voted for the 1% assessment in 2006.  Information about
BBRSDA may be found at www.bbrsda.com.
12 Northern Economics, 2010 Bristol Bay Processor Survey. Prepared for Bristol Bay Regional Seafood
Development Association, February 2011.  http://www.bbrsda.com/layouts/bbrsda/files/documents/
bbrsda_reports/BB-RSDA%202010%20Survey%20Final%20Report.pdf
                                            90

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                      Bristol Bay fishing boats waiting to unload to a tender
                               Photograph by Gabe Dunham
3.6 Bristol Bay Salmon Ex-Vessel and Wholesale Value

The decline in catches and prices during the 1990s led to a drastic decline in value in the Bristol
Bay salmon fishery. The nominal ex-vessel value paid to fishermen fell from a peak of $214
million in 1989 to just $32 million in 2002—a decline of 86%. The inflation-adjusted "real"
value (expressed in 2010 dollars) fell by an even greater 89% from a 1989 value of $359 million
to $39 million in 2002.
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        700
        600
                  Ex-Vessel and First Wholesale Value of Bristol Bay Sockeye Salmon
                               Harvests and Production,  1984-2010
-Real first
 wholesale value
 (2010$)
                                                                       -Nominal first
                                                                        wholesale value
                                                                    -0- Real ex-vessel
                                                                        value (2010$)
                                                                       •Nominal ex-
                                                                        vessel value
                                      Source: CFEC, ADFG
                Figure 41. Ex-Vessel and First Wholesale Value: 1984-2010

As catches and prices have improved after 2002, the Bristol Bay salmon industry experienced a
significant economic recovery.  Ex-vessel value increased to $181 million in 2010.  However,
this was well below the inflation-adjusted "real" value of the highest-value years of the late
1980s and early 1990s.

The first wholesale value of Bristol Bay salmon production exhibited similar trends over time as
ex-vessel value.  The nominal first wholesale value fell from a peak of $351 million in 1992 to
$100 million in 2002. As catches and prices improved, nominal wholesale value rose to a record
$390 million in 2010. Adjusted for inflation, however, the 2010 first wholesale value remained
well below the 1989 peak real wholesale value of $616 million.

The decline in value of the Bristol Bay fishery during the 1990s and the rise in value after 2002
was experienced by both processors and fishermen. Like the ex-vessel value to fishermen, the
value retained by processors after deducting payments to fishermen (sometimes called the
processors' margin) fell  dramatically during the 1990s and rose dramatically after 2002 (Figure
42).
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                        Distribution of Nominal Value of Bristol Bay Sockeye Salmon
          400.0
           350.0
                                        Source: CFEC, ADFG
•Total first
 wholesale
 value
                                                                          • Ex-vessel
                                                                           value received
                                                                           by fishermen
                                                                          •Value to
                                                                           processors
                                                                           after
                                                                           deducting
                                                                           payments to
                                                                           fishermen
          Figure 42. Distribution of Nominal Value of Bristol Bay Sockeye Salmon
The share of first wholesale value received by fishermen fell from 83% in 1988 to 32% in 2002
and then rose to 46% in 2010 (Figure 43).
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Distribution of Value of Bristol Bay Sockeye Salmon
1 nn% -,
80% - . _ _ - - -
pno/
/no/
ono/
no/
IIIIIIII
_ _ j \.\\-\\ iin -




^rcQcoocM^rcQcoocM^rcQco
cococooooooooooo
O5O5O5O5O5O5O5O5OOOOO
Source: CFEC, ADFG
-
o
o
CM

0 Value to
processors after
deducting
payments to
fishermen
• Ex-vessel value
received by
fishermen


              Figure 43. Distribution of Value of Bristol Bay Sockeye Salmon

The relative share of wholesale value received by fishermen and processors has been a subject of
contention between fishermen and processors.13 During the 1990s, fishermen argued that they
had experienced a disproportionate and unfair share of the decline in wholesale value.  Note,
however, that there is no economic reason to expect fishermen or processors' shares of gross
wholesale value to remain constant over time. Regardless of wholesale value, processors must
cover the costs of processing—which account for a relatively larger share of wholesale value as
wholesale value declines.

The loss in value during the 1990s led to a severe economic crisis in the Bristol Bay salmon
industry. As discussed above, as the value of the fishery declined, the prices of limited entry
permits plummeted and many fishermen stopped fishing their permits.  Similarly, many land-
based salmon processing operations closed and many floating processors left Bristol Bay.
13 The decline in the fishermen's share of ex-vessel value was a key issue in an unsuccessful class-action lawsuit
filed in 1995, in which Bristol Bay permit holders alleged that major processors and Japanese importers of Bristol
Bay salmon had conspired to fix prices paid to fishermen (Alakayak v. All Alaskan Seafoods, Inc). The author
served as an expert witness on behalf of the defendant processors and importers.

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3.7 Bristol Bay Salmon Fishermen

As discussed earlier, both the Bristol Bay drift gillnet fishery and the Bristol Bay set gillnet
fishery are managed under a "limited entry" management system which was implemented for all
of Alaska's twenty-seven salmon fisheries in the mid-1970s.  The basic purpose and effect of the
limited entry system is to limit the number of boats fishing in each fishery, which makes it easier
for managers to control the total fishing effort and makes the fishery more profitable for
participants than it would be if entry (participation) were unrestricted and more boats could fish.

There are approximately 1860 drift gillnet permits and approximately 1000  set net permits.
Every drift gillnet fishing boat or set net operation must have a permit holder on board or present
while fishing—so the number of boats or set net operations cannot exceed the number of permit
holders.

A permit represents a right (legally a revocable privilege) to participate in a fishery. Unlike
individual fishing quota (IFQ) or  catch-share systems which have been  implemented in some
United States fisheries, a permit does not restrict a permit-holder to catching a specific number of
fish. Fishermen may catch as many fish as they can—as long as they follow the numerous
regulations which restrict when, where and how they may fish.

When limited entry management was implemented in 1975, permits were allocated for free to
individuals who had historically participated in the fishery. Permit holders may hold permits in
perpetuity, although they must renew their permits each year for a nominal administrative fee.
Persons without permits can acquire them only by gift, inheritance, or by buying them from
existing permit holders.

Permit holders must register to fish in one of the five Bristol Bay fishing districts.  They may
transfer to fish in another district, but must wait 48 hours before fishing in the new district.

A "permit stacking" regulation implemented in 2004 for the drift gillnet fishery allows two
permit holders who opt to fish together on a single vessel to use 200 fathoms of drift gillnet gear
(an  additional 50 fathoms more than the usual limit of 150 fathoms). The objective of the
regulation was to allow two permit holders to team up to reduce their combined harvesting costs
to create a more profitable operation.

In addition to permit holders, there are an average of about two crew members for each drift
gillnet fishing boat and about two crew members for each set gillnet site.  Crew members are
usually paid a percentage share of gross earnings after deducting costs of food and fuel.  A
typical drift gillnet crew share is about  10%.14

The Commercial Fisheries Entry Commission (CFEC) maintains detailed public data about
salmon permit holders, including  their names, addresses, and vessel information. It also
14 Personal communicatiosn fo the author with numerous Bristol Bay permit holders and crew members.

                                           95

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publishes annual data on the total number of permits fished, total pounds landed, total gross
earnings, and average prices paid for permits sold.15

In contrast, almost no data are available about Bristol Bay crew members.  Although crew are
required to purchase an annual Alaska fishing crew license for a nominal fee, no data are
available about whether they participate in fishing, which fisheries they fish in, or how much
they earn. For this reason, most of the data presented in this section are about Bristol Bay permit
holders.  But keep in mind that about two-thirds of the people working in Bristol Bay fish
harvesting are crew members.

Fishery Participation

Until the late 1990s, most Bristol Bay permits were fished (Figure 44).  However, beginning in
the late 1990s, a growing number of permit holders stopped participating in the Bristol Bay
fishery, because they couldn't make enough money to cover their costs. In 2002—the lowest
year for Bristol Bay ex-vessel value since the start of the limited entry program in 1975—only
63% of drift gillnet permits and 66% of set gillnet permits were fished.

Since 2002, as the value of the fishery increased, fishery participation also increased, although
many permits remained unfished. In 2010, 80% of drift gillnet permits and 86% of set gillnet
permits were fished.
                      Number of Limited Entry Permits Issued and Fished in Bristol Bay
            O5O5O5O5O5O5O5O5O5O5OOOOOO
            T-T-T-T-T-T-T-T-T-T-CNCNCNCNCNCN

                         Source: CFEC Salmon Basic Information Tables
       Figure 44. Number of Limited Entry Permits Issued and Fished in Bristol Bay
 ' The data may be found at the Commercial Fisheries Entry Commission website:  http://www.cfec.state.ak.us/.

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Understanding the extent of participation in the Bristol Bay drift gillnet fishery since 2004 is
complicated by the permit-stacking option for the drift gillnet fishery, under which two permit
holders may opt to fish together (with an additional 50 fathoms of gear) from a single boat.
A CFEC analysis of the 2009 fishery, based on district registration data (both permit-holders in a
two-permit operation are required to register for fishing in that district) concluded that "for the
fishery as a whole, two-permit operations occurred on an estimated 20.9% (278) of the 1,331
vessels registered during the season and one-permit only operations occurred on 79.1% (1,053)
of the vessels. Of the 1,610 distinct permit holders who registered during the season, 34.7%
(558) were involved in a two-permit operation during the season, while 65.3% (1,052) were
involved in a one-permit operation only."16

Table 29 and Table 30 (on the following page) provides selected indicators of participation in the
Bristol Bay drift gillnet fishery in 2009, based on various measures reported by CFEC. A total
of 1863 permits were issued to 1838 permit holders.  Of these, 1610 registered to fish during the
season in one or more of the Bristol Bay fishing districts.  Of these an estimated 1052 fished
alone and 558 fished with another permit holder. Of those who fished with another permit
holder, an estimated 401 reported landings on their permits while 157 reported no landings on
their permits (all of the operation's landings were reported on the other permit holder's permit).

Thus the CFEC data for the "number of permits fished," shown in Figure 44 above (1453 in
2009), overstates the number  of boats which fished (1331 in 2009), but understates the number
of permit holders who participated in the fishery (1610 in 2009).
16 Schelle, K., N. Free-Sloan, and C. Farrington, "Bristol Bay Salmon Drift Gillnet Two-Permit Operations:
Preliminary Estimates from 2009 District Registration Data (CFEC Report No. 09-6N, 2009).
http://www.cfec.state.ak.us/RESEARCH/09-6N^r_fmal_v4_121409.pdf.

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Table 29. Selected Indicators of Participation in 2009 Drift Gillnet Fishery
      Selected Indicators of Participation in the 2009 Bristol Bay Drift Gillnet Salmon Fishery
Row
1
2
3
4
5
6
7
8
9
10
Indicator
Total permits issued
Number of permit holders
Number of distinct permit holders who registered during the season
Estimated number involved in a one-permit operation only during the season
Estimated number involved in a two-permit operation during the season
Number of fishermen who fished (reported landings on their permits)
Total permits fished (with reported landings)
Number of vessels registered during the season
Estimated number on which only one-permit operations occurred
Estimated number on which two-permit operations occurred
Source
a,b
b
c
c
c
b
a,b
c
c
c
Number
1,863
1,838
1,610
1,052
558
1,453
1,444
1,331
1,053
278
 (a) CFEC, Salmon Basic Informaton Tables, Bristol Bay Drift Gillnet Salmon Fishery,
 http://www.cfec.sMe.ak.usMt/X_S03T.HTM.
 (b) CFEC, "Permit & Fishing Activity by Year, State, Census Area or City," data for "Grand Total:  All
 Fishermen Combined", http://www.cfec.state.ak.us/gpbycen/2009/00_ALL.htm.
 (c) Schelle, K., N. Free-Sloan, and C. Farrington, "Bristol Bay Salmon Drift Gillnet Two-Permit
 Operations: Preliminary Estimates from 2009 District Registration Data (CFEC Report No. 09-6N, 2009).
 http://www.cfec.state.ak. us/RESEARCH/09-6N/bbr_final_v4_121409.pdf.
Table 30. Estimated Number of 2009 Drift Gillnet Permit Holders who Fished Alone, With
another Permit Holder, or Did Not Fish
        Estimated Numbers of 2009 Drift Gillnet Permit Holders Who Fished Alone,
                    Fished with Another Permit Holder, or Did Not Fish
Number of permit holders who:
Fished alone
Fished with another permit holder
Fished with another permit holder and reported landings
As the only permit holder who reported landings
With both reporting landings
Fished with another permit holder but did not report landings
Held permit but did not fish it
TOTAL NUMBER OF PERMIT HOLDERS
Estimates
1,052
558
401
722
279
157
228
1,838
How calculated*
4
5
5 - (3 - 6)
6-8
5 - (3 -6) - (6-8)
3 -6
2-3
2
 *Numbers refer to rows in the previous table.

Distribution of Earnings

In both the drift gillnet and set gillnet fisheries, each year there is wide variation among permit
holders in average earnings, reflecting differences in vessel size, fishing style, fishing experience
and skill, how aggressively and for how long they fish, what fishing districts they choose to fish
in, and good or bad luck. These differences are reflected in average earnings among four
                                             98

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"quartile" groups of permit holders, each of which accounts for one quarter of total Bristol Bay
earnings.

In the drift gillnet fishery, typically, the first quartile has about one-third to one-fourth as many
fishermen as the fourth quartile, earning on average of about three to four times as much (Figure
45).
                      Average Gross Earnings of Bristol Bay Drift Gillnet Permit Holders,
                                           by Quartile
          $250,000
                   O5O5O5O5O5O5O5O5O5O5O5O5O5OOOOO
                                                                            -•-First
                                                                               quartile

                                                                            -*— Second
                                                                               quartile

                                                                            -•-Third
                                                                               quartile

                                                                            -*- Fourth
                                                                               quartile
                             Source: Commercial Fisheries Entry Commission quartile tables
       Figure 45. Average Gross Earnings of Bristol Bay Drift Gillnet Permit Holders

Average earnings in the set gillnet fishery are much lower than in the drift gillnet fishery. The
highest earning "first quartile" set gillnet permit holders earn about half as much as the "first
quartile" drift gillnet permit holders (Figure 46).  There is a wider range of variation in earnings
of set net permit holders, reflecting in part wide differences in the number offish swimming past
set net sites in different Bristol Bay locations.
                                              99

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                     Average Gross Earnings of Bristol Bay Set Gillnet Permit Holders,
                                          by Quartile
        $120,000
                                                                             -•-First
                                                                                quartile


                                                                             ^^ Second
                                                                                quartile


                                                                             -•-Third
                                                                                quartile


                                                                             -*-Fourth
                                                                                quartile
                 O5O5O5O5O5O5O5O5O5O5O5O5O5
T-  co  LO h-  a>
o  o  o o  o
o  o  o o  o
CM  CM  CM CM  CM
                           Source: Commercial Fisheries Entry Commission quartile tables
       Figure 46. Average Gross Earnings of Bristol Bay Set Gillnet Permit Holders
Permit Prices

The prices paid for Bristol Bay permits have fluctuated dramatically over time. Expressed in
nominal dollars, average prices paid for drift gillnet permits rose from $66,000 in 1980 to
$249,000 in 1989, fell to $20,000 in 2002, and rose again to $102,000 in 2010. Average prices
paid for set gillnet permits rose from $29,000 in 1980 to $65,000 in 1989, fell to $12,000 in
2002, and rose again to $29,000 in 2010.
                                             100

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                        Average Prices Paid for Bristol Bay Limited Entry Permits
          $250,000
                                                       CM  "3"  CD  00  O
                                                       O  O  O  O
                  rorororororororororooooooo

                             Source: CFEC Salmon Basic Information Tables
           Figure 47. Average Prices Paid for Bristol Bay Limited Entry Permits
Bristol Bay limited entry permit prices are clearly strongly related to total earnings in the fishery.
In both fisheries, trends over time in permit prices closely track trends over time in total earnings
(Figure 48 & Figure 49). Economic theory suggests that permit prices would be driven by
fishermen's expectations of future profits from the fishery.  The close relationship between total
earnings and  permit prices suggests that expectations of future profits are driven by trends in
average profits in recent years.

Costs of Fishing

Not all Bristol Bay permit holder earnings are profits, of course.  Permit holders face significant
costs of fishing,  some of which are relatively fixed regardless of the volume or value of their
catch—which makes fishing profits relatively more volatile than earnings.

No data are collected on a regular basis on the costs faced by Bristol Bay permit holders. From
time to time,  studies have estimated costs of fishing based on  surveys of Bristol Bay permit
holders.  However, it is difficult to characterize fishing costs, for several reasons.  First, costs
may vary widely between fishing operations, because of differences in factors such as vessel
size, number of crew, how and where permit holders  fish, and where permit holders and crew
live. Second, costs may vary significantly from year to year due to changes in prices of fuel,
insurance and other inputs to fishing.  Third, fixed costs such as vessel storage and insurance
may vary widely from year to year when expressed on a per-pound basis due to changes in
harvest volumes.
                                            101

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                    Average Permit Prices and Total Earnings:  Bristol Bay Drift Gillnet Fishery
                           •Average permit price ($)
                                              -0-Total earnings ($ million)
          $250,000
          $200
                                                                      \
                                                                            $200
        Q.

       ±i





        &

        0
        D)

        &
        
-------
Figure 50 summarizes the estimated 2008 fishery-wide distributions of operating costs and
incomes to Bristol Bay permit holders and crew reported by the Anchorage-based economic
consulting firm Northern Economics in a recent detailed study of the importance of Bristol Bay
salmon fisheries to the Bristol Bay region and its residents, conducted for the Bristol Bay
Economic Development Corporation.  The estimates were based on updates of estimates of
previous analyses by CFEC and Northern Economics to account for changes in fuel prices and
other costs.  A review of the details of how the estimates were prepared and their limitations is
beyond the scope of this report.  We include them here as a general indicator of the kinds of costs
which are important in the fishery and their approximate magnitudes relative to 2008 earnings.
Note that operating costs in both fisheries include fuel and oil, net maintenance, gear, boat and
net storage, transportation, food, insurance, taxes, fees and services. Permit holders also face
costs of crew share payments (about 10% of gross earnings per crew member, after deducting
costs of fuel and  food), as well as loan payments for permits and boats.
                          All Drift Net Vessels
   Transport & Food
      6%  Fuel & Oil
           4%
                        Income toCrewS
                       Permit Holders (Incl.
                        Loan Payments)
                          74%
                                                         Maintenance Nets,
                                                          Gear& Storage
                                                             10% "
                                                            nsurance. Taxes.
                                                            Fees, & Services
                           All Set Net Vessels
Transport & Food
    CO/
       Fuels, Oil
         2%
                                                        Maintenance Nets,
                                                        Gear & Storage
                                                           10%
                                                           Insurance, Taxes.
                                                           Fees, & Services
                                                               3%
                        Income to CrewS
                       Perm it Holders (Incl
                        Loan Payments)
      Figure 50. Northern Economies' Estimates of the Breakdown of Operating Costs
       and Incomes to Crew and Permit Holders, Bristol Bay Salmon Fisheries, 2008
Source: Northern Economics, The Importance of the Bristol Bay Salmon Fisheries to the Region and its Residents
(report prepared for the Bristol Bay Economic Development Corporation, October 2009).  Estimates based in part
on earlier analyses by Northern Economics and CFEC.
                                            103

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3.8 Bristol Bay Salmon Processors

Fish processing is an integral part of the Bristol Bay commercial salmon industry, employing
approximately half as many people as fish harvesting and more than doubling the value of the
fish.

Bristol Bay salmon are processed in both land-based processing facilities and on floating
processors. Salmon are canned only in large land-based facilities, which also have salmon
freezing capacity. Floating processors produce only frozen salmon. As discussed, the Bristol
Bay salmon processing industry typically employs about 3000 to 4000 workers annually at the
height of the salmon processing season—depending upon the size of the harvest. Of these, fewer
than 5% are residents of the Bristol Bay region. Another 10% to 15% are residents of other parts
of Alaska, and about 75% to 80% are residents of other states or countries.  Most are relatively
unskilled short-term workers:  only about 20% work in Bristol Bay for more than five years.
Almost all live in bunkhouses provided by the processing companies.
                                Yardarm Knot Cannery, Naknek
      Source: http://vw.yardarm.net/red%20salmon%20cannery/cannery%20home4Jiles/image301.jpg

                 Icicle Seafoods' Floating Processor Bering Star in the Nushagak River
             (the ship on the left is a cargo vessel loading frozen salmon for shipment to Japan)
                                           104

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In 2010, six companies operated salmon canning facilities in Bristol Bay.  These included some
of the largest seafood processing companies operating in Alaska, such as Trident Seafoods,
Ocean Beauty Seafoods, Icicle Seafoods and Peter Pan Seafoods. Most of these companies have
both land-based and floating processing operations in many parts of Alaska, which process not
only salmon but other major Alaska species as well, such as pollock, crab and halibut. All large
processors have home offices in or near Seattle.

In 2010, all of the processors with canning facilities, and five other larger processors purchased
salmon in multiple Bristol Bay districts. There were twenty-five other buyers and smaller
processors who bought salmon in just one district.

Most of the land-based  processing facilities in the Bristol Bay region are located in or near a
small number of communities with regularly-scheduled air transportation. The largest number of
processors are located in Naknek along the Naknek River. Most of the other land-based facilities
are in Dillingham, Egegik and Togiak.

Bristol Bay salmon processing is not an easy business.  The list of companies buying and
processing salmon in Bristol Bay changes from year to year. The number of large processors
operating in Bristol Bay declined in the 1990s, reflecting consolidation in the industry forced by
harvest volumes and lower profits.  Many land-based processing plants closed and the number of
floating processors brought into Bristol Bay each year to process salmon also declined sharply.
This consolidation helped to make the industry more efficient and more profitable.
                  Number of Companies Reporting Salmon Production in Bristol Bay,
                                        by Product
           00000000000005050505050505050505
           O5O5O5O5O5O5O5O5O5O5O5O5O5O5O5O5
OOOOOOOOOO
00000000000
0101010101010101010101
                       Source: ADF&G Commercial Operator Annual Reports
Figure 51. Number of Companies Reporting Salmon Production in Bristol Bay, by Product
                                           105

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Fish account for the largest share of costs of Bristol Bay processors.  Other important costs
include labor, fish tendering, packaging (boxes and cans), transportation of products and
workers, utilities and taxes, maintenance, and costs of equipment and buildings.

Another important "cost" is the adjustment for the yield from the "round pound" weight offish
purchased from fishermen to the "processed pound" weight offish products.  In effect, for any
given ex-vessel prices, the lower the yield, the higher the cost offish per pound of final product
weight.

Costs per pound vary between product forms and may also vary widely from year to year as
fixed costs are spread over different volumes of salmon. Table 31 provides rough estimates of
Bristol Bay salmon processing costs from an analysis for 1994 and 1995. Note that costs have
likely risen  considerably since these estimates were prepared, due to changes in costs of labor,
energy and  other factors. However, salmon ex vessel prices are highly variable and not directly
tied to general changes in price levels. Therefore the Table 31 data is provided as a picture of
two specific years, and not indexed to current price levels.
Table 31. Estimates of Bristol Bay Processor Costs, Prices and Profits
               Estimates of Bristol Bay Processor Costs, Prices, and Profits: Mid-Range Estimates for 1994 and 1995

Price paid to fishermen
+ Taxes and assessments
+ Tender cost
+ Costs of services to fishermen
= Fish cost per round Ib.
- Roe value per round Ib. (= roe yeild x roe price)
= Fish cost per round Ib., net of roe value
T Processing yield
= Fish cost per processed Ib., net of roe value
+ Processing costs per processed Ib.
+ Transportation and storage costs before sale
+ Other costs
= Processor's total cost
Average price received by processor
Profit or loss (= average price - total cost)
per processed Ib.
per round Ib.
Frozen Dressed
1994 1995
$0.97 $0.75
$0.03 $0.02
$0.17 $0.17
$0.03 $0.03
$1.20 $0.97
$0.09 $0.09
$1.11 $0.88
74% 74%
$1.51 $1.20
$0.60 $0.60
$0.00 $0.00
$0.10 $0.10
$2.21 $1.90
$2.45 $1.80
$0.24 -$0.10
$0.18 -$0.07
Frozen Round
1994 1995
$0.97 $0.75
$0.03 $0.02
$0.17 $0.17
$0.03 $0.03
$1.20 $0.97
$0.00 $0.00
$1.20 $0.97
97% 97%
$1.24 $1.00
$0.40 $0.40
$0.00 $0.00
$0.10 $0.10
$1.74 $1.50
$2.20 $1.00
$0.46 -$0.50
$0.45 -$0.49
Canned
1994 1995
$0.97 $0.75
$0.03 $0.02
$0.17 $0.17
$0.03 $0.03
$1.20 $0.97
$0.07 $0.07
$1.13 $0.90
59% 59%
$1.92 $1.53
$0.73 $0.73
$0.10 $0.10
$0.10 $0.10
$2.85 $2.46
$2.71 $2.80
-$0.14 $0.34
-$0.08 $0.20
Note: Costs and prices can vary widely between processors. Any given processor's profits or lesses could be higher or lower than showin in this table.
Source: Currents: A Journal of Salmon Market Trends, University of Alaska Anchorage, Salmon Market Information Service, December 1995.
                                             106

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                      Selected Bristol Bay Salmon Processor Costs, 2001-2009
       "o
       T3
          300
          250
          200
          150
          100
                                                III
       =   50
•Ufl
                                                I Other costs
                                                 and profits
                                                0 Cost of labor
                                                 (fish processing
                                                 earnings)
                                     I Cost of fish
                                      (ex-vessel
                                      value)
               8
               CM
      CM
      8
      CM
CO
8
CM
8
CM
in
8
CM
CD
8
CM
8
CM
00
8
CM
O)
8
CM
                                  Source: ADFG.ADLWD
           Figure 52. Selected Bristol Bay Salmon Processor Costs, 2001-2009

Most larger Bristol Bay salmon processors contract with tender vessels to transport salmon from
fishing vessels at or near the best fishing areas to land-based or floating processing facilities.
Tendering represents a significant cost for the industry. Many tender vessels are larger vessels
used seasonally in other Alaska fisheries such as the Bering Sea crab fisheries.  No data are
available on the number of tender vessels used in the Bristol Bay fishery. A rough guess is that
there are about fifty.
Fishermen delivering salmon to a tender. As fish are
caught, they are placed in broiler bags in the hold of
the fishing boat. Here, a broiler bag is being hoisted
aboard a tender, where the fish are kept in refrigerated
water during transport to the processor.
                            Fish are pumped from tenders into processing plants
         Photograph by Gabe Dunham
                                                  Photograph by Gabe Dunham
                                       107

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    Sockeye salmon entering a processing plant
Workers cleaning salmon
                                             Packaging is an important cost offish processing
3.9 Bristol Bay Salmon Industry Employment

Challenges in Measuring Bristol Bay Salmon Industry Employment

Measuring employment in the Bristol Bay salmon industry is complicated by several factors.
First, no employment data are collected for commercial fishing comparable to the employment
data collected for most other industries. This is because commercial fishermen (both permit
holders and crew) are considered self-employed, and they do not pay unemployment insurance.
Employment data for most industries (including fish processing) are based on unemployment
insurance reporting forms filed by employers.  To make up for this significant gap in Alaska
employment data, as discussed below, the Alaska Department of Labor and Workforce
Development (ADLWD) Research and Analysis Division estimates monthly commercial fishing
employment by multiplying the number of permits for which fish landings are reported each
month by assumed average employment per permit fished (crew factors).
                                        108

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Second, the Bristol Bay salmon industry is highly seasonal. Most of the fishing and processing
occurs between the middle of June and the middle of July, with smaller numbers of fishermen
and processing workers engaged in smaller-scale fishing and processing as well as  start-up and
close-down activities earlier and later in the year. Thus a Bristol Bay fishing or processing job
which typically lasts less than two months is not directly comparable to a year-round job in
another industry. As discussed below, to provide a basis for comparing employment in the
Bristol Bay salmon industry with year-round employment in other industries, we estimate
"annual average employment," calculated as the total number of months worked divided by 12.

Third, the "Bristol Bay Region" for which ADLWD reports fish processing employment and
estimated salmon fishing employment includes the  Chignik salmon fishery—an important
Alaska salmon fishery although much smaller than  the Bristol Bay fishery. By way of
comparison, between 2006 and 2010, expressed as  a percentage of the Bristol Bay salmon
fisheries, total pounds landed in the Chignik salmon fishery were 7.7% of Bristol Bay, earnings
were 6.3% of Bristol Bay, and total permits fished were 2.4% of Bristol Bay. Thus  ADLWD fish
harvesting and processing employment estimates and data for the "Bristol Bay region" slightly
overestimate employment for the Bristol Bay salmon fishery.

Fourth, estimates offish processing employment are not available by fishery—because in
reporting employment fish processing plants do not distinguish between the species offish that
their workers were processing during the reporting  period. Thus fish processing employment
estimates for the Bristol Bay region include some employment in processing other species such
as herring. However, it is likely that fish processing employment data for the Bristol Bay region
are overwhelmingly dominated by Bristol Bay salmon.  For a comparison of the relative  scale of
the two fisheries, between 2006 and 2010, expressed as a percentage of the Bristol Bay salmon
fisheries, total pounds landed in the Bristol Bay (Togiak) herring seine and gillnet fisheries
22.6% of pounds landed in the Bristol Bay salmon fisheries, earnings were 2.1% of earnings in
the salmon fisheries, and the total permits fished were 2.6% of permits fished in the salmon
fisheries. Note also that Bristol Bay herring processing is much less labor intensive than salmon
processing because Bristol Bay herring are entirely frozen round for export.
Terminology for Measures of Employment

In the subsequent discussion, we use the following terms for different kinds of employment
estimates:

       Jobs:                        The number of distinct work positions
       Workers:                    The number of different individuals who worked
       Annual average employment   The number of months worked divided by 12

For example, suppose a permit holder fishes for two months with two crew members on board
his boat.  After one month one crew member leaves and is replaced by another crew member.
The permit holder's operation would account for 3 jobs, 4 workers, and annual average
employment of 0.5 (3 jobs x 2 months = 6 job months which is 6/12 or 0.5 job years).
                                          109

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Estimates of Bristol Bay Salmon Harvesting and Processing Employment

Table 32 (on the following page) summarizes available estimates of Bristol Bay salmon
harvesting and processing employment from several different sources calculated in several
different ways. Figure 53 (on the subsequent page) graphs several of the estimates shown in
Table 32.

Estimated fishing jobs based on salmon permits fished (Rows 1-4)

A simple way to estimate Bristol Bay salmon fishing jobs is from Commercial Fisheries Entry
Commission (CFEC) data for the number of permits fished and the Alaska Department of Labor
and Workforce Development (ADLWD) assumption of three jobs for each drift gillnet and each
setnet fishing operation.1? Based on this methodology, between 2000 and 2010, the number of
Bristol Bay salmon fishing jobs ranged between 5592 and 8232. The estimated number of jobs
varied from year to year because the number of permits fished varied from year to year.

A problem with this method of estimating fishing jobs is that since the introduction of "permit
stacking" in the drift gillnet fishery, there is no longer necessarily a direct relationship between
the number of permits fished and the number of vessels fished.  As discussed, the number of
permits fished each year likely understates the number of permit holders who fished but likely
overstates the number of vessels which fished (since some permit holders fished together on the
same vessel).

CFEC reported that 1444 permits were fished in 2009, but only 1331  vessels were registered to
fish during the season. This would imply that the number of permits  fished overstated that
number of vessels fished by  113, which would in turn imply that the estimates in Row 4
overstate the number of fishing jobs  by 339. For the same reason, the estimates in rows 6 and 9-
12 of Table 32 (discussed below) may also slightly overestimate the number of fishing workers.
17 According to a table of crew factors provided to Gunnar Knapp by ADLWD in 2004 (crewfactor.xls), ADLWD
assumed crew factors of 3.0 for both the Bristol Bay drift gillnet and set gillnet fisheries.

                                          110

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Table 32. Indicators and Estimates of Bristol Bay Salmon Industry Fishing Processing
Employment

                  Indicators and Estimates of Bristol Bay Salmon Industry Fishing and Processing Employment, 2000-2010
Measure
Estimated fishing jobs based on salmon
permits fished (a)
Permits fished, drift gillnet fishery
Permits fished, set gillnet fishery
Permits fished, total
Estimated number of fishing jobs (= permits
fished x 3 jobs/permit fished)
ADLWD estimates of Bristol Bay region
salmon fishing workers (b)
[ndivi duals who fished permits
Total estimated workforce
Ratio of estimated workforce to individuals
who fished permits
Estimated crew workers
ADLWD estimates of Bristol Bay region
salmon fishing workers by month (c)
June
July
August
September
Bristol Bay region fish processing workers,
all species (d)
Total worker count
Bristol Bay region food manufacturing
employment (e)
July
Annual average
Assumed total salmon industry workers
Fishing (July employment) (Row 10)
Processing (total worker count) (Row 13)
Total
Estimated annual average
salmon industry employment
Fishing
(= total months of employment / 12)
Fish processing (f)
Total
Row

1
2
3
4

5
6
7
8

9
10
11
12

13
14
15

16
17
18

19
20
21
2000

1,823
921
2,744
8,232





















2001

1,566
834
2,400
7,200

2,412
6,969
2.89
4,557

6,771
7,098
276
0

2,862


7,098
2,862
9,960

1,179
475
1,654
2002

1,184
680
1,864
5,592

1,867
5,334
2.86
3,467

4,830
5,514
309
0

2,273
2,414
765

5,514
2,273
7,787

888
366
1,254
2003

1,424
761
2,185
6,555

2,196
6,324
2.88
4,128

6,045
6,465
249
0

2,484
3,026
992

6,465
2,484
8,949

1,063
409
1,472
2004

1,411
795
2,206
6,618

2,210
6,294
2.85
4,084

6,093
6,513
375
84

3,474
4,189
1,139

6,513
3,474
9,987

1,089
581
1,669
2005

1,447
829
2,276
6,828

2,286
6,444
2.82
4,158

6,135
6,750
279
15

3,272
3,946
1,147

6,750
3,272
10,022

1,098
532
1,631
2006

1,475
844
2,319
6,957

2,340
7,020
3.00
4,680

6,201
6,936
540
3

2,940
4,391
1,339

6,936
2,940
9,876

1,140
483
1,623
2007

1,468
835
2,303
6,909

2,239
6,717
3.00
4,478

5,982
6,891
444
0

3,512
4,480
1,385

6,891
3,512
10,403

1,110
566
1,675
2008

1,469
850
2,319
6,957

2,245
6,735
3.00
4,490

6,060
6,969
504
12

3,952


6,969
3,952
10,921

1,129
640
1,769
2009

1,444
843
2,287
6,861

2,309
9,236
4.00
6,927

6,393
6,768
504
54

4,522


6,768
4,522
11,290

1,143
764
1,907
2010

1,494
861
2,355
7,065





















 Sources and notes: (a) CFEC Salmon Basic Information Tables, http://www.cfec.state.ak.us/bit/MNUSALM.htm; (b) ADLWD, "Fish Harvesting Workforce and
 Gross Earnings by Species, 2001 - 2009,"
 http://www.labor.state.ak.us/research/seafood/BristolBay/BBFHVWrkrEmgSpec.pdf. Estimated crew workers= Total estimated workforce - Individuals who
 fished permits, (c) ADLWD, "Fish Harvesting Employment by Species and Month, 2000-2009, Bristol Bay Region,"
 http://labor.alaska.gov/research/seafood/BristolBay/BBAvgMonthlyRegSpc.pdf; (d) ADLWD, "Bristol Bay Region Seafood Industry, 2003-2009, Processing,"
 http://labor.alaska.gov/research/seafood/BristolBay/BBSFPOver.pdf. 2001 & 2002 data are earlier estimates formerly posted at the same website; (e) ADLWD,
 Quarterly Census of Employment and Wages Data, http://labor.alaska.gov/research/qcew/qcew.htm; (f) annual average fish processing employment estimated by
 assuming the same ratio of annual average employment to total worker count as the ratio of estimated annual average fishing employment to July fishing
 employment.



ADLWD estimates of Bristol Bay region salmon fishing workers (rows 5-8)


These are ADLWD estimates of the salmon harvesting workforce (number of workers) in the
                                                   i &
Bristol Bay region for the years  2001-2009.    Note that these include workers  in the Chignik

salmon fishery. The total estimated workforce (row 6) was estimated by multiplying the number
  The estimates are posted at http://labor.alaska.gov/research/seafood/BristolBav/BBFHVWrkrErngSpec.pdf. A
discussion of the methodology used to prepare the estimates is posted on the ADLWD website at:
                                                       111

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                                                                                    19
of individuals who fished permits (row 5) by assumed crew factors for each fishery. y We
calculated estimated crew workers (row 8) by subtracting individuals who fished permits (Row
5) from the total estimated workforce (row 6).
              Selected Estimates of Bristol Bay Salmon Fishing and Processing Workers
    12,000
    10,000
     8,000
    6,000
    4,000
    2,000
                                     •Assumed total fishing and
                                      processing workers
                                      (Row 18)

                                     - Estimated fishing jobs
                                      (Row 4)
                                     -Estimated July salmon fishing
                                     workers
                                     (row 10)

                                     -Estimated fishing workforce
                                     (Row 6)
                                     -Food manufacturing July
                                      employment
                                      (Row 14)

                                     -Fish processing worker count
                                      (Row 13)
            O   T-    CM
            O   O    O
            O   O    O
            CM   CM    CM
o
O
CM
CD
O
O
CM
O
O
CM
OO    O>    O
O    O    T-
O    O    O
CM    CM    CM
 Note: Row numbers
refer to previous table.
    Figure 53. Selected Estimates of Bristol Bay Salmon Fishing and Processing Workers
ADLWD estimates of Bristol Bay region salmon fishing workers by month (Rows 9-12)


These are ADLWD estimates of the salmon harvesting workforce (number of workers) by month
in the Bristol Bay region for the years 2001-2009.20  The methodology used for these estimates
http://labor.alaska.gov/research/seafood/Methodologv.pdf.  Additional discussion of the methodology is provided in
Josh Warren and Rob Kreiger, "Fish Harvesting in Alaska (Alaska Economic Trends, November 2011); Josh
Warren and Jeff Hadland, "Employment in Alaska's Seafood Industry" (Alaska Economic Trends, November 2009);
and Paul Olson and Dan Robinson, "Employment in the Alaska Fisheries: A special project estimates fish
harvesting jobs" (Alaska Economic Trends, December 2004),   These articles are posted on the ADLWD website at
http://labor.alaska.gov/trends/.
19 No documentation was provided as to what crew factors were used for these estimates.  The ratio of estimated
workforce to individuals who fished permits (Row 7) suggests that crew factors of 3.0 were used for the years 2006-
2009.  It is not clear why the ratio was lower for the years 2001-2005 (between 2.82-2.89) and much higher for 2009
(4.00), suggesting that different crew factors were used for these years.  The estimate for 2009, based on a 25%
higher crew factor of 4.0, is indicated with a dashed line in Figure 53.
20 The estimates are posted at http://labor.alaska.gov/research/seafood/BristolBay/BBAvgMonthlyRegSpc.pdf.
                                               112

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was similar but not identical to that used to for the estimates of salmon fishing workers in rows
5-8), resulting in slightly higher estimates.21

Bristol Bay region fish processing workers, all species (Row 13)

These are ADLWD estimates of the total worker count for Bristol Bay region seafood
processing.22'23

Bristol Bay region food manufacturing employment (Rows 14 & 15)

These are the sum of ADLWD data for food manufacturing employment in Bristol Bay Borough,
Lake and Peninsula Borough, and the Dillingham Census Area (the ADLWD's Bristol Bay
region).24 Table 33 provides the same detail in more detail, by month. Presumably, almost all
food manufacturing in the Bristol Bay region is fish processing. It is not clear why the July food
manufacturing employment (Row 14) is considerably larger than the total worker count for fish
processing for the same region (Row 13).

Assumed total salmon industry workers (Rows  14 & 15)

For the purposes of this report, we assume that the total  number of workers in the Bristol Bay
salmon industry is July salmon fishing workers (Row 10) and the ADLWD total worker count
(Row 13).  The inconsistencies between the different estimates discussed above suggest that
while these should be considered  reasonable indicators of the general magnitude of the number
rather than precise data.  In general, it appears reasonable to assume that in recent years the total
number of workers in Bristol Bay salmon fishing and processing has exceeded 10,000.

Estimated annual average salmon industry employment  (Rows 19-21)

These are estimates of salmon industry annual average employment,  or job months / 12. Again,
these should be considered reasonable indicators of the general magnitude of annual average
employment rather than precisely accurate data. In general,  it appears reasonable to assume that
in recent years average annual employment in Bristol Bay salmon fishing and processing has
exceeded 1600.
21 According to notes provided with the estimates, for these estimates "... the permit itself is considered the
employer. In other tables where a count of workers was estimated, the employer was considered to be the vessel, or
permit holders for fisheries that did not typically use vessels. This means that a permit holder who makes landings
under two different permits (in the same vessel) in the same month will generate two sets of jobs whereas for tables
where the vessel is the employer there would be only one set of workers."
22 The data are posted at http://labor.alaska.gov/research/seafood/BristolBay/BBSFPOver.pdf.
23 The only information about how the data source or methodology is the following: "The Alaska Department of
Labor and Workforce Development's Occupational Database (ODB) is the primary source of seafood processing
employment data. The ODB contains quarterly information for all Alaska workers covered by unemployment
insurance (UI)." (http://labor.alaska.gov/research/seafood/Methodology.pdf).
24Quarterly Census of Employment and Wages Data posted at http://labor.alaska.gov/research/qcew/qcew.htm.

                                            113

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Seasonally of Bristol Bay Fish Processing Employment

ADLWD monthly data for Bristol Bay food manufacturing employment provide an indication of
the seasonality and geographic distribution of Bristol Bay salmon processing (Figure 54 and
Table 33).  Presumably salmon processing accounts for most but not all of Bristol Bay region
food manufacturing employment. One indicator of this is that for the years 2001-2009, the total
fish harvesting workforce for other fisheries for which ADLWD reported Bristol Bay region
harvesting workforce estimates, expressed as a percentage of the salmon harvesting workforce
estimates, averaged 5.5% for herring, 2.1% for halibut and 0.4% for sablefish.25

Bristol Bay region food manufacturing employment peaks in July, and is generally much higher
during the months from May through September than at other times in the year. Note that a
significant part of the work in fish processing occurs before the season starts (getting ready for
processing) and after the season ends (closing down processing operations and preparing for the
next season).  Some people are employed throughout the year in activities such as plant
maintenance and repair.
                Monthly Employment in Food Manufacturing, Bristol Bay Region, 2002-2007
     5,000
     4,000
     3,000
     2,000
     1,000
2007
2006
2005
2004
2003
2002
                      Source: Alaska Department of Labor and Workforce Development
       Figure 54. Monthly Employment in Food Manufacturing, Bristol Bay Region
25 ADLWD, "Fish Harvesting Workforce and Gross Earnings by Species, 2001-2009, Bristol Bay Region,"
http://labor.alaska.gov/research/seafood/BristolBay/BBFHVWrkrErngSpec.pdf.
                                           114

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Table 33. Monthly Employment in Food Manufacturing, by Borough or Census Area.
             Monthly Employment in Food Manaufacturing, by Borough or Census Area, Bristol Bay Region, 2002-2010
Area Month






Bristol Bay
Borough

























T

B
oroug










Total








Units reporting
January
February
March
April
May
June
July
August
September
October
November
December
Average
Units reporting
January
February
March
April
May
June
July
August
September
October
November
December
Average
Units reporting
January
February
March
April
May
June
July
August
September
October
November
December
Average
Units reporting
January
February
March
April
May
June
July
August
September
October
November
December
Average
2002
8
7
8
8
441
495
713
977
325
51
42
29
34
261
4
283
529
590
455
372
384
1,091
392
347
283
149
48
410
7
20
21
19
23
53
222
346
278
87
15
13
28
94
19
310
558
617
919
920
1,319
2,414
995
485
340
191
110
765
2003
9
52
56
57
197
464
1,115
1,915
1,291
728
41
49
22
499
3
124
512
495
373
390
339
775
544
618
270
260
84
399
5
10
34
11
40
53
191
336
329
90
14
10
8
94
17
186
602
563
610
907
1,645
3,026
2,164
1,436
325
319
114
992
2004
11
11
10
21
81
678
1,299
2,644
1,250
834
46
59
46
582
3
184
519
496
451
285
739
1,035
544
552
331
253
147
461
5
5
5
11
27
52
258
510
250
18
8
7
6
96
19
200
534
528
559
1,015
2,296
4,189
2,044
1,404
385
319
199
1,139
2005
14
11
12
19
81
818
1,365
2,663
1,424
847
68
72
51
619
4
123
543
507
377
392
799
1,057
694
567
306
257
82
475
4
4
4
5
9
38
171
226
135
17
11
9
10
53
22
138
559
531
467
1,248
2,335
3,946
2,253
1,431
385
338
143
1,147
2006
11
14
13
25
113
894
1,957
2,898
1,471
789
61
74
53
697
4
232
418
487
477
455
951
1,164
987
789
305
199
97
547
4
11
17
19
26
62
242
329
258
89
41
27
20
95
19
257
448
531
616
1,411
3,150
4,391
2,716
1,667
407
300
170
1,339
2007
11
12
11
19
73
651
1,635
3,018
1,661
826
671
504
188
772
3
332
259
366
326
338
760
1,162
901
1,040
293
315
167
522
4
10
15
17
25
61
197
300
215
97
66
59
24
91
18
354
285
402
424
1,050
2,592
4,480
2,777
1,963
1,030
878
379
1,385
2008
10













3













4
9
15
16
29
69
156
319
24
20
5
5
5
56
17
9
15
16
29
69
156
319
24
20
5
5
5
56
2009
12













3













3













18













2010
12
16
19
27
96
977
1,819
3,489
1,738
914
92
66
59
776
3













3













18













 Source:  Alaska Department of Labor and Workforce Development, Quarterly Census of Employment and Wages Data, historical data for 2002-
 2010, Excel file annual.xls, http://labor.alaska.gov/research/qcew/qcew.htm, downloaded November 27, 2011. Blank cells indicate data were not
 available.
                                                      115

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 3.10 Bristol Bay Salmon Industry Taxes

The Bristol Bay salmon industry pays millions of dollars annually in state, local and federal
taxes.  This section briefly describes these taxes and provides estimates, where available, of taxes
paid in recent years.

Alaska Fisheries Business Tax

The Alaska Fisheries Business Tax (AS 43.75.015) accounts for the largest share of local and
state taxes paid by the Bristol Bay salmon industry.  Under the fisheries business tax, salmon
processors pay the state:

       5.0% of the ex-vessel value of salmon processed on floating facilities

       4.5% of the ex-vessel value of salmon canned at shore-based facilities

       3.0% of the ex-vessel value of other salmon processed at shore-based facilities
       (e.g. salmon processed frozen, fresh, or in other ways except for canning)

The State of Alaska does not publish data on fisheries business tax revenues for specific species
and regions. Rows 1-4 of Table 34 provide a lower-bound estimate of tax obligations (before
credits) of Bristol Bay salmon processors, assuming that processors pay a tax rate of 5.0% for a
share of ex-vessel value equivalent to the share of canned salmon production in total Bristol Bay
salmon production, and 3.0% of ex-vessel value on the remaining share of ex-vessel value. This
estimate suggests that during the period 2000-2010,  fisheries business tax obligations ranged
from as low as $1.3 million in 2002 to $6.4 million.  Fisheries business tax payments are directly
proportional to ex-vessel value and thus highly sensitive to the effects of changes in catches and
prices on ex-vessel value.

Actual tax obligations are likely higher than the lower-bound estimates in Row 4, since (a) the
estimates do not take account of the higher tax rate (5.0%) on salmon processed on floating
processing; and (b) the share of salmon which is canned is likely higher than the share of canned
production in total production, because average yields are lower for canning.

Processors are entitled to credits against Fisheries Business Tax obligations up to certain limits
for certain kinds of expenditures,  including for example investments in salmon product
development (AS 43.75.035); investments to improve salmon utilization (AS 43.75.036), and
and contributions to the University of Alaska and other Alaska higher education institutions (AS
43.75.018). No data are available on the extent to which these tax credits reduce Bristol Bay
fisheries business tax revenues.
                                           116

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Table 34. Selected Data and Estimates for Bristol Bay Salmon Taxes
                             Selected Data and Estimates for Bristol Bay Salmon Taxes

Simple lower-bound estimate of
fisheries business tax obligations
ix-vessel value of Bristol Bay salmon
harvests ($ 000)
Canned share
(assumed tax rate = 5.0%)
STon-canned share
( assumed tax rate = 3%)
^ower-bound estimate of fisheries tax
obligation ($ 000)
State of Alaska Shared Business Tax
Payments to Bristol Bay Boroughs
and Cities (S 000) (a)
3ristol Bay Borough
^ake and Peninsula Borough
Dillingham
Egegik
Total
Row

1
2
3
4

5
6
7
8
9
2000

$84,014
37%
63%
$3,145

$1,440
$357
$203
$30
$2,029
2001

$40,359
32/0
68%
$1,467

$918
$246
$176
$176
$1,517
2002

$31,898
49%
51%
$1,270

$494
$162
$49
$78
$784
2003

$46,684
39%
61%
$1,760

NA
NA
NA
NA
NA
2004

$76,461
34%
66%
$2,818

$451
$113
$100
$36
$700
2005

$94,556
32%
68%
$3,439

$835
$71
$154
$29
$1,089
2006

$108,570
34%
66%
$3,998

$1,178
$99
$148
$29
$1,454
2007

$115,763
35%
65%
$4,287

$1,296
$134
$184
$74
$1,687
2008

$116,717
28%
72%
$4,163

$1,564
$138
$176
$63
$1,941
2009

$144,200
25%
75%
$5,061

$1,543
$152
$187
$63
$1,944
2010

$180,81S
27%
73%
$6,383

$1,797
$215
$23?
$85
$2,335
 (a) Source: Alaska Department of Revenue, Annual Shared Taxes and Fees Reports, www.tax.alaska.gov. NA: Not available.
Fisheries Business Tax Refunds

The State of Alaska "refunds" a major share of Fisheries Business Tax revenues to Alaska local
governments, as follows (AS 43.75.130):

       Cities receive 50% of the tax revenues collected in unified municipalities and in
       cities outside organized boroughs, and 25% of tax revenues collected in cities in
       organized boroughs

       Boroughs receive 50% of the tax revenues collected in areas of boroughs outside
       cities and 25% of the tax revenues collected in cities inside Boroughs.

Rows 5-9 of Table X-l provide data on State of Alaska shared fisheries tax payments to Bristol
Bay boroughs and cities.  In total, these payments ranged from $700 thousand in 2004 to $2.3
million in 2010.
Local Government Taxes

Several local governments in the Bristol Bay region impose taxes on the ex-vessel value of
salmon processed within their jurisdictions.  In 2010, these included the following:
                                   26
       Bristol Bay Borough:
       raw fish tax
       Lake and Peninsula Borough:
       Pilot Point:
4% fish taxEgegik:

2% raw fish tax
3% raw fish tax
3%
  Alaska Office of the State Assessor, 2010 Alaska Taxable, Table 2, Sales/Special Taxes and Revenues,
http://www.dced. state.ak.us/dca/osa/osa_summary.cfm.
                                            117

-------
Local governments also impose property taxes on processing facilities. No data are published on
Bristol Bay local government fish taxes or property taxes.  However, it is likely that these taxes
are comparable in magnitude to fisheries business taxes, and represent a major share of total
local government tax revenues.

Federal Government Taxes

Like all U.S. industries, the Bristol Bay salmon industry pays federal taxes including corporate
and individual income taxes paid by processing companies, processing workers, and fishermen.
No data are available on federal taxes specifically attributable to the Bristol Bay salmon industry,
although it is likely that they significantly exceed total taxes paid to the state and local
governments.
3.11 Regional Distribution of Bristol Bay Permit Holders, Fishery
Earnings, and Processing Employment

An important characteristic of the Bristol Bay commercial salmon industry is that shares of the
participants in the industry—both fishermen and processing workers—do not live in the Bristol
Bay region but rather in other parts of Alaska or other states and countries. In this section we
review available data on trends in the regional distribution of permit holdings, earnings and
processing employment between "local" residents of the Bristol Bay region, other Alaskans, and
non-Alaskans.

The Bristol Bay Region

There are twenty-six communities in the Bristol Bay region the Commercial Fisheries Entry
Commission (CFEC) considers "local" to the fishery for its analyses (Figure 55). Residents of
these villages are considered "Bristol Bay residents" for the CFEC data presented below on
permit holdings and earnings of Bristol Bay residents.

Residents of five additional villages on the south side of the Alaska Peninsula (Chignik City,
Chignik Lagoon, Chignik Lake, Perryville and Ivanof) are also considered "Bristol Bay
residents"  for the Alaska Department of Labor and Workforce Development (ADLWD) data on
seafood processing employment.
                                         118

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                                                               Nondaltono
                                            oKollganek

                                 New Stuyahoko
                                            OEkwok
           OlMnHHh  A'«^ikO
                   Manokotak   ODillingham        oLovolock
                           O.           O Portage Creek
                            n OEKuk           oN.ikm-k
                                   South NaknckO    oKjng ^,^0,,
Iliamna
o       o
    Pedro Bay

  OKoKhanok
                                          OEgcgik
            Bristol Bay
                              Pilot Pointo
                                         OUgashik
                                                            anatak
                Port Hoidcno
                 Figure 55. Bristol Bay Region Local Communities Source:
                       www. visitbristolbay. org/bbvc/images/bb_map_large.jpg
Regional Distribution of Permit Holders

Limited entry was implemented for most Alaska salmon fisheries in 1975, including the Bristol
Bay drift gillnet and set gillnet fisheries. The permits were initially issued for free to individuals
based on their degree of economic dependence upon the fishery and the extent of their past
participation in the fishery.  The purpose and effect of this initial allocation system was to
ensure that significant numbers of rural local residents received permits in regions of Alaska with
limited other economic opportunities, such as Bristol Bay (Knapp, 2011).
                                          119

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        Number of Bristol Bay Drift Gillnet Permit Holders, by Residency
                                              -Residents
                                               of other
                                               states
                                              -Other
                                               Alaska
                                               residents
                                              -Bristol Bay
                                               residents
        Number of Bristol Bay Set Gillnet Permit Holders, by Residency
Soon after the implementation of
limited entry a significant long-
term decline began in the share of
permits held by local residents in
the Bristol Bay fisheries and many
other rural Alaska fisheries. There
has been a corresponding increase
in the number of permits held by
other Alaska residents as well as
non-Alaska residents. This decline
in local permits has been an
important concern at both the
regional and state level.

Between 1978 and 2010, the
number of permits Bristol Bay
drift gillnet permits held by local
residents fell from 614 to 383
(Figure 56).  The share of drift
gillnet permits held by local
residents fell from 36% to 21%.

Between 1978 and 2010, the
number of permits Bristol Bay set
gillnet permits held by local
residents fell from 530 to 353.  The
share of permits held by local
residents fell from 59% to 36%.

The decline in local permit
ownership has come about as a
result of both net permit transfers
(sales and gifts) from residents  of
the region to non-local residents, as well as migration of permit holders out of the region.
Initially net permit transfers played a far greater role, but migration of permit holders out of the
region has also played an important role in recent years.
Figure 56. Number of Bristol Bay Permit Holders by
                     Residency
      120

-------
Regional Distribution of Fishery Earnings
                                      Drift Gillnet Permit Holders Average Earnings Per Permit Fished, by Residency
                                $140,000
                                $120,000
                                      Set Gillnet Permit Holders Average Earnings Per Permit Fished, by Residency
Historically, Bristol Bay
residents have had the
lowest average earnings
(gross revenues) per permit
fished, while residents of
other stages have had had
the highest average
earnings per permit fished.
For example, in 2007—the
latest year for which CFEC
earnings data by residency
are available, in the Bristol
Bay drift gillnet fishery,
average earnings per permit
fished were $44,604 for
Bristol Bay residents,
$66,191  for other Alaska
residents, and $73,391 for
non-Alaska residents
(Figure 57).

In the Bristol Bay  set
gillnet fishery,  average
earnings per permit fished
were  $22,991 for Bristol
Bay residents, $23,259 for
other Alaska residents, and
$25,333  for non-Alaska
residents (Figure 57).

A variety of factors may
contribute to these
differences in average
earnings per permit fished
by residency. In the drift
gillnet fishery,  the vessels operated by Bristol Bay residents tend to be older and smaller, with
lower average horsepower and fuel capacity than those of other Alaska residents or residents of
other states (Table 35). A much smaller share of the vessels operated by Bristol Bay residents
have refrigeration  capacity.  All of these differences may reflect less access to capital for Bristol
Bay residents than for other Alaska residents or residents of other states. However, the reasons
for differences  in earnings between groups have not been studied in detail or conclusively
explained. In part, the differences in earnings reflect differences in capital investment in the
fishery, as reflected in differences between groups in average vessel horsepower, refridgeration
                                Figure 57. Permit Holders Average Earnings, by Residency
                                            121

-------
capacity, and other measures (Northern Economics, 2009). These differences in investment may
in turn reflect differences between groups in access to capital, objectives for fishery
participation, and many other factors (Carothers, 2010; Knapp, 2011; Koslow, 1986; Langdon,
1986).

Table 35. Comparison of Vessels Used in the Bristol Bay Drift Gillnet Fishery, by
Residency of Permit Holder
   Comparison of Vessels Used in the Bristol Bay Drift Gillnet Fishery, by Residency of Permit Holder

Average age
of vessels
(years)
Average
lorsepower of
vessels
Average
displacement of
vessels
(gross tons)
Average fuel
capacity of
vessels (gallons)
3ercent of
vessels with
refrigeration
capacity
Group
Bristol Bay Residents
Other Alaska Residents
Residents of Other States
Average
Bristol Bay Residents
Other Alaska Residents
Residents of Other States
Average
Bristol Bay Residents
Other Alaska Residents
Residents of Other States
Average
Bristol Bay Residents
Other Alaska Residents
Residents of Other States
Average
Bristol Bay Residents
Other Alaska Residents
Residents of Other States
Average
1983
9
9
11
10
239
243
252
245
10
12
12
11
239
306
283
276
0.5%
1.3%
0.5%
0.8%
1988
11
11
12
11
279
271
286
278
12
13
12
12
288
334
311
311
0.5%
2.3%
2.0%
1.6%
1993
14
14
13
14
282
315
335
311
12
13
13
13
282
364
348
331
2.3%
7.5%
8.1%
6.0%
1998
18
17
16
17
294
345
368
336
12
13
14
13
294
357
352
335
4.5%
13.7%
15.5%
11.2%
2003
22
21
20
21
287
350
372
336
12
14
14
13
287
357
350
331
5.5%
15.3%
17.8%
12.9%
2008
26
24
24
25
337
373
382
364
12
15
14
14
299
360
364
341
7.7%
20.8%
22.2%
16.9%
 Northern Economics. 2009.  The Importance of the Bristol Bay Salmon Fisheries to the Region and its
 Residents. Report prepared for the Bristol Bay Economic Development Corporation. 193 pages.  Data are
 from tables on pages 136 and 137 of report. Based on data provided by the Commercial Fisheries Entry
 Commission.
                                            122

-------
           Share of Total Earnings of Bristol Bay Drift Gillnet Permit Holders, by Residency
  70%
  60%
   50%
  40%
       O5O5O5O5O5O5O5O5O5O5O5O5O5OOOO
   30%
  20%
   10%
-Residents of other
 states

-Other Alaska
 residents
                                                                        •Bristol Bay
                                                                         residents
     Figure 58. Share of Total Earnings of Bristol Bay Drift Gillnet Permit Holders, by
                                        Residency
Trends over time in the share of different groups in total earnings of Bristol Bay permit holders
represent the combined effects of trends over time in each group's share of permit holdings as
well as differences between groups in average earnings. In the drift gillnet fishery, the share of
Bristol residents in total earnings fell from about 35% in the late 1970s to just 15% in 2007.  The
share of non-Alaska residents increased from less than 50% in the late 1970s to 60% in 2007
(Figure 58).
                                           123

-------
           Share of Total Earnings of Bristol Bay Set Gillnet Permit Holders, by Residency
    70%
    60%
    50%
    40%
    30%
    20%
    10%
    0%
- Residents of other
 states

-Other Alaska
 residents

•Bristol Bay
 residents
                                  §§§§§8888
                                                   CXI  CXI  CXI  CXI
  Figure 59. Share of Total Earnings of Bristol Bay Set Gillnet Permit Holders, by
                                    Residency
In the set gillnet fishery, the share of Bristol residents in total earnings fell from about 63% in the
late 1970s to 35% in 2007.  The share of non-Alaska residents increased from about 20% in the
late 1970s to 34% in 2007 (Figure 59).
Regional Distribution of Processing Employment

Employment in Bristol Bay seafood processing is overwhelmingly dominated by residents of
other states and countries. In 2009, according to Alaska Department of Labor and Workforce
Development data, Bristol Bay residents accounted for less than 2% of Bristol Bay processing
workers, and other Alaska residents accounted for only 12%. Residents of other states and
countries accounted for 87%. (Processing employment data by residency are only available for
the years 2004-2009).(Figure 59).
                                           124

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                Share of Bristol Bay Seafood Processing Employment, by Residency
   100%
    90%
10% -
     0%
             0
             0
             CM
                   0
                   0
                   CM
CD
0
0
CM
0
0
CM
oo
0
0
CM
a>
0
0
CM
                                                                           Residents of other
                                                                           states or countries
                                                                           Other Alaska
                                                                           residents
                                                                          - Bristol Bay
                                                                           residents
          Source: Alaska Department of Labor and Workforce Development, Research and Analysis Division
       Figure 60. Share of Bristol Bay Seafood Processing Employment, by Residency
A Primarily Non-Local Fishery—With Widely Distributed Benefits


As is clear from the preceding figures, local residents account for a relatively small and declining
share of the jobs and earnings in the Bristol Bay salmon industry (Figure 61).  In contrast, non-
Alaska residents account for relatively large and growing share of the jobs and earnings.
                                             125

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     50%
     40%
     30%
     20%
     10%
              Local Bristol Bay Resident Share of the Bristol Bay Salmon Fisheries:
                                     Selected Measures
   •Total
   permits
   held*
-A-Total
   earnings*
                                                                              -Processing
                                                                              employment
          OOOCN^COOOOCN'^-COOO
          r^ooooooooooo>a>a>a>a>
          a>a>a>a>a>a>a>a>a>a>a>
                                                                CD   oo
                                                    oooooo
                                                    CM  CM   CM   CM   CM  CM
                   Source: CFEC, Changes in the Distribution of Alaska's Commercial Fisheries Entry Permits,
                                           1975-2010
  *Shares for
 both fisheries
  combined.
    Figure 61. Local Bristol Bay Resident Share of Salmon Fisheries: Selected Measures
This does not mean, of course, that the Bristol Bay salmon fishery is unimportant as a source of
jobs or income for local residents.  As we discuss in greater detail previously, it remains very
important. However, it is not as important for local residents as it might appear if one were to
erroneously assume that all the jobs were held by local residents and all the income was earned
by local residents.
                          Bristol Bay processing worker from Turkey
                                             126

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A different perspective is that the Bristol Bay fishery is not just economically important for a
remote region of southwestern Alaska.  Rather, it is of major economic importance for other
parts of Alaska and other states, particularly the Pacific Northwest.  Thousands of residents of
other parts of Alaska and other states work in and earn significant income from participating in
Bristol Bay fishing and processing. For example, as shown in Table 36, in 2010,  597 residents
of other parts of Alaska,  656 residents of Washington, 125 residents of Oregon and 119 residents
of California fished Bristol Bay salmon permits.  They had gross earnings of $40  million (other
Alaskans), $59 million (Washington residents), $10 million (Oregon residents, and $9.5 million
(California residents).
Table 36. Participation and Gross Earnings in Bristol Bay Salmon Fisheries

             Participation and Gross Earnings in Bristol Bay Salmon Fisheries, by Group, 2010

Group
Bristol Bay Residents, Total
Dillingham Census Area
Bristol Bay Borough
Lake and Peninsula Borough
Other Alaska Residents, Total
Anchorage
ECenai Peninsula Borough
Matanuska-Susitna Borough
Wrangell-Petersburg Census Area
ECodiak Island Borough
Other parts of Alaska
Alaska Residents, Total
Other States and Countries, Total
Washington
Oregon
California
Other States & Countries
TOTAL
Number of Fishermen Who Fished*
Drift gillnet
fishery
301
202
56
43
359
86
86
38
18
42
89
660
850
538
87
87
138
1510
Set gillnet
fishery
297
183
83
31
238
120
44
42

9
23
535
281
118
39
32
92
816
Total
598
385
139
74
597
206
130
80
18
51
112
1195
1131
656
126
119
230
2326
Estimated Gross Earnings ($1000)
Drift gillnet
fishery
18,250
11,170
4,227
2,854
31,215
6,479
7,968
3,593
2,445
3,951
6,780
49,466
84,671
55,342
8,383
8,058
12,888
134,137
Set gillnet
fishery
10,670
6,451
3,162
1,057
8,858
4,288
1,685
1,504
0
321
1,061
19,528
11,494
4,179
1,618
1,449
4,249
31,022
Total
28,920
17,620
7,389
3,911
40,074
10,767
9,652
5,097
2,445
4,272
7,841
68,994
96,165
59,521
10,001
9,507
17,136
165,159
 *Number of fishermen who made at least one landing as a permit holder.
 Source:  Commercial Fisheries Entry Commission, Fishery Participation and Earnings Statistics, 2010:
 http ://www.cfec. state, ak.us/gpbycen/2010/mnu.htm.
                                             127

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3.12 Distribution of Salmon Permits and Earnings within  The Bristol
Bay Region
Above, we discussed the distribution of Bristol Bay
salmon permits and earnings between local residents of
the Bristol Bay region and residents of other parts of
Alaska and other states. In this section, we discuss the
distribution of permits and earnings within the Bristol
Bay region.

For this analysis, we used the Commercial Fisheries
Entry Commission (CFEC) definition of the Bristol Bay
region as the twenty-six communities within the Bristol
Bay watershed.  For the analysis in this section, we use
the Alaska Department of Labor and Workforce
Development (ADLWD) definition of the Bristol Bay
region as the Bristol Bay Borough, the Lake and
Peninsula Borough, and the Dillingham Census Area.
The ADLWD definition is slightly larger because it
includes five communities outside the Bristol Bay
watershed (Chignik City, Chignik Lagoon, Chignik
Lake, Perryville and Ivanof).
                                       Source: Alaska Department of Labor and Workforce Development.
                                       Research and Analysis Section
                  DILLINGHAM CENSUS AREA
   Dillingham Region
     Dillingham
     Aleknagik
     darks Point
    Portage Creek
       Ekuk
                                           LAKE AND PENINSULA
                                              BOROUGH
             Upper Nushagak
               Region
               Koliganek
             NewStuyahok
               Ekwok
   Togiak-Manokotak Region
        Togiak
       Twin Hills
       Manokotak
      BRISTOL BAY BOROUGH
         King Salmon
           Naknek
         South Nakne
Chignik Region
 Chignik City
Chignik Lagoon
 ChignikLake
 Ivanov Bay
 Perryville
South Bristol Bay Region
     Egegik
    Pilot Point
    Ugashik
   Port Heiden
We further divide the Bristol
Bay region into seven smaller
regions, consisting of the groups
of communities:

Bristol Bay Borough
Dillingham Region
Togiak-Manokotak Region
Upper Nushugak Region
Lake Region
South Bristol Bay Region
Chignik Region

We omit the Chignik Region
from the figures because
residents of the region have very
little involvement with the
Bristol Bay fishery.
Table 37 summarizes population, numbers of permit holders, and salmon fishery earnings for
each community and region in 2000 and 2010.  These data were used to calculate per capita
                                            128

-------
permit holdings and earnings shown in Table 38 and Table 39. We used similar data to calculate
Figure 62 through Figure 69 which show trends by region over time.
Table 37. Population, Permit Holders, and Salmon Earnings, by Community: 2000 & 2010

            Population, Salmon Permit Holders, and Bristol Bay Salmon Earnings, by Community, 2000 & 2010


BRISTOL BAY BOROUGH
King Salmon
Naknek
South Naknek
DILLINGHAM CENSUS AREA
Dillingham Region
Aleknagik
Clarks Point
Dillingham
Ekuk
Portage Creek
Togiak-Manokotak Region
Manokotak
Togiak
Twin Hills
Upper Nushagak Region
Ekwok
Koliganek
New Stuyahok
LAKE AND PEN. BOROUGH
Lake Region
Igiugig
Iliamna
Kokhanok
Levelock
Newhalen
Nondalton
Pedro Bay
Port Alsworth
South Bristol Bay Region
Egegik
Pilot Point
Port Heiden
Ugashik
Chignik Region
Chignik
Chignik Lagoon
Chignik Lake
Ivanof Bay
Perryville
BRISTOL BAY, TOTAL (a)
BRISTOL BAY, TOTAL (b)
Population
2000
1257
442
678
137
4,922
2800
221
75
2,466
2
36
1277
399
809
69
783
130
182
471
1,823
986
53
102
174
122
160
221
50
104
346
116
100
119
11
456
79
103
145
22
107
8003
7547
2010
997
374
544
79
4,847
2614
219
62
2,329
2
2
1333
442
817
74
834
115
209
510
1,631
953
50
109
170
69
190
164
42
159
291
109
68
102
12
362
91
78
73
7
113
7475
7113
Drift gillnet
permit holders
2000
63
14
37
12
326
167
19
8
139
0
1
107
28
72
7
52
5
14
33
86
36
4
8
4
8
6
4
1
1
49
23
9
15
2
1
0
0
1
0
0
475
474
2010
63
15
38
10
262
142
15
7
120
0
0
80
24
53
3
40
3
16
21
57
28
3
9
3
4
6
2
0
1
28
10
8
8
2
1
0
0
1
0
0
382
381
Set gillnet
permit holders
2000
117
17
70
30
231
115
9
5
101
0
0
106
44
60
2
10
0
3
7
64
32
0
7
4
6
2
8
2
3
31
15
11
3
2
1
0
0
1
0
0
412
411
2010
101
17
69
15
199
97
6
4
87
0
0
97
35
62
0
5
0
2
3
45
27
1
6
6
2
4
4
3
1
17
7
5
3
2
1
0
0
1
0
0
345
344
Resident drift
gillnet earnings
($000)
2000
$1,939
$589
$1,120
$230
$10,287
$6,284
$530
$329
$5,425
-
-
$2,918
$847
$2,071
$0
$1,084
$117
$300
$667
$1,454
$371
-
$116
$76
$130
$49
-
-
-
$1,083
$494
$232
$357
-
-
-
-
-
-
-
$13,679
$13,679
2010
$4,227
$1,209
$2,695
$323
$10,913
$6,855
$752
$C
$6,103
-
-
$3,222
$696
$2,526
$C
$836
-
$456
$38C
$2,01S
$865
-
$45C
$C
$189
$226
-
-
-
$1,152
$468
$C
$684
-
-
-
-
-
-
-
$17,158
$17,158
Resident set
gillnet earnings
($000)
2000
$1,506
$291
$920
$295
$3,901
$2,005
$131
$68
$1,806
-
-
$1,811
$646
$1,165
$0
$85
-
-
$85
$436
$109
-
$51
$0
$0
$0
$57
-
-
$328
$222
$106
$0
-
-
-
-
-
-
-
$5,843
$5,843
2010
$3,162
$749
$2,184
$229
$6,246
$3,032
$174
$117
$2,742
-
-
$3,213
$1,547
$1,666
$C
$0
-
-
-
$599
$499
-
$215
$143
$C
$141
-
-
-
$100
$10C
$c
$c
-
-
-
-
-
-
-
$10,007
$10,007
 (a) Total includes the Chignik Region; (b) Total excludes the Chignik Region. Note:
 and not reported. Sources: U.S. Censuses, 2000 and 2010; CFEC.
"-" indicates that earnings data were confidential
                                               129

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                                          Estimated Bristol Bay Area Population, by Borough / Census Area
Bristol Bay Population Trends

Figure 62 and Figure 63 show population trends for the Bristol Bay region. Note that the
population data should be considered estimates rather than precise data. They are based on the
decennial United States censuses conducted in 1980, 1990, 2000 and 2010, and were estimated
for intervening years by the Alaska Department of Labor and Workforce Development. In
addition, given the
seasonality of the Bristol
Bay area employment and
the fact that much of the
workforce is non-resident,
it is difficult to define or
measure population
precisely. It is most
useful to focus on long-
term population trends
and relative populations of
different regions  rather
than short-term changes
which may result from
changes in how the data
were estimated rather than
actual population changes.
 In general, the population
of the Bristol Bay area
increased rapidly during
the 1980s, grew more
slowly during the  1990s,
and declined gradually
during the 2000s.  The
total 2010 population was
about 7500.

Of the six regions within
the Bristol Bay area
(excluding Chignik) the
Dillingham Region has by
far the largest population
and the south Bristol Bay
region has by far the
smallest.
                              9000
                              8000
                              7000
                              6000
                              5000
                              4000
                              3000
                              2000
                               1000
    Dillingham Census Area
    and Lake & Peninsula
    Borough Combined
                                                        T- CM  CM CM CM  CM CM
                               Figure 62. Estimated Bristol Bay Area Population, by Area
                                                    Estimated Population, by Region
                               3000
                               2500
                               2000
                               1500
                               1000
                                500
-»- Dillingham Region


-•-Togiak-Manokotak Region


-x- Bristol Bay Borough


-x-Lake Region


-*- Upper Nushagak Region


-e- South Bristol Bay Region
                                       Figure 63. Estimated Population by Region
                                             130

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Permit Holders
Figure 64 shows the number of drift gillnet permit holders by region for the years 1984-2010.
The number is highest for the Dillingham Region, followed by the Togiak-Manokotak Region.
The number of drift gillnet permit holders has declined in all regions since 1984. The rate of
decline has been somewhat less for the Bristol Bay Borough, particularly since 2000.
Figure 65 shows number
of drift gillnet permit
holders per 100 residents,
by region.  This measure
is equal to per capita
permit holdings multiplied
by 100.
By adjusting for
differences in population
over time and between
regions, it provides a way
of comparing the relative
degree of participation by
residents in the drift
gillnet fishery over time
and between regions.

Because the Bristol Bay
population is currently
higher than it was in the
early 1980s, permit
holdings per 100 residents
have declined relatively
more sharply than total
permit holdings, and have
fallen by about half since
1984 in all regions except
the Bristol Bay Borough.

In 2010, the number of
permit holders per 100
residents was highest in
the South Bristol Bay
Region (10) and lowest in
the Lake Region (3).
Thus the degree of
participation in the drift
gillnet fishery varies
between these regions by
                  Number of Drift Gillnet Permit Holders, by Region
 250
 200
 150
 100
                                           -»-Dillingham Region


                                           -•-Togiak-Manokotak Region


                                           -x-Bristol Bay Borough


                                           -*- Upper Nushagak Region


                                           -e- South Bristol Bay Region


                                           -x-Lake Region
    cncncncncncncncnoooooo
     --------
    Figure 64. Number of Drift Gillnet Holders, by Region
            Number of Drift Gillnet Permit Holders per 100 Residents, by Region
10
                                            -e-South Bristol Bay Region


                                            -•-Togiak-Manokotak Region


                                            -*- Bristol Bay Borough


                                            -»-Dillingham Region


                                            •^All Bristol Bay Regions


                                            -*- Upper Nushagak Region


                                            -x-Lake Region
                                   CD  CO  O
Figure 65. Number of Drift Gillnet Holders per 100 Residents,
                          by Region
                                             131

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                Number of Set Gillnet Permit Holders, by Region
a factor of 3 .
Figure 66 shows the number of set gillnet permit holders by region for the years 1984-2010.  The
number is highest for the Bristol Bay Borough, Togiak-Manokotak Region, and Dillingham
Region, and is much lower for the other three regions. Since 1984, the number of set gillnet
permit holders has declined in four regions (Bristol Bay Borough, Dillingham Region, Lake
Region, and South Bristol
Bay Region). However,
the declines have
generally not been as
steep as the declines in the
number of drift gillnet
permit holders. The
number of set gillnet
permit holders has stayed
about the same in the
Togiak-Manakotak
Region.  It is very small in
the Upper Nushagak
Region.
160
140
120
100
 80
          .A.
                                            - Bristol Bay Borough
                                             Togiak-Manokotak Region
                                             Dillingham Region
                                           -x-Lake Region
                                           -e- South Bristol Bay Region
                                            - Upper Nushagak Region
                          OCN^rcDCOO
                          oooooT-
                          oooooo
                          CMCMCMCMCMCM
    Figure 66. Number of Set Gillnet Holders, by Region
           Number of Set Gillnet Permit Holders per 100 Residents, by Region
Figure 67 shows number
of set gillnet permit
holders per 100 residents,
by region.  In general, the
number of set gillnet
permit holders  per 100
residents has trended
downward in all regions
except for the Bristol Bay
Borough.

There is wide variation
between regions in the
degree of participation in
the set gillnet fishery,
from as high as 10 permit
holders per 100 residents
in the Bristol Bay
Borough to as low as 1 in
the Upper Nushagak
Region.

Just as there is  wide
variation between regions
in the numbers of permit
holders per 100 residents, there is also wide variation between individual communities within
   TCDCOOCMTCDCOOCMTCDCOO
                                             Bristol Bay Borough


                                           -e-South Bristol Bay Region


                                           -•-Togiak-Manokotak Region


                                           —^All Bristol Bay Regions


                                           -»-Dillingham Region


                                           -x-Lake Region


                                           -*- Upper Nushagak Region
  Figure 67. Number of Set Gillnet Permit Holders per 100
                    Residents, by Region
              132

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regions and within the Bristol Bay watershed as a whole (Table 38). In 2010, some
communities, such as Ekwok and Nondalton, had fewer than 5 permit holders (drift and set
gillnet combined) per 100 residents.  Others communities, such as Naknek and South Naknek,
had 20 or more.  Ugashik, Egegik, and South Naknek have over 30 permit holders per 100
residents.
                                         133

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Table 38. Salmon Permit Holders per 100 Residents, by Community
                 Salmon Permit Holders Per Hundred Residents, by Community, 2000 & 2010


BRISTOL BAY BOROUGH
King Salmon
Naknek
South Naknek
DILLINGHAM CENSUS AREA
Dillingham Region
Aleknagik
Clarks Point
Dillingham
Ekuk
Portage Creek
Togiak-Manokotak Region
Manokotak
Togiak
Twin Hills
Upper Nushagak Region
Ekwok
tColiganek
New Stuyahok
LAKE AND PEN. BOROUGH
Lake Region
[giugig
[liamna
tCokhanok
Levelock
Newhalen
Nondalton
Pedro Bay
Port Alsworth
South Bristol Bay Region
Egegik
Pilot Point
Port Heiden
Ugashik
Chignik Region
Chignik
Chignik Lagoon
Chignik Lake
[vanof Bay
Perryville
BRISTOL BAY, TOTAL (a)
BRISTOL BAY, TOTAL (b)
Drift gillnet permit holders
per hundred residents
2000
5
3
5
9
7
6
9
11
6
0
3
8
7
9
10
7
4
8
7
5
4
8
8
2
7
4
2
2
1
14
20
9
13
18
0
0
0
1
0
0
6
6
2010
6
4
7
13
5
5
7
11
5
0
0
6
5
6
4
5
3
8
4
3
3
6
8
2
6
3
1
0
1
10
9
12
8
17
0
0
0
1
0
0
5
5
Set gillnet permit holders
per hundred residents
2000
9
4
10
22
5
4
4
7
4
0
0
8
11
7
3
1
0
2
1
4
3
0
7
2
5
1
4
4
3
9
13
11
3
18
0
0
0
1
0
0
5
5
2010
10
5
13
19
4
4
3
6
4
0
0
7
8
8
0
1
0
1
1
3
3
2
6
4
3
2
2
7
1
6
6
7
3
17
0
0
0
1
0
0
5
5
Total permit holders per
hundred residents
2000
14
7
16
31
11
10
13
17
10
0
3
17
18
16
13
8
4
9
8
8
7
8
15
5
11
5
5
6
4
23
33
20
15
36
0
0
0
1
0
0
11
12
2010
16
9
20
32
10
9
10
18
9
0
0
13
13
14
4
5
3
9
5
6
6
8
14
5
9
5
4
7
1
15
16
19
11
33
1
0
0
3
0
0
10
10
 (a) Total includes the Chignik Region;
 CFEC.
(b) Total excludes the Chignik Region. Sources: U.S. Censuses, 2000 and 2010;
                                               134

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Salmon Fishery Earnings

Figure 68 and Figure 69 show total and per capita salmon fishery earnings for Bristol Bay
regions. Note that trends in fishery earnings for each region, as well as differences between
regions, reflect the combined effects of three factors: (1) trends in overall catches, prices and
value of the fishery; (2) trends in the number of permit holders in each region; and (3) trends in
average catch shares of
permit holders within each
region.
                                                 Total Salmon Fishery Earnings, by Region
                                 $25,000
                                                                          -»-Dillingham Region


                                                                          -*- Bristol Bay Borough


                                                                          -•-Togiak-Manokotak Region


                                                                          -e- South Bristol Bay Region


                                                                          -x-Lake Region


                                                                          -*- Upper Nushagak Region
                                       cncncncncncncncnoooooo
                                       --------
                                  Figure 68. Total Salmon Fishery Earnings, by Region
                                                Per Capita Salmon Fishery Earnings, by Region
The combined effect of
the decline in total value
of the fishery as well as a
decline in the number of
permit holders was a
dramatic decline in
salmon fishery earnings
and per capita earnings for
all regions between the
late 1990s and 2002. Note
that this effect would
appear even more
dramatic if adjusted for
the inflation which
occurred during this
period of time.

Between 2002 and 2010,
both earnings and per
capita earnings have
recovered significantly
in all regions. However,
except for the Bristol Bay
Borough, per capita
earnings were well below
the levels of the 1980s,
particularly for the Lake
Region and Upper
Nughagak Region.

Just as there is wide
variation between regions
in per capita salmon
fishery earnings, there is
also wide variation
between individual communities within regions and within the Bristol Bay watershed as a whole
                                $25,000
                                $20,000
                                $15,000
                                $10,000
                                 $5,000 -y
-e-South Bristol Bay Region


-*- Bristol Bay Borough


-•-Togiak-Manokotak Region


-»-Dillingham Region


-x-Lake Region


-*- Upper Nushagak Region
                               Figure 69. Per Capita Salmon Fisheries Earnings, by Region
                                             135

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(Table 39). In 2010, per capita salmon fishery earnings in some communities, such as Kokhanok
and Newhalen, were less than $2000.  Presumably they were much lower in other communities,
such as Nondalton and Ekwok, for which earnings data were confidential due to the small
number of permit holders. In other communities, such as Naknek, South Naknek, Hiamna and
Port Heiden, they per capita earnings exceeded $6000. Thus there is clearly wide variation
within the Bristol Bay watershed in the extent to which communities and regions participate in
and benefit economically from Bristol Bay salmon fisheries.
Table 39. Bristol Bay Salmon Fishery Earnings, by Community
               Bristol Bay Salmon Fishery Per Capita Earnings, by Community, 2000 and 2010


BRISTOL BAY BOROUGH
King Salmon
Naknek
South Naknek
DILLINGHAM CENSUS AREA
Dillingham Region
Aleknagik
Clarks Point
Dillingham
Ekuk
Portage Creek
Togiak-Manokotak Region
Manokotak
Togiak
Twin Hills
Upper Nushagak Region
Ekwok
tColiganek
New Stuyahok
LAKE AND PEN. BOROUGH
Lake Region
[giugig
[liamna
tCokhanok
Levelock
Newhalen
Nondalton
Pedro Bay
Port Alsworth
South Bristol Bay Region
Egegik
Pilot Point
Port Heiden
Ugashik
Chignik Region
Chignik
Chignik Lagoon
Chignik Lake
[ vanof Bay
Perryville
BRISTOL BAY, TOTAL (a)
BRISTOL BAY, TOTAL (b)
Drift gillnet fishery per
capita earnings
2000
$1,542
$1,334
$1,652
$1,675
$2,090
$2,244
$2,399
$4,385
$2,200


$2,285
$2,123
$2,560
$0
$1,384
$900
$1,649
$1,416
$798
$377

$1,137
$435
$1,067
$309



$3,129
$4,261
$2,316
$2,998







$1,709
$1,813
2010
$4,240
$3,232
$4,954
$4,093
$2,252
$2,623
$3,435
$0
$2,620


$2,417
$1,576
$3,091
$0
$1,002

$2,182
$745
$1,237
$908

$4,127
$0
$2,743
$1,191



$3,960
$4,296
$0
$6,705







$2,295
$2,412
Set gillnet fishery per capita
earnings
2000 | 2010
$1,198 J $3,172
$657
$1,357
$2,154
$793
$716
$591
$901
$733


$1,418
$1,619
$1,440
$0
$109


$181
$239
$110

$504
$0
$0
$0



$947
$1,911
$1,058
$0







$730
$774
$2,004
$4,015
$2,892
$1,289
$1,160
$794
$1,882
$1,177


$2,410
$3,500
$2,039
$0
$0



$367
$524

$1,975
$842
$0
$740



$343
$915
$0
$0







$1,339
$1,407
Total salmon fishing per
capita earnings
2000
$2,740
$1,991
$3,009
$3,829
$2,882
$2,960
$2,990
$5,286
$2,933


$3,703
$3,742
$4,000
$0
$1,494


$1,597
$1,037
$487

$1,640
$435
$1,067
$309



$4,076
$6,173
$3,375
$2,998







$2,439
$2,587
2010
$7,411
$5,236
$8,969
$6,986
$3,540
$3,783
$4,229
$1,882
$3,798


$4,828
$5,075
$5,131
$0
$1,002



$1,604
$1,432

$6,102
$842
$2,743
$1,931



$4,302
$5,211
$0
$6,705







$3,634
$3,819
 (a) Total includes the Chignik Region;
 confidential and not reported. Sources:
(b) Total excludes the Chignik Region. Blank cells indicate that earnings data were
 U.S. Censuses, 2000 and 2010; CFEC.
                                            136

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3.13 Economic Measures of the Bristol Bay Salmon Industry

There is no single or best economic measure for the Bristol Bay fishery. Which measure is
appropriate depends upon the question being asked.

For example, if we want to know how the Bristol Bay salmon fishery compares in scale with
other fisheries, we should look at total harvests or ex-vessel or wholesale value. If we want to
know how it affects the United States balance of payments, we should look at estimated net
exports attributable to the fishery. If we want to know how much employment the industry
provides for residents of the local Bristol Bay region, Alaska or the United States, we should
look at estimated employment in fishing and processing for residents of these regions. If we
want to know the net economic value attributable to the fishery, we should look at estimated
profits of Bristol Bay fishermen and processors. These different measures vary widely in units,
in scale, and how economically "important" they make the fishery appear.

In this section, we summarize selected economic measures of the Bristol Bay commercial fishery
for recent years. These include harvests, gross ex-vessel and wholesale value, estimated export
value, direct employment and earnings in fishing and processing by region of residency, and
limited entry prices and total estimated limited entry permit value. We present tables of each of
these measures for the years 2000-2010.  Where data are available, we present graphs for longer
periods, showing dollar values in both nominal and real (inflation-adjusted) prices expressed in
2010 dollars. Blank cells in the tables indicate that data were not available as of November
2011. Refer to earlier sections in this report for more detailed discussions of each measure.

Harvests

The Bristol Bay salmon fishery is a world-scale commercial salmon fishery. Between 2000 and
2010, Bristol Bay averaged 60% of total Alaska sockeye salmon harvests (by volume), 45% of
world sockeye salmon harvests, 18% of all Alaska wild salmon  harvests,  7% of all world wild
salmon harvests, and 2%  of all world salmon production (wild and farmed combined).
                                         137

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Table 40. Economic Measures of Bristol Bay Salmon Industry: Sockeye Salmon Harvests
                    Economic Measures of the Bristol Bay Salmon Industry: Sockeye Salmon Harvests
Measure
Harvests
Millions offish
Millions of pounds
Bristol Bay harvest
volume as a share of:
Alaska sockeye salmon
World sockeye salmon
Alaska wild salmon (all species)
World wild salmon (all species)
World wild & farmed salmon
(all species)
2000

21
125

61%
45%
18%
7%
3%
2001

14
96

56%
40%
12%
5%
2%
2002

11
65

48%
28%
10%
4%
1%
2003

15
93

50%
38%
13%
5%
2%
2004

26
152

59%
47%
19%
8%
3%
2005

25
155

58%
47%
16%
7%
3%
2006

28
165

69%
49%
22%
8%
3%
2007

30
173

62%
47%
18%
7%
3%
2008

28
160

71%
52%
23%
9%
3%
2009

31
183

71%
55%
25%
7%
3%
2010

29
170

74%




Avg.

23
140

62%
45%
18%
7%
2%
Range

11 - 31
65 - 183

48%- 74%
28%- 55%
10%- 25%
4%- 9%
1%- 3%
 Sources: Alaska Department of Fish and Game, National Marine Fisheries Service, FAO.
Bristol Bay Commercial Salmon Harvests
^n
AE*
A.r\ -
Ti
"m ^n -
M—
M—
O
/n 9^
c
o
^ 9fl -
E Z(J
^^
^r\
c _
n









nj
Ull
LO h- O> T-
h- h- h- OO
O) O) O) O)












co LO r*- o •<-
oo oo oo oo o
O) O) O) O) O)










CO LO Is- O5
O) O) O) O)
O) O) O) O)
Source: Commercial Fisheries Entry Com mission; Alaska






T- CO LO h-
o o o o
o o o o
CM CM CM CM
Department of Fish and G




D Other
Species


• Sockeye




O) T-
O T-
O O
CM CM
ame

                    Figure 70. Bristol Bay Commercial Salmon Harvests
                                              138

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Gross Ex-Vessel Value and First Wholesale Value

During the period 2000-2010, Bristol Bay sockeye salmon harvests had an average annual real
ex-vessel value to fishermen of $101 million (expressed in 2010 $). During this period of time,
the value was generally increasing, from a low or $39 million in 2002 to $181 million in 2010.
The real  first wholesale value of salmon products processed from Bristol Bay sockeye salmon in
Bristol Bay was more than twice as high as harvest value, averaging $234 million for the period
2000-2010, and increasing from $124 million in 2002 to $390 million in 2010.
Table 41. Economic Measures of Bristol Bay Salmon Industry: Sockeye Value

           Economic Measures of the Bristol Bay Salmon Industry: Sockeye Salmon Ex-Vessel Value and First Wholesale Value
Measure
Ex -Vessel Value
($ Millions)
Nominal value (not inflation-adjusted)
Real value (inflation adjusted, 2010 $)
First wholesale value
Nominal value (not inflation-adjusted)
Real value (inflation adjusted, 2010 $)
Bristol Bay sockeye salmon
share of:
Alaska wild salmon ex- vessel value
(all species)
World wild salmon ex-vessel value
(all species) *
United States fish & shellfish
landed value (all species)
Rank of Naknek-King Salmon among
U.S. ports in annual landed value
2000


80
104

175
227


23%

12%

2%
21

2001


40
51

115
144


14%

6%

1%
49

2002


32
39

100
124


16%

6%

1%
87

2003


48
57

114
137


19%

8%

1%
58

2004


76
90

176
206


24%

13%

2%
12

2005


95
107

220
250


24%

12%

2%
8

2006


109
119

237
261


28%

13%

2%
8

2007


116
125

249
268


24%

11%

2%
7

2008


117
120

262
270


22%

10%

2%
7

2009


144
147

293
298


29%

9%

3%
4

2010


181
181

390
390


25%



3%
4

Avg.


94
104

212
234


23%

10%

2%
24

Range


32 - 181
39 - 181

100 - 390
124 - 390


14% - 29%

6% - 13%

1% - 3%
87 - 4

 * Valued at average prices of Alaska wild salmon, by species.

 Sources: Alaska Department of Fish and Game, National Marine Fisheries Service, FAO.
                                            139

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                   Ex-Vessel and Wholesale Value of Bristol Bay Sockeye Salmon
      700
      600
Note: Real (inflation-
adjusted) values are
 expressed in 2010
      dollars
          i"~i"~i-~cocococococncncncncnooooo
-A- Real first
   wholesale
   value
                                                                             first
                                                                             wholesale
                                                                             value

                                                                         -0- Real ex-
                                                                             vessel
                                                                             value
                                                                            •Nominal
                                                                             ex-vessel
                                                                             value
                                                      (S|(S|(S|(S|(S|

                        Source: Alaska Department of Fish and Game
         Figure 71. Ex-Vessel and Wholesale Value of Bristol Bay Sockeye Salmon
Between 2000 and 2010, Bristol Bay averaged 23% of the ex-vessel for all Alaska wild salmon,
an estimated 10% of the harvest value of world wild salmon harvests, and 2% of the value of
U.S. fish and shellfish landings of all species combined.

As ex-vessel value increased dramatically between 2003 and 2010, the Bristol Bay port of
Naknek-King Salmon rose from a rank of 87th to 4th among all U.S. ports in annual landed
value (ex-vessel value, or value paid to fishermen, offish landed in the port).
Export Value of Bristol Bay Salmon Products

During the period 2000-2010, the value of Bristol Bay salmon products exported from the United
States averaged $173 million for the years 2000-2010, and was $254 million in 2010.
                                           140

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Table 42. Economic Measures of the Bristol Bay Salmon Industry: Export Value.

      Economic Measures of the Bristol Bay Salmon Industry: Estimated Export Value of Bristol Bay Sockeye Salmon Products
Measure
Nominal value of exports
(millions of dollars)
Canned
Frozen
Fresh
Roe
Total
Real value of exports
(millions of 2010 $)
Canned
Frozen
Fresh
Roe
Total
2000

44
8
87
11
150

57
11
112
14
193
2001

49
3
76
8
137

62
4
96
11
173
2002

41
11
40
5
97

50
14
49
6
120
2003

45
10
48
7
111

54
12
58
8
133
2004

68
13
82
8
172

80
15
96
9
201
2005

65
10
105
13
193

74
11
119
14
219
2006

79
5
80
9
173

86
6
88
10
191
2007

79
8
82
14
183

85
9
89
15
197
2008

84
8
92
22
206

86
8
94
23
212
2009

86
8
113
24
230

87
8
115
24
234
2010

80
8
146
20
254

80
8
146
20
254
Avg.

65
8
87
13
173

73
10
97
14
193
Range

41 -86
3 -13
40 - 146
5 -24
97 - 254

50 -87
4 -15
49 - 146
6 -24
120 -254
 Note: The value oTUS exports oTBristol Bay sockeye salmon products was estimated as the total value oTUS sockeye salmon exports
 multiplied by the share oTBristol Bay sockeye in total Alaska sockeye salmon havests. The value oTBristol Bay sockeye salmon roe exports
 was assumed to be equal to the first wholesale value oT sockeye salmon roe production.  The data source Tor US exports was the National
 Marine Fisheries Serivce Foreign Trade in Fisheries Products website.
                        Estimated Value of US Exports of Bristol Bay Salmon Products
        $300,000
        $250,000
        $200,000
     "5
     T3
        $150,000
        $100,000
         $50,000
                                                                                       I Roe
                                                                                        Fresh
                                                                                       I Canned
                                                                                       I Frozen
-0-Real total
    export value
    (2010 dollars)

•^—Nominal total
    export value
                          Source:  NMFS trade data, ADFG COAR data for roe production value
          Figure 72. Estimated Value of US Exports of Bristol Bay Salmon Products
                                                    141

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Employment

During the period 2001-2009, estimated peak employment in the Bristol Bay salmon industry
averaged 6,656 fishermen and 3,255 processing workers, for average total peak employment of
9,911.

Because the fishery occurs almost entirely in June and July, estimated annual average
employment is only about one-sixth as high as peak employment.  During the period 2001-2009,
estimated annual average employment averaged 1,093 in fishing and 535 in processing, for a
total of 1,628 annual average jobs.

During this period Bristol Bay salmon annual average fishing employment averaged 15% of
Alaska statewide annual average fishing employment. Peak Bristol Bay commercial fishing
employment averaged 33% of peak statewide Alaska commercial fishing employment.  Put
differently, in July—the busiest month for Alaska commercial fishing—about one third of all the
people fishing commercially in Alaska were fishing in Bristol Bay. Bristol Bay fish processing
accounted for an average of 14% of the individuals who worked in Alaska fish processing.
Table 43. Economic Measures of the Bristol Bay Salmon Industry: Employment

                      Economic Measures of the Bristol Bay Salmon Industry: Employment
Measure
Estimated peak employment or
number of workers
Peak (July) fishing employment
Number offish processing workers
Total
Estimated annual average
employment
Fishing
Fish processing
Total
Bristol Bay share of estimated Alaska
total
Annual average fishing employment
Peak (July) employment in fishing
Number offish processing workers
2001

7,098
2,862
9,960

1,179
475
1,654

15%
33%
13%
2002

5,514
2,273
7,787

888
366
1,254

12%
30%
11%
2003

6,465
2,484
8,949

1,063
409
1,472

14%
33%
11%
2004

6,513
3,474
9,987

1,089
581
1,669

15%
33%
16%
2005

6,750
3,272
10,022

1,098
532
1,631

15%
33%
15%
2006

6,936
2,940
9,876

1,140
483
1,623

16%
35%
13%
2007

6,891
3,512
10,403

1,110
566
1,675

15%
34%
15%
2008

6,969
3,952
10,921

1,129
640
1,769

16%
34%
17%
2009

6,768
4,522
11,290

1,143
764
1,907

16%
34%
19%
Avg.

6,656
3,255
9,911

1,093
535
1,628

15%
33%
14%
Range

5,514 -7,098
2,273 - 4,522
7,787 - 11,290

888 - 1,179
366 - 764
1,254 - 1,907

12% - 16%
30% - 35%
11% - 19%
 Source: Alaska Department of Labor and Workforce Development, Research and Analysis Division.
                                          142

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Limited Entry Permit Prices and Values

Limited entry permit prices provide a measure of the value to the marginal permit holder of the
present and future right to participate in the fishery. Economic theory suggests that this will be
the marginal permit holder's present discounted present value of expected future profits from the
fishery. During the period 2002-2010 Bristol Bay permit prices increased from $19,700 to
$102,100 for drift gillnet permits and from $11,900 to $28,700 for set gillnet permits.  The
dramatic recovery in permit prices reflects a dramatic increase in profitability of the fishery and
expectations of continued profitability.

The total value of Bristol Bay permits—calculated as the number of permits multiplied by the
permit price—provides an estimate of the total present discounted value of expected future
profits from the fishery. During the period 2000-2010 the estimated total value of Bristol Bay
permits (both fisheries combined) ranged from $48 million to $218 million.

Multiplying the total value of a permit by the rate of return a permit holder demands on a permit
investment provides a measure  of the annual profit permit holders expect to earn.  We do not
know the rate of return demanded by permit holders. However, it is likely that it is between  5%
and 20% (Hupert et al 1996). This suggests that in 2010 annual expected profits from Bristol
Bay commercial fishing between $10.9 million and $43.7 million. Note that this does not
include expected profits from fish processing.

Table 44. Economic Measures of the Bristol Bay Salmon Industry: Permit Prices and
Values. (Source: www.cfec.state.ak.us/bit/MNUSALM.htm)
                   Economic Measures of the Bristol Bay Salmon Industry: Permits Prices and Values
Vleasure
V umber of permanent permits
issued
Drift gillnet fishery
Set gillnet fishery
Total
Average nominal permit price
($)
Drift gillnet fishery
Set gillnet fishery
Estimated total nominal value
($ millions) (a)
Drift gillnet fishery
Set gillnet fishery
Total
Implied annual nominal
profits ($ millions) (b)
assuming permit holders
demand a rate of return of:
5%
10%
15%
20%
2000

1858
1,007
1,007

80,500
32,400

149.6
32.6
182.2

9.1
18.2
27.3
36.4
2001

1,861
1,008
2,869

34,700
25,300

64.6
25.5
90.1

4.5
9.0
13.5
18.0
2002

1,863
1,004
2,867

19,700
11,900

36.7
11.9
48.6

2.4
4.9
7.3
9.7
2003

1,861
999
2,860

29,300
12,600

54.5
12.6
67.1

3.4
6.7
10.1
13.4
2004

1,857
988
2,845

37,000
14,700

68.7
14.5
83.2

4.2
8.3
12.5
16.6
2005

1,859
988
2,847

51,200
15,100

95.2
14.9
110.1

5.5
11.0
16.5
22.0
2006

1,859
985
2,844

75,000
22,400

139.4
22.1
161.5

8.1
16.1
24.2
32.3
2007

1,861
983
2,844

79,400
24,000

147.8
23.6
171.4

8.6
17.1
25.7
34.3
2008

1,863
979
2,842

89,800
27,400

167.3
26.8
194.1

9.7
19.4
29.1
38.8
2009

1,863
982
2,845

78,300
28,200

145.9
27.7
173.6

8.7
17.4
26.0
34.7
20K

1,863
982
2,845

102, IOC
28,70C

190.2
28.2
218/

10.9
21.8
32.8
43.7
Avg.

1,861
991
2,683

61,545
22,064

114.5
21.9
136.4

6.8
13.6
20.5
27.3
Range

1,857 - 1,863
979 - 1,008
1,007 - 2,869

19,700 - 102,100
11,900 - 32,400

36.7 - 190.2
11.9 - 32.6
48.6 - 218.4

2.4 - 10.9
4.9 - 21.8
7.3 - 32.8
9.7 - 43.7
 (a) Calculated as average permit price x number of permanent permits issued, (b) Estimated total value x assumed rate of return demanded. Source: Commercial
 Fisheries Entry Commission, Salmon Basic Information Tables.
                                            143

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                       Estimated Total Value of Bristol Bay Limited Entry Permits
        900
                                                                           •Real
                                                                           (2010)
                                                                           dollars
                                                                           •Nominal
                                                                           dollars
            r^ooooooooooa>a>a>a>a>
            O5O5O5O5O5O5O5O5O5O5O5
O  CM  •*  CD  OO  O
O  O  O  O  O  T-
O  O  O  O  O  O
CM  CM  CM  CM  CM  CM
                        Source: Estimated from CFEC Salmon Basic Information Tables
          Figure 73. Estimated Total Value of Bristol Bay Limited Entry Permits
3.14 Bristol Bay Commercial Fisheries: Summary
The Bristol Bay sockeye salmon fishery is one of the world's largest and most valuable wild
salmon fisheries. Between 2006 and 2010, the Bristol Bay salmon industry averaged:

   •   Annual harvests of 31 million salmon (including 29 million sockeye salmon)
   •   51% of world sockeye salmon harvests
   •   Annual "ex-vessel" value to fishermen of $129 million
   •   Annual first wholesale value after processing of $268 million.
   •   26% of the "ex-vessel" value to fishermen of the entire Alaska salmon harvest.
   •   Seasonal employment of more than 6800 fishermen and 3700 processing workers.

Participation in the Bristol Bay salmon fishery is limited to holders of limited entry permits and
their crew.  There are approximately 1860 drift gillnet permits for fishing from boats and
approximately 1000 set net permits for fishing from the shore.  The driftnet fishery accounts for
about 80% of the harvest. Most of the harvest is processed by about ten large processing
                                          144

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companies in both land-based and floating processing operations which employ mostly non-
resident seasonal workers.

Bristol Bay Salmon Harvests

Sockeye salmon account for about 94% of the volume of Bristol Bay salmon harvests and an
even greater share of the value. Total catches vary widely from year to year. Between 1980 and
2010, Bristol Bay sockeye salmon harvests ranged from as low as  10 million fish to as high as 44
million fish. Harvests can vary widely from year to year.  Annual  pre-season forecasts are
subject to a wide margin of error.
Bristol Bay Commercial Salmon Harvests




•5
g
E

5







n


...
ml









X) CO CO CO Cn
7) Cn Cn Cn Cn










ro ID h- en
en en en en
en en en en























D Other
Species
• Sockeye

T- c^ LO r^ en T-
888885
Source: Commercial F sheries Entry Commission; Alaska Department of F sh and Game

                   Figure 74. Bristol Bay Commercial Salmon Harvests

There are no formal long-term forecasts of future Bristol Bay harvests. The variability and
uncertainty of annual salmon returns are important factors influencing how the fishery is
managed and how fish are harvested, processed and marketed.

The Bristol Bay commercial salmon fishery harvests salmon which spawn in and return to
numerous rivers over a broad area. For management purposes, the fishery is divided into five
fishing districts.  Catches in each district vary widely from year to year and over longer time
periods of time, reflecting wide variation in returns to river systems within each district (Table ).
There is no obvious way to characterize the relative share of the Bristol Bay commercial salmon
fishery attributable to particular river systems or to the individual streams and lakes that make up
each river system.
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Table 45. Distribution of Harvests for Bristol Bay Fishing Districts, 1986-2010

               Distribution of Harvests for Bristol Bay Fishing Districts, 1986-2010
Measure
Harvests
(millions of
fish)
Share of total
harvests (%)
District
Naknek-Kvichak
Nushagak
Egegik
Ugashik
Togiak
Naknek-Kvichak
Nushagak
Egegik
Ugashik
Togiak
Minimum
0.6
1.7
2.3
0.5
0.1
5%
9%
16%
3%
0%
10th
percentile
2.7
2.7
4.0
1.5
0.2
18%
10%
21%
7%
1%
Mean
8.0
5.1
8.3
2.8
0.5
30%
22%
34%
11%
2%
90th
percentile
15.3
8.0
13.3
4.5
0.8
46%
32%
48%
15%
4%
Maximum
20.3
11.1
21.6
5.0
0.8
52%
45%
62%
32%
6%
Standard
deviation
5.0
2.3
4.3
1.3
0.2
11%
10%
11%
5%
1%
 Source:  Alaska Department of Fish and Game, Bristol Bay Annual Management Reports

Currently there is particular interest in the significance of fisheries resources of river systems in
the Nushagak and Kvichak districts, because of potential future resource development in these
watersheds. Over the period 1986-2010, the Naknek-Kvichak catches ranged from as low as 5%
to as high as 52% of total Bristol Bay catches; Nushagak district catches ranged form as low as
9% to as high as 45% of total Bristol Bay catches. For most of the past decade, the combined
Nushagak and Naknek-Kvichak districts have accounted for about 60% of the total Bristol Bay
commercial sockeye harvest.

In general,  a decline in salmon returns associated with any particular river system might have a
relatively small effect on average catches over a long period of time in the Bristol Bay fishery.
But it might have a much larger effect on catches in those years when the river system would
have contributed a relatively larger share of total harvests.  For example, if a particular river
system accounts for an average of 1% of the return on average but 10% of the return in some
years, the loss of that system would reduce catches by only 1% on average but would reduce
catches  in some years by 10%. Put differently, a decline in catches from any particular river
system would increase the variability in catches in the fishery and the overall economic risk
associated with the fishery.

An inherent question here is whether 51% of the world's sockeye  are caught in Bristol Bay
because that is where the fish are or because that is where the boats go. One could  envision
circumstances where the boats prefer to go to areas that are more safe/convenient (more
sheltered, closer to port, etc.) and there are enough fish available there that they don't need to go
elsewhere.  It is not clear if severe degradation of the Bristol Bay commercial fishery may
necessarily result in the total loss of 51% of the world's harvest, but rather displace it to other
areas (possibly even in another area of AK). However, such changes in the Alaska and Bristol
Bay fishery could result in more dangerous working conditions, negatively affect Alaska native
participation in the fishery; and will change the Alaska commercial fishery market structure.
Evaluating such impacts is beyond the scope of this baseline assessment.
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Bristol Bay Salmon Production and Markets

Most Bristol Bay salmon is processed into either frozen or canned salmon.  Traditionally most
frozen salmon has been frozen headed and gutted (H&G) for further processing elsewhere,
particularly in Japan.  However, in recent years production of frozen salmon fillets in the Bristol
Bay region has increased.

Formerly almost all Bristol Bay frozen salmon was exported to Japan as frozen headed and
gutted salmon. Over the  past decade exports of frozen head and gutted salmon to Japan have
declined while exports have increased to Europe and to China (for reprocessing into fillets).
Most Bristol Bay canned salmon is exported, primarily to the United Kingdom and Canada.
             Estimated Shares of Bristol Bay Sockeye Salmon Production, 2010
                              Fresh
                              10%
     Canned
Roe    tails
2%    6%
                     Frozen
                      fillets
                      12%
Canned
 halves
  14%
                                          Frozen H&G
                                             56%
                                                         Source:  Estimated
                                                         from ADFG COAR
                                                          data and ADOR
                                                       Annual Alaska Salmon
                                                         Price Report data
       Figure 15. Estimated Shares of Bristol Bay Sockeye Salmon Production, 2010
                                         147

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Bristol Bay Salmon Prices and Value

Ex-vessel prices paid to fishermen and first wholesale prices received by processors in the
Bristol Bay salmon fishery have varied widely over the past three decades, reflecting dramatic
changes in world salmon markets during this period.
               Average Ex-Vessel and Wholesale Prices of Bristol Bay Sockeye Salmon
        $6.00
        $0.00
              0)0)0)0)0)0)0)0)000000

                          Source: Alaska Department of Fish and Game
           Figure 76. Average Ex-Vessel and Wholesale Prices of Bristol Bay Sockeye Salmon

Strong Japanese demand from frozen sockeye salmon drove a sharp rise in Bristol Bay salmon
prices during the 1980s. Competition from rapidly increasing farmed salmon production drove a
protracted and dramatic decline in prices between 1988 and 2001, which led to an economic
crisis in the industry. Growing world salmon demand, a slowing of farmed salmon production
growth, diversification  of Bristol Bay salmon products and markets, and improvements in quality
have driven a strong recovery in prices over the past decade.  Many other factors, such as
changes in wild salmon harvests, exchange rates, and global economic conditions have also
affected prices. In general, changes in ex-vessel prices paid to fishermen have reflected changes
in first wholesale prices paid to processors.

Changes in prices, harvests and production have combined to drive dramatic changes in the ex-
vessel and first wholesale value of Bristol  Bay salmon over the past three decades . Adjusted for
inflation (expressed in 2010 $), the real ex-vessel value paid to fishermen fell from $359 million
in 1988 to $39 million in 2002, and rose to $181 million in 2010. The real first wholesale value
of Bristol Bay salmon production fell from $616 million in 1988 to $124 million in 2002, and
then rose to $390 million in 2010.
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            700
            600
                     Ex-Vessel and First Wholesale Value of Bristol Bay Sockeye Salmon
                                Harvests and Production, 1980-2010
-A- Real first
   wholesale value
   (2010$)
                                                                   -Nominal first
                                                                    wholesale value
                                                                 -0-Real ex-vessel
                                                                    value (2010$)
                                                                   •Nominal ex-
                                                                    vessel value
                OOOOOOO)O)O)O)O)
                O)O)O)O)O)O)O)O)
                                            CM   CM  CM   CM  CM  CM
                                      Source: CFEC, ADFG
                     Figure 77. Ex-Vessel and First Wholesale Value 1980-2010
Bristol Bay Salmon Industry Employment

The number of Bristol Bay permits fished each year has varied over time depending on economic
conditions in the fishery.  Over the past decades, between about 1200 and 1500 drift gillnet
permits and between about 700 and 900 set gillnet permits were fished each year.

On average, for each permit fished, about three people were engaged in fishing (the permit
holder and two crew members).  The estimated total number of people working in fishing during
the Bristol Bay season ranged from about 5500 to 7100. Because most of the commercial
harvest occurs within a period of a few weeks in late June and early July, annual average
employment in the fishery is much smaller than peak employment,  ranging from about 900 to
1200 over the past decade.

Over the past decade Bristol  Bay fish processors employed between about 2300 and 4500
workers, with annual average employment ranging from about 360  to 760.   Together, about
7,800-11,300 people worked seasonally in fishing and processing, for combined annual average
employment of 1200 to 1900.
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Geographic Distribution of Bristol Bay Salmon Fishery Participation and Earnings

Local residents of the Bristol Bay region account for a relatively small and declining share of
employment and earnings in the Bristol Bay salmon industry.  Non-Alaska residents account for
a relatively large and growing share of employment and earnings.
Table 46. Geographic Distribution of Bristol Bay Salmon Industry Employment and
Earnings.
         Geographic Distribution of Bristol Bay Salmon Industry Employment and Earnings:  Selected Measures

Measure
Permit holders, drift gillnet fishery
Permit holders, set gillnet fishery
Permit holders, total
Earnings, drift gillnet fishery (2007) ($000)
Earnings, set gillnet fishery (2007) ($000)
Earnings, total (2007) ($000)
Processing workers (2009)
Processing workers' earnings (2009) ($000)
Measure by Residency
Bristol Bay
region
residents
383
353
736
$14,273
$6,989
$21,262
76
$1,000
Other
Alaska
residents
471
311
782
$25,020
$6,071
$31,091
529
$3,025
Residents
of other
states or
countries
1,009
317
1,326
$58,821
$6,840
$65,661
3,916
$27,162
Total
1,863
982
2,845
$98,115
$19,900
$118,014
4,521
$31,187
Share of Total
Bristol Bay
region
residents
21%
36%
26%
15%
35%
18%
2%
3%
Other
Alaska
residents
25%
32%
27%
26%
31%
26%
12%
10%
Residents
of other
states or
countries
54%
32%
47%
60%
34%
56%
87%
87%
 Sources: Gho, Marcus, K. Iverson, C. Farrington, and N. Free-Sloan, "Changes in the Distribution of Alaska's Commercial
 Fisheries Entry Permits, 1975 - 2010," CFEC Report 11-3N (2011); Permit holder earnings: Iverson, Kurt, "Permit Holdings,
 Harvests, and Estimated Gross Earnings by Resident Type in the Bristol Bay Salmon Gillnet Fisheries," CFEC Rpt 09-IN (2009);
 Processing workers and earnings: Alaska Department of Labor and Workforce Development estimates,
 http://labor.alaska.gov/research/seafood/seafoodbristol.htm.
              50%
              40%
              30%
                      Local Bristol Bay Resident Share of the Bristol Bay Salmon Fisheries:
                                           Selected Measures
                                                       O  
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This does not mean, of course, that the Bristol Bay salmon fishery is unimportant as a source of
jobs or income for local residents.  It remains very important—but not as important as it would
be if all the jobs were held by local residents and all the income were earned by local residents.

A different perspective is that the Bristol Bay fishery is not just economically important for a
remote region of southwestern Alaska. Rather, it is of major economic importance for other
parts of Alaska  and other states, particularly the Pacific Northwest.  Thousands of residents of
other parts of Alaska and other states work in and earn significant income from participating in
Bristol Bay fishing and processing.

Distribution of Salmon Permits and Earnings within the  Bristol Bay Region

Within the Bristol Bay region, there is wide variation in the extent to which residents of different
communities participate in and derive income from the Bristol Bay salmon fisheries.  In 2010,
the number of permits held per 100 residents ranged from as high as 16 in the Bristol Bay
Borough to as low as 5 in the Upper Nushagak Region. Per  capita salmon fishery earnings
ranged from more than $7000 in the Bristol Bay Borough to only $1000  in the Upper Nushagak
Region.

Table 47. Relative Indicators of 2010 Salmon Fishery Participation and Earnings.
      Relative Indicators of 2010 Salmon Fishery Participation and Earnings, Bristol Bay Watershed Regions


Bristol Bay Borough
Togiak-Manokotak Region
South Bristol Bay Region
Dillingham Region
Lake Region
Upper Nushagak Region
Bristol Bay Watershed
Number of permit holders per 100 residents
Drift gillnet
fishery
6
6
10
5
3
5
5
Set gillnet
fishery
10
7
6
4
3
1
5
Combined
fisheries
16
13
15
9
6
5
10
Per capita salmon fishery earnings
Drift gillnet
fishery
$4,240
$2,417
$3,960
$2,623
$908
$1,002
$2,412
Set gillnet
fishery
$3,172
$2,410
$343
$1,160
$524
*
$1,407
Combined
fisheries
$7,411
$4,828
$4,302
$3,783
$1,432
$1,002
$3,819
 * Confidential. Sources: U.S. Censuses, 2000 and 2010; CFEC.

Economic Measures of the Bristol Bay Salmon Industry

There are many potential economic measures of the Bristol Bay salmon industry. Which
measure is most useful depends upon the question being asked. For example, if we want to know
how the Bristol Bay salmon fishery compares in scale with other fisheries, we should look at
total harvests or ex-vessel or wholesale value.  If we want to know how it affects the United
States balance of payments, we should look at estimated net exports attributable to the fishery. If
we want to know how much employment the industry provides for residents of the local Bristol
Bay region, Alaska or the United States, we should look at estimated employment in fishing and
processing for residents of these regions. If we want to know the net economic value attributable
to the fishery, we should look at estimated profits of Bristol Bay fishermen and processors.
These different measures vary widely in units, in scale, and how economically "important" they
make the fishery appear.
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Table 48. Selected Economic Measures of the Bristol Bay Salmon Industry, 2000-2010.

                      Selected Economic Measures of the Bristol Bay Salmon Industry, 2000-2010
Measure
Sockeye Salmon Havests
Millions offish
Millions of pounds
Bristol Bay harvest
volume as a share of:
Alaska sockeye salmon
World sockeye salmon
Alaska wild salmon (all species)
World wild salmon (all species)
World wild & farmed salmon
(all species)
Gross Value ($ mllions)
Ex -vessel value
First wholesale value
Total value of US exports of
Bristol Bay salmon products
Workers
Peak (July) fishing employment
Number offish processing
workers
Total
Estimated annual average
employment
Fishing
Fish processing
Total
Average permit price (S 000)
Drift gillnet fishery
Set gillnet fishery
Estimated total permit value ($
millions)
Drift gillnet fishery
Set gillnet fishery
Total
2000

21
125

61%
45%
18%
7%
3%

80
175
150









81
32

149.6
32.6
182.2
2001

14
96

56%
40%
12%
5%
2%

40
115
137

7,098
2,862
9,960

1,179
475
1,654

35
25

64.6
25.5
90.1
2002

11
65

48%
28%
10%
4%
1%

32
100
97

5,514
2,273
7,787

888
366
1,254

20
12

36.7
11.9
48.6
2003

15
93

50%
38%
13%
5%
2%

48
114
111

6,465
2,484
8,949

1,063
409
1,472

29
13

54.5
12.6
67.1
2004

26
152

59%
47%
19%
8%
3%

76
176
172

6,513
3,474
9,987

1,089
581
1,669

37
15

68.7
14.5
83.2
2005

25
155

58%
47%
16%
7%
3%

95
220
193

6,750
3,272
10,022

1,098
532
1,631

51
15

95.2
14.9
110.1
2006

28
165

69%
49%
22%
8%
3%

109
237
173

6,936
2,940
9,876

1,140
483
1,623

75
22

139.4
22.1
161.5
2007

30
173

62%
47%
18%
7%
3%

116
249
183

6,891
3,512
10,403

1,110
566
1,675

79
24

147.8
23.6
171.4
2008

28
160

71%
52%
23%
9%
3%

117
262
206

6,969
3,952
10,921

1,129
640
1,769

90
27

167.3
26.8
194.1
2009

31
183

71%
55%
25%
7%
3%

144
293
230

6,768
4,522
11,290

1,143
764
1,907

78
28

145.9
27.7
173.6
2010

29
170

74%





181
390
254









102
29

190.2
28.2
218.4
Avg.

23
140

62%
45%
18%
7%
2%

94
212
173

6,656
3,255
9,911

1,093
535
1,628

62
22

114.5
21.9
136.4
Range

11 - 31
65 - 183

48%- 74%
28%- 55%
10%- 25%
4%- 9%
1%- 3%

32 - 181
100 - 390
97 -254

5,514 -7,098
2,273 - 4,522
7,787 - 11,290

888 - 1,179
366 - 764
1,254 - 1,907

20 - 102
12 - 32

36.7 - 190.2
11.9 - 32.6
48.6 - 218.4
Economic impacts and net economic value of the Bristol Bay salmon industry are not necessarily
proportional to harvests or gross value, particularly in the short run.  Put differently, economic
impacts and net economic value are disproportionately affected by changes in value. A 1%
change in harvests results in less than a 1% change in fishing and processing employment—
particularly if it is unexpected. In contrast, because many of the costs of the fishery are fixed, a
1% change in value results in more than a 1% change in profits and net economic value.  For
these reasons, short term changes in future fish harvests would likely have less-than-proportional
or greater-than-proportional economic effects. Longer-term changes in fish harvests would tend
to have proportional economic effects as the scale of the fishing and processing industry changed
over time.
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Future Economic Importance of the Bristol Bay Salmon Industry

It is impossible to predict the future economic importance of the Bristol Bay salmon industry
with certainty.  Historically, catches, prices and value have varied dramatically both from year to
year and over longer-term periods of time.  They are likely to continue to vary.

No particular recent year or period is necessarily a good indicator of future Bristol Bay catches
and value.  However, it seems likely that future catches, prices and values will fall within the
wide range experienced between  1980 and 2010.


Table 49. Distribution of Selected Economic Measures for the Bristol Bay Commercial
Salmon Fishing Industry, 1980-2010

    Distribution of Selected Economic Measures for the Bristol Bay Commercial Salmon Fishing Industry, 1980-2010
Measure
Total sockeye salmon harvest (million fish)
Total sockeye salmon harvest (million pounds)
Ex-vessel price paid to fishermn ($/lb)
Average first wholesale price, frozen H&G salmon ($/lb)
Average first wholesale price, canned salmon ($/lb)
Total ex-vessel value ($ millions)
Total first wholesale value ($ millions)
Drift gillnet permit price ($ thousands)
Set gillnet permit price ($ thousands)
Estimated total permit value ($ millions)
Minimum
10.0
57.7
$0.53
$1.48
S2.21
39.3
123.9
24.3
14.7
60.0
10th
percentile
14.0
87.8
$0.61
SI. 64
$2.32
89.5
160.8
43.6
17.2
113.3
Mean
24.8
145.6
$1.31
S2.18
$3.05
184.0
324.8
180.5
54.2
375.6
90th
percentile
35.2
195.5
$2.18
$2.73
$3.86
311.8
486.2
311.6
83.6
623.6
Maximum
44.2
243.6
$3.79
$3.77
$5.72
359.2
616.5
434.7
107.2
879.5
Standard
deviation
8.8
48.8
$0.70
$0.54
$0.76
90.5
131.2
106.1
27.0
212.0
 Note: All prices and values are adjusted for inflation to real 2010 dollars. 10th and 90th percentiles are interpolated. Estimated
 total permit value calculated by mulltiplying average permit prices by the number of permanent permits renewed. First wholesale
 prices and values are for the years 1984-2010. Data are from Alaska Department of Fish and Game and Commercial Fisheries
 Entry Commission.
3.15 Appendix:  Data Sources

A rich variety of data exists for the Bristol Bay commercial salmon fishery.  However, the data
can be difficult and confusing to work with, for a number of reasons.  Some data are not
published, and are available only upon request from Alaska state government agencies. Many
data series are available only for limited periods of time: some have been discontinued and are
not available for recent years; others have been collected or published only beginning relatively
recently and are not available for earlier years.  Many data series are inconsistent: reports
published by the same agency in different years may provide different data for the same series.
Preliminary data (particularly for prices and values) are often revised later, sometimes
substantially.  Some kinds of data are confidential except when aggregated for minimum
threshold numbers of permit holders, processors or other firms. Some kinds of data are
proprietary (particularly price data gathered by private market information services). Most
importantly, what data mean, how they were collected or estimated, and how reliable they are is
often unclear. For all these reasons,  pulling together the variety of data presented in this report
                                            153

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was a significant task, building on a variety of research conducted over many years, much of it
devoted to finding data sources and learning what they meant (and didn't mean).

The purpose of this appendix is to document, as best practical, the sources for the analysis, both
for the benefit of readers and for other researchers. The appendix provides details on the data
sources for all of the text references, graphs and tables in this report, except where the source is
obvious or reported in detail in the text.

This section begins with a description of the major data sources for this report (those used
multiple times), listed in alphabetical order of the names used to refer to them.

This section then describes the sources for all data provided in the report, text, figures and tables,
except where the source information is provided in the report or is otherwise clear. These are
listed in the chronological order in which they appear in the report.

The final section of the appendix provides the price index data used to convert selected prices
and values in the report from "nominal" dollars (not adjusted for inflation) to "real" dollars
(adjusted for inflation).

Researchers wishing more detailed information about data sources may contact Gunnar Knapp at
Gunnar.Knapp@uaa.alaska.edu or 907-786-7717.

                           Major Data Sources for This Report

Below are descriptions of the major data sources used in this report (those used multiple times),
listed in alphabetical order of the names used to refer to them (shown in bold font). Website
addresses were current as of October 2011 for all data found online.

ADFG Annual Run Forecasts and Harvest Projections. Each year the Alaska Department of
Fish and Game publishes  a report on "Run Forecasts and Harvests Projections for Alaska Salmon
Fisheries" for the current year, which also includes a review of the salmon fisheries for the
previous season. This report includes forecasts for the coming  season of commercial sockeye
salmon harvests in Bristol Bay. The reports for the most recent years are available at the
"Commercial Salmon Fisheries Forecasts" website:

http://www.adfg.alaska.gov/index.cfm?adfg=commercialbvfisherysalmon.salmonforecast

Reports for earlier years available on the Alaska Department of Fish and Game "Fishing and
Subsistence" Publications Searchable Database at:

http ://www. adfg. alaska. gov/sf/publications/

To find them, search for the following: Report = All Reports; Field = Title; Operator =
Contains; Search String = Forecast. Then scroll through several  pages out output until you
come to "Commercial Fisheries Reports."
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ADFG Bristol Bay Annual Management Reports.  These are detailed reports for each salmon
season compiled by Alaska Department of Fish and Game Division of Commercial Fisheries
Bristol Bay area management staff. Each report also contains an extensive data appendix with
dozens of tables of catches and escapements by district, day, gear type, etc. The reports are
available on the Alaska Department of Fish and Game "Fishing and Subsistence" Publications
Searchable Database at:

http ://www. adfg. alaska. gov/sf/publications/

To find them, search for the following:  Report = Commercial Fisheries Annual Management
Reports; Field = Title;  Operator = Contains;  Search String =  Bristol Bay.

ADFG Bristol Bay Salmon Season Summaries. These are news releases prepared by compiled
by Alaska Department of Fish and Game Division of Commercial Fisheries Bristol Bay area
management staff after each Bristol Bay salmon season after each salmon season which
summarize catches and preliminary ex-vessel price information. The news releases are available
on the ADFG Bristol Bay website at:

http://www.cf.adfg.state.ak.us/region2/fmfish/salmon/salmhom2.php

ADFG Commercial Operator Annual Report (COAR) Data. In April of every year, all
Alaska fish processors are required to submit "Commercial Operator Annual Reports" to the
Alaska Department of Fish and Game. In these reports they are required to report the total
volume offish purchased, by species and area; the total amount paid for fish purchased, by
species and area; the total volume (weight) of production, by  product, species and area; and the
total  first wholesale value  of production. Information about the COAR reporting forms is at:

http://www.adfg.alaska.gov/index.cfm?adfg=fishlicense.coar

The COAR data are not posted on the internet or published regularly by ADF&G (which is
unfortunate), but are available by special request from ADF&G. The data used for this report
were provided on August 2, 2011 to Gunnar Knapp and were saved as Excel file "Statewide and
regional COAR production 1984-2011 provided by ADFG 8-2-1 l.xls." Average "first wholesale
prices" were calculated by dividing first wholesale value by production volume.

ADFG Alaska Commercial Salmon Harvests and Ex-vessel Values Reports. These reports
provide summary annual data for each of 11  Alaska salmon harvest areas. The data include
average fish weight, average price per pound, numbers offish, harvest volume in pounds, and
estimated value in dollars. Prices for the most recent year are generally preliminary estimates
based on fish tickets and reports from area managers. Prices for earlier years are generally based
on "Commercial Operators Annual  Report and area staff reports." The reports are available at:

http://www.adfg.alaska.gov/index.cfm?adfg=commercialbyfisherysalmon.salmoncatch

ADFG Salmon Ex-Vessel Price Time  Series by Species 1984-2008. This is a two-page table
of ex-vessel prices by species, 1984-2008, for the following areas:  Cook Inlet, Kodiak, Alaska


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Peninsula, Bristol Bay, Prince William Sound, Southeast, and Statewide.  Original source is cited
as the Commercial Operator Annual Reports database.
http ://www. cf. adfg. state. ak.us/geninfo/fmfish/salmon/catchval/blusheet/84-08exvl .pdf

ADLWD Bristol Bay Region Fishing and Seafood Industry Data. The Alaska Department of
Labor and Workforce Development (ADLWD) Research and Analysis Division posts a variety
of economic information for the Bristol Bay Seafood Industry on its "Bristol Bay Region Fishing
and Seafood Industry Data" website at:

http://labor.alaska.gov/research/seafood/seafoodbristol.htm.

ADOR Annual Salmon Price Reports. Every year, "large" Alaska salmon processors (those
with sales exceeding 1 million pounds in the previous calendar year) are required to report sales
volumes and first wholesale values for major salmon product categories to the Alaska
Department of Revenue. Annual  statewide summary reports of these data are available on the
Alaska Department of Revenue's Tax Division Reports website at:

http://www.tax.alaska.gOv//programs/reports.aspx

Once on this page, click on "Alaska Salmon Price/Production." Note that the "Annual Salmon
Price Reports" differ from (and sometimes are inconsistent with the "Annual Salmon Production
Reports" and "Monthly Salmon Price Reports" which are also available at the  same website.

ADOR Canned Salmon Wholesale Price Reports. For many years prior to 2001, the Alaska
Department of Revenue prepared "Canned Salmon Average Wholesale Reports." These reported
monthly statewide average prices for canned salmon, by species, compiled from information
reported by Alaska salmon processors. The University of Alaska Anchorage Institute of Social
and Economic Research (ISER) maintains a collection of these reports beginning with the period
April l-September30, 1983.

ADOR Monthly Salmon Price Reports.  Every four months, large Alaska salmon processors
(those with sales exceeding 1 million pounds in the previous calendar year) are required to
submit salmon price reports to the Alaska Department of Revenue for the following four-month
periods:  January-April, May-August, and September-December.
The reports include sales volumes and first wholesale values for major salmon product, by area
and month. Summaries of the data from these reports, for each four-month period, are available
on the Alaska Department of Revenue's Tax Division Reports website at:

 http://www.tax.alaska.gOv//programs/reports.aspx.

Once at this page, click on "Alaska Salmon Price/Production." Note that  these "Monthly Salmon
Price Report"  differ from (and sometimes are inconsistent with the "Annual Salmon Price
Reports" and the "Annual  Salmon Production Reports" which are also available at the same
website.  Data are not reported for product-area-month combinations for  which fewer than three
processors reported sales.
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CFEC Basic Information Tables. The Commercial Fisheries Entry Commission (CFEC) posts
"Basic Information Tables" for each Alaska salmon fishery on its website at:

http ://www. cfec. state. ak.us/bit/MNUS ALM.htm

These tables provide a useful summary of trends since 1975 in each salmon fishery for numbers
of permits issued/renewed, numbers of permits fished, total pounds harvested, average pound
harvested, gross earnings, average earnings, and average annual permit prices. The most recent
data currently available are for 2010.

CFEC Data for Alaska Salmon Harvests 1980-2005. 1980-2005: CFEC Alaska Salmon
Summary Data 1980-2005 061113. These are Commercial Fisheries Entry Commission data for
Alaska commercial salmon harvest (number offish, pounds, earnings, and price), by species, for
the years 1980-2005.  This file was prepared by the Commercial Fisheries Entry Commission on
March 31, 2005, in response to a request by Professor Gunnar Knapp of the University of Alaska
Anchorage Institute of Social and Economic Research (ISER). The data was provided as an
Excel file named SWPrices.xls, containing the worksheet of this file named "Original data."
Professor Knapp maintains a copy of the file named "CFEC_Alaska_Salmon_Summary_Data
_1980-2005.xls."  The data were calculated from CFEC fish ticket database.  The harvest and
earnings figures include set and drift gill net, test fishing, confiscated and educational permit
harvests, and any other harvest where the product was sold.

CFEC Data for Bristol Bay Salmon Harvests 1975-2003. These are Commercial Fisheries
Entry Commission data for Bristol Bay commercial salmon harvests for the years 1975-2003,
provided by Kurt Iverson, June 9, 2004, as file BBayEarnHarvl.xls. The data were calculated
from CFEC fish ticket database.  The harvest and earnings figures include set and drift gill  net,
test fishing, confiscated and  educational permit  harvests, and  any other harvest where the product
was sold.

CFEC Quartile Tables. The Commercial Fisheries Entry Commission (CFEC) posts annual
"Quartile Tables" for each Alaska salmon fishery on its website at:

 http://www.cfec.state.ak.us/quartile/mnusalm.htm

These tables show the number  of permit holders and average  earnings per permit holder in  each
"quartile group"—calculated by ranking permit holdings in each year by earnings, and then
dividing them into four "quartile" groups with equal total earnings. The first quartile has the
smallest number of permit holders with the highest average earnings; the fourth quartile has the
highest number of permit holders with the lowest average earnings.

CFEC Permit and Fishing  Activity Data. The Commercial Fisheries Entry Commission
(CFEC) posts annual data on permit and fishing activity by year, state, census area and Alaska
city on its website at:

http://www.cfec.state.ak.us/fishery statistics/earnings.htm
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For each state, census area and city in which permit holders reside, and for each fishery for
which residents held permits, data include the number of permits issued, number of permit
holders, number of permits with recorded landings, total pounds landed and estimated gross
earnings. Earnings data are confidential for fisheries in which fewer than four permit holders in a
census area or community had landings.

FAO FishstatJ Database. FAO FishstatJ is software for fishery statistical time series developed
by the Food and Agricultural Organization of the United Nations (FAO) Fisheries and
Aquaculture Department, based in Rome.  The software is designed to be used with global
datasets for capture (wild) fisheries catches and aquaculture production, by species, country and
year. The software and the global datasets can be downloaded from the FAO Fisheries and
Aquaculture Department website at:

http://www.fao.org/fi shery/stati stics/software/fi shstatj /en

NMFS Commercial Fishery Landings Database.  The National Marine Fisheries Service
(NMFS) Office of Science and Technology maintains an online database of US Commercial
Fishery Landings (volume and value) by state, species and year. Customized datasets for Alaska
and other states may be downloaded  from NMFS Commercial Fishery Landings webite at:

http://www.st.nmfs.noaa.gov/stl/commercial/index.html

NMFS Foreign Trade in Fisheries  Products Data. The National Marine Fisheries Service
posts very detailed data online about U.S. exports and imports of fisheries products at:

http://www.st.nmfs.noaa.gov/stl/trade/

The export data in this report were calculated from the "Monthly Trade Data by Product,
Country/Association" option at this website.

NMFS Major Ports Data. The National Marine Fisheries Service publishes an annual report
entitled Fisheries of the United States which provides a wide variety of useful data on United
States fisheries. A regular table in this report (on page 7 in recent years), entitled "Commercial
Fishery Landings and Value at Major U.S. Ports," lists the value and volume of landings for the
top 50 United States ports (ranked by value). The Fisheries of the United States reports are
available at:

http://www.st.nmfs.noaa.gov/stl/publications.html

                    Data Sources  for Report Text, Figures and Tables

Below are descriptions of the sources for data provided in the report text, figures and tables.
Except where text sources are given below, the data in the text is from the same sources as the
adjacent figures and tables in the same sections of the report. Except where text sources are
given below, all of the material discussed in the "Overview" and "Summary" sections of the
report is discussed in greater detail in corresponding sections of the report. Refer to the body of


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the report for more details as well as sources for information presented in the "Overview" and
"Summary" sections.

Page 51.  "Annual harvests of 31 million salmon ..."  Source: ADFG Alaska Commercial
Salmon Harvests and Exvessel Values Reports.

Page 51.  "57% of world sockeye salmon harvests. " Source: See discussion below of sources
for Figure 22 (World Sockeye Supply).

Page 51.  "Annual ex-vessel" value to fishermen of $129 million. " Source: ADFG Alaska
Commercial Salmon Harvests and Exvessel Values Reports.

Page 51.  "Annual first wholesale value ... of $268 million." ADFG Commercial Operator
Annual Report (COAR) Data.

Page 51.  "26% of the ex-vessel value ..." Source: ADFG Alaska Commercial Salmon
Harvests and Exvessel Values Reports.

Page 51.  "Seasonal employment of more than 6800 fishermen and 3 700 processing workers. "
Source:  See sources for Table 36, page 112.

Figure 11. Bristol Bay Commercial Salmon Harvests.  Sources:  1975-2003:  CFEC Data for
Bristol Bay Salmon Harvests; 2004-2010: ADFG Alaska Commercial Salmon Harvests and
Exvessel Values Reports; 2011:  ADFG 2011 Bristol Bay Salmon Season Summary (9/26/2011).

Page 56.  "The average weight of a Bristol Bay sockeye salmon is typically about 6 pounds. . . .
average weights varied from as low as 5.3 pounds to as high as 6.7 pounds. "  Data sources are
the same as for Figure 11.

Figure 12. Bristol Bay Fishing Districts. Average annual harvests for the years 1991-2010 were
calculated from the  same data used for Figure  13.

Figure 13. Bristol Bay Commercial Sockeye Salmon Harvests, by District. Sources: 1986-1989:
ADFG Bristol Bay Annual Salmon Management Report, 2006, Appendix A3 .-Sockeye salmon
commercial catch by district, in numbers offish, Bristol Bay, 1990-2010;  1990-2010: ADFG
Bristol Bay Annual Salmon Management Report, 2010, Appendix A3.-Sockeye salmon
commercial catch by district, in numbers offish, Bristol Bay, 1990-2010. 2011: ADFG Bristol
Bay Salmon Season Summary, 2011.

Figure 14. Share of Bristol Bay Commercial Sockeye Salmon Harvest, by District.  Same
sources as for Figure 13.

Figure 15. Naknek-Kvichak District Sockeye  Salmon Harvests, by River of Origin. Compiled
from ADFG Bristol Bay Annual Management Reports for each year (usually tables 18, 19 or 20).
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Table 27. Comparison of Bristol Bay Drift Gillnet and Set Gillnet Fisheries (2006-10 Averages).
Source:  CFEC Basic Information Tables.

Figure 16. Bristol Bay Salmon Harvests, by Fishery. Source: CFEC Basic Information Tables.

Figure 17. World Sockeye Salmon Supply. Bristol Bay:  Sources are the same as for Figure 16.
Other Alaska: Calculated by subtracting Bristol Bay data from Alaska data. Alaska data:  1980-
2005: CFEC Data for Alaska Salmon Harvests 1980-2005; 2006-2009:   ADFG Alaska
Commercial Salmon Harvests and Exvessel Values Reports. Lower 48:  NMFS Commercial
Fishery Landings Database, data for Washington, Oregon and California; Canada, Russia and
Japan: FAO FishstatJ Database.

Figure 18. Alaska Salmon Supply. Bristol Bay sockeye:  Sources are the same as for Figure 11.
Other Alaska sockeye:  Calculated by subtracting Bristol Bay data from Total Alaska data.  Total
Alaska data:  1980-2005: CFEC Data for Alaska Salmon Harvests 1980-2005; 2006-2009:
ADFG Alaska Commercial Salmon Harvests and Exvessel Values Reports.

Figure 19 World Salmon and Trout Supply. Wild salmon:  Sources are the same as for Figure 17.
Farmed salmon and farmed trout:  FAO FishstatJ Database. Includes only farmed production of
Atlantic, Coho and Chinook salmon. Includes only farmed rainbow trout farmed in a
"mariculture" (saltwater) environment.

Figure 20. Bristol Bay Sockeye Preseason Projection and Annual Commercial Catch. Preseaon
Projections: 1990-2005: ADFG Bristol Bay Annual Management Reports; Beginning 2006:
ADFG Annual Run Forecasts and Harvest Projections. Actual harvests:  same sources for Figure
11.

Figure 21 Bristol Bay Sockeye Salmon Harvests, 1895-2009. 1893:-1997:  Byerly, Mike;
Beatrice Brooks, Bruce Simonson, Herman Savikko and Harold Geiger.  1999.  Alaska
Commercial Salmon Catches, 1878-1997. Alaska Department of Fish and Game Regional
Information Report No. 5J99-05. March 1999.  1998-2003: CFEC Data for Bristol Bay Salmon
Harvests 1975-2003.  2004-2011: ADFG Alaska Commercial Salmon Harvests and Exvessel
Values Reports.

Figure 22. Bristol Bay Sockeye Salmon Production. ADFG Commercial Operator Annual Report
(COAR) Data.

Figure 23. Share of Sockeye Salmon Production in Bristol Bay. ADFG Commercial Operator
Annual Report (COAR) Data.

Table 28. Sales of Selected Sockeye Salmon Products by Major Bristol Bay Salmon Processors.
ADOR Annual Salmon Price Reports.

Figure 24. Bristol Bay Sockeye Salmon Harvests and Production. Harvests: See sources for
Figure 11. Production: ADFG Commercial Operator Annual Report (COAR) Data.
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Figure 25. Monthly Sale Volume of Bristol Bay Salmon Products. ADOR Monthly Salmon
Reports

Figure 26. Alaska Frozen Sockeye Production and U.S. Frozen Sockeye Exports. ADFG
Commercial Operator Annual Report (COAR) Data; NMFS Foreign Trade in Fisheries Products
Data.

Figure 27. Estimated End-Markets for Alaska Frozen Sockeye Salmon. Sources:  ADFG
Commercial Operator Annual Report (COAR) Data; NMFS Foreign Trade in Fisheries Products
Data.  The estimates for the "USA" were calculated by subtracting exports from Alaska
production as reported in the COAR data. For the years 1989-1992 reported exports exceeded
reported Alaska production.  The estimate for the USA was assumed to be zero for these years.
This is almost certainly an underestimate. In reality, some frozen sockeye production
undoubtedly went to the US market, but the production and export data suggest that the amount
going to the US market was relatively low, with most of the production being exported.

Figure 28. Alaska Canned Sockeye Production and U.S. Canned Sockeye Exports.  Sources:
ADFG Commercial Operator Annual Report (COAR) Data; NMFS Foreign Trade in Fisheries
Products Data.

Figure 29. Average Ex-Vessel Price of Bristol Bay Sockeye Salmon.  See data sources for Figure
11. Real prices calculated using Anchorage CPI, as discussed below.

Figure 30. Average Wholesale and Ex-Vessel Prices of Bristol Bay Sockeye Salmon. Ex-vessel
prices: See data sources for Figure 11. Wholesale Prices:  ADFG Commercial Operator Annual
Report (COAR) Data.

Figure 31. Average Monthly First Wholesale Prices.  Sources: ADOR Monthly Salmon Price
Reports

Figure 32. Average Wholesale and Ex-Vessel Prices, Bristol Bay and Rest of Alaska. Rest-of-
Alaska wholesale and ex-vessel prices were calculated by dividing Rest -of -Alaska value by
Rest-of-Alaska volume.  Rest-of-Alaska wholesale value and volume were calculated by
subtracting  Bristol Bay wholesale value and volume from total Alaska wholesale value and
volume, as reported in ADFG Commercial Operator Annual Report (COAR) Data. Rest-of-
Alaska ex-vessel value and volume were calculated by subtracting Bristol Bay ex-vessel value
and volume (from sources for Figure 16, page 61) from total Alaska ex-vessel value and volume.
Sources for total Alaska ex-vessel value and volume were: 1980-2005: CFEC Data for Alaska
Salmon Harvests 1980-2005; 2006-2009: ADFG Alaska Commercial Salmon Harvests and Ex
vessel Values Reports.

Figure 33. Average Ex-Vessel Prices of Sockeye Salmon, Selected Alaska Areas. Sources:
ADFG Alaska Commercial  Salmon Harvests and Exvessel Values Reports.

Figure 34. Japanese Red-Fleshed Salmon Imports, May-April. Sources: Japanese monthly
import data reported in Bill Atkinson's News Report (a weekly compilation of articles and


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information from the Japanese seafood industry press, translated into English, published until
2006 by industry analyst Bill Atkinson) and Japanese import data reported on the National
Marine Fisheries Service "Fishery Market News" website at:
http ://www. st. nmfs .noaa. gov/st 1/market_news/index .html.

Figure 35. Japanese Red-Fleshed Frozen Salmon Imports & Wild Sockeye Wholesale Prices.
Japanese red-fleshed salmon imports are data for May-April, from the same sources as for Figure
34. Sockeye wholesale price data are average prices for the period May-April, from the same
sources as for Figure 36.

Figure 36. Japanese Wholesale Prices and Bristol Bay Prices for Sockeye Salmon. Source for
ex-vessel price: see  sources for Figure 11. Source for average first wholesale price:  ADFG
Commercial Operator Annual Report (COAR) Data. Sources for Japanese monthly wholesale
prices: January 1980-December 1989: Tokyo Central Wholesale Market reports, average price
for all frozen sockeye.  January 1990-April 2002.  Suisan Tsushin (Seafood News), Marine
Products Power Data Book, 2002. Beginning May 2002:  Japanese frozen market salmon prices
posted on www.fis.com and the predecessor "Seaworld" website (data are prices reported for the
first day of the month). Monthly wholesale prices in yen/kilo converted to prices in $/lb using
monthly Japanese exchange rate data reported on the website of the Federal Reserve Bank of St.
Louis (series EXJPUS, available at:  http://research.stlouisfed.org/fred2/series/EXJPUS).

Figure 37. Average United States Import Prices of Selected Farmed Salmon Products. Source:
NMFS Foreign Trade in Fisheries Products data.

Figure 38. U.S. Wholesale Prices for Selected Wild and Farmed Salmon Products. Prices are
from Urner Barry's Seafood Price-Current, a twice-weekly market report for U.S. seafood
wholesale prices. Data shown in the figure are "low" reported prices for the first reporting date
of the month.  Products are as follows: "Fresh farmed Atlantic, whole fish": Northeast,
Domestic and Canadian Atlantic, 6-8 Ibs; "Fresh farmed Atlantic, pinbone-out fillets": Fob
Miami, Chilean Atlantic Fillets, Scale-on/Standard,  C  Trim/Premium,Pinbone out, 2-3 Ibs;
"Frozen H&G wild sockeye":  Red/Sockeye, Gillnet, 4-6 Ibs. Information on Seafood Price-
Current is at www.urnerbarry.com.

Figure 39. Monthly Average Wholesale Case Prices for Alaska Canned Sockeye Salmon. Data
through August 2000:  ADOR Canned Salmon Wholesale Price Reports (statewide data for
canned sockeye salmon).  Data beginning September 2000: ADOR Monthly Salmon Price
Reports (data for Bristol Bay canned sockeye salmon).

Figure 40. Estimated Chilled and Unchilled Shares of Bristol Bay Salmon Harvests. Northern
Economics, 2010 Bristol Bay Processor Survey. Prepared for Bristol Bay Regional Seafood
Development Association, February 2011.  Available at:
http://www.bbrsda.com/layouts/bbrsda/files/documents/
bbrsda_reports/BB-RSDA%202010%20Survey%20Final%20Report.pdf
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Figure 41. Ex-Vessel and First Wholesale Value of Bristol Bay Sockeye Salmon Harvests and
Production, 1984-2010. Ex-vessel value:  Same data sources as for Figure 11. Wholesale value:
ADFG Commercial Operator Annual Report (COAR) Data.

Figure 42. Distribution of Nominal Value of Bristol Bay Sockeye Salmon. Sources for ex-vessel
value and wholesale value are the same as for Figure 46, page 94. Value to processors after
deducting payments to fishermen was calculated by subtracting ex-vessel value from wholesale
value.

Figure 43. Distribution of Value of Bristol Bay Sockeye Salmon. Calculated from data used for
Figure 42.

Figure 44. Number of Limited Entry Permits Issued and Fished in Bristol Bay. Source: CFEC
Basic Information Tables.

Figure 45. Average Gross Earnings of Bristol Bay Drift Gillnet Permit Holders, by Quartile.
Source: CFEC Quartile Tables.

Figure 46. Average Gross Earnings of Bristol Bay Set Gillnet Permit Holders, by Quartile.
Source: CFEC Quartile Tables.

Figure 47. Average Prices Paid for Bristol Bay Limited Entry Permits. Source: CFEC Basic
Information Tables.

Figure 48. Average Permit Prices and Total Earnings:  Bristol Bay Drift Gillnet Fishery. Source:
CFEC Basic Information Tables.

Figure 49. Average Permit Prices and Total Earnings:  Bristol Bay Drift Gillnet Fishery. Source:
CFEC Basic Information Tables.

Figure 51. Number of Companies Reporting Salmon Production in Bristol Bay, by Product.
Source:  ADFG Commercial Operator Annual Report (COAR) Data.

Figure 52. Selected Bristol Bay Salmon Processor Costs, 2001-2009. "Cost of labor" data are
ADLWD Bristol Bay Region Fishing and Seafood Industry Data. They are from the column
titled "Seafood Processing Wages" in a table named "Bristol Bay Region Seafood Industry 2003-
2009" (as well as earlier versions of the same table no longer posted online) posted at:

http://labor.alaska.gov/research/seafood/BristolBay/BBoverall.pdf

The data  are also accessible by clicking on "Harvesting and Processing Workers and Wages" at
the ADLWD Bristol Bay Region Fishing and Seafood Industry Data website. "Cost offish" are
ex-vessel values from the same data sources as Figure 11. "Other costs and profits" were
calculated by subtracting "cost of labor" and "cost offish" from wholesale value, as reported in
ADFG Commercial Operator Annual Report (COAR) Data.
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Figure 54. Monthly Employment in Food Manufacturing, Bristol Bay Region, 2002-2007.
Alaska Department of Labor and Workforce Development, Quarterly Census of Employment
and Wages Data, historical data for 2002-2010, Excel file annual.xls, downloaded November 27,
2011 from:

http://labor.alaska.gov/research/qcew/qcew.htm

Table 34. Selected Data and Estimates for Bristol Bay Taxes. Ex-vessel value of Bristol Bay
salmon harvests: see data sources for Figure 11. Canned and non-canned share of production:
ADFG Commercial Operator Annual Report (COAR) Data.

Figure 56. Number of Bristol Bay Permit Holders by Residency. Source:  Gho, Marcus, K.
Iverson, C. Farrington, and N. Free-Sloan,  Changes in the Distribution of Alaska's Commercial
Fisheries Entry Permits,  1975 - 2010, CFEC Report 11-3N (2011), Appendix C.  Available at:

 http://www.cfec.state.ak.us/RESEARCH/12-lN/12-lN.htm

Figure 57. Permit Holders Average Earnings, by Residency.  Source: Kurt Iverson, CFEC
Permit Holdings, Harvests, and Estimated Gross Earnings by Resident Type in the Bristol Bay
Salmon Gillnet Fisheries, CFEC Report 09-IN (February, 2009). Available at:

http://www.cfec.state.ak.us/RESEARCH/09  IN/09 IN.pdf.

Figure 58. Share of Total Earnings of Bristol Bay Drift Gillnet Permit Holders, by Residency.
Same source as for Figure 57.

Figure 58. Share of Total Earnings of Bristol Bay Set Gillnet Permit Holders, by Residency.
Same source as for Figure 57.

Figure 60. Share of Bristol Bay Seafood Processing Employment, by Residency. Source:
ADLWD Bristol Bay Region Fishing and Seafood Industry Data, posted at:

http://labor.alaska.gov/research/seafood/seafoodbristol.htm

In particular, see the following tables:

(A) "Bristol Bay Region Seafood Industry, 2003-2009, Processing" at:
http://labor.alaska.gov/research/seafood/BristolBay/BBSFPOver.pdf

(B) "Local Seafood Processing Workforce, 2003-2009, Bristol Bay Region" at:
http://labor.alaska.gov/research/seafood/BristolBay/BBSFPLocal.pdf

The number and percentage of residents of other states or countries was calculated from data in
(A). The number and percentage of Bristol Bay residents was calculated from data in (B). The
share of "Other Alaska residents" was calculated as the residual.
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Figure 61. Local Bristol Bay Resident Share of Salmon Fisheries:  Selected Measures.  Source
for local resident share of total permits held: Gho, Marcus, K. Iverson, C. Farrington, and N.
Free-Sloan, Changes in the Distribution of Alaska's Commercial Fisheries Entry Permits, 1975 -
2010, CFEC Report 11-3N (2011),  Appendix C. Available at:

http://www.cfec.state.ak.us/RESEARCH/12-lN/12-lN.htm

Source for local resident share of total earnings: Iverson, Kurt, CFEC Permit Holdings,
Harvests, and Estimated Gross Earnings by Resident Type in the Bristol Bay Salmon Gillnet
Fisheries, CFEC Report 09-1N (2009).  Available at:

http://www.cfec.state.ak.us/RESEARCH/09 IN/09  IN.pdf

Source for local resident share of processing employment: Alaska Department of Labor and
Workforce Development, "Local Seafood Processing Workforce, 2003-2009, Bristol Bay
Region," available at:

http://labor.alaska.gov/research/seafood/BristolBay/BBSFPLocal.pdf
Table 37. Population, Permit Holders, and Salmon Earnings, by Community: 2000 & 2010.
Source for population: U.S. Census, 2000 and 2010, in "Alaska Population Estimates by
Borough, Census Area, City and Census Designated Place (CDP), 2000-2011," Excel
spreadsheet available on website of Alaska Department of Labor and Workforce Development,
Research and Analysis Division at:

http://labor.alaska.gov/research/pop/popest.htm

Source for numbers of permit holders and earnings: CFEC Permit and Fishing Activity Data.

Figure 63. Estimated Bristol Bay Population, by Area and Region. Data for 2000-2010 are from
"Alaska Population Estimates by Borough, Census Area, City and Census Designated Place
(CDP), 2000-2011," Excel spreadsheet available on website of Alaska Department of Labor and
Workforce Development, Research and Analysis Division, at:

http://labor.alaska.gov/research/pop/popest.htm

Data for 1984-1999 are from Northern Economics, The Importance of the Bristol Bay Salmon
Fisheries to the Region and its Residents, Report prepared for the Bristol Bay Economic
Development Corporation (October 2009), Tables A1-A12.

Figure 63 [TOP FIGURE]. Estimated Bristol Bay Population, by Area. Data for 2000-2010 are
from "Alaska Population Estimates by Borough, Census Area, City and Census Designated Place
(CDP), 2000-2011," Excel spreadsheet available on website of Alaska Department of Labor and
Workforce Development, Research and Analysis Division.  Data for 1984-1999 are from
Northern Economics, The Importance of the Bristol Bay Salmon Fisheries to the Region and its
Residents, Report prepared for the Bristol Bay Economic Development Corporation (2009),
Tables A1-A12.
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Figure 63 [BOTTOM FIGURE]. Estimated Population by Region. Data for 2000-2010 are from
"Alaska Population Estimates by Borough, Census Area, City and Census Designated Place
(CDP), 2000-2011," Excel spreadsheet available on website of Alaska Department of Labor and
Workforce Development, Research and Analysis Division. Data for 1984-1999 are from
Northern Economics, The Importance of the Bristol Bay Salmon Fisheries to the Region and its
Residents, Report prepared for the Bristol Bay Economic Development Corporation (2009),
Tables A1-A12.

Figure 65 [TOP FIGURE]. Number of Drift Gillnet Holders, by Region. Source: CFEC Permit
and Fishing Activity Data.

Figure 65 [BOTTOM FIGURE]. Number of Drift Gillnet Holders per 100 Residents, by Region.
Calculated by dividing data for number of drift gillnet holders, shown in Figure 65 [TOP
FIGURE], by data for estimated population by region, from the same sources as for Figure 63
[BOTTOM FIGURE].

Figure 67 [TOP FIGURE]. Number of Set Gillnet Holders, by Region.  Source:  CFEC Permit
and Fishing Activity Data.

Figure 67 [BOTTOM FIGURE]. Number of Set Gillnet Holders per 100 Residents, by Region.
Calculated by dividing data for number of set gillnet holders, shown in Figure 67 [TOP
FIGURE], by data for estimated population by region, from the same sources as for Figure 63
[BOTTOM FIGURE].

Table 38. Salmon Permit Holders per 100 Residents, by Community. Calculated by dividing
data for number of permit holders by community, from CFEC Permit and Fishing Activity Data,
by data for population by community, from the same sources as for Figure 63 [BOTTOM
FIGURE].

Figure 69 [TOP FIGURE]. Total Salmon Fishery Earnings, by Region. Source: CFEC Permit
and Fishing Activity Data.

Figure 69 [BOTTOM FIGURE]. Per Capita Salmon Fisheries Earnings, by Region. Calculated
by dividing data for total salmon fisheries earnings, shown in Figure 69 [TOP FIGURE], by data
for estimated population by region, from the same sources  as for Figure 63 [BOTTOM
FIGURE].

Table 39. Bristol Bay Salmon Fishery Earnings, by Community, 2000 and 2010.  Calculated by
dividing data for salmon fishery earnings by community, from CFEC Permit and Fishing
Activity Data, by data for population by community, from the same sources as for Figure 63
[BOTTOM FIGURE].

Table 40. Economic Measures of Bristol Bay Salmon Industry: Sockeye Salmon Harvests.
Same sources as for Figure 11, Figure 17, Figure 18 and Figure 19.
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Figure 70.  Bristol Bay Commercial Salmon Harvests. Same sources as for Figure 16.

Table 41.  Economic Measures of Bristol Bay Salmon Industry:  Sockeye Value. Source for ex-
vessel value is the same as for Figure 11.  Source for first wholesale value is ADFG Commercial
Operator Annual Report (COAR) Data. Source for Bristol Bay ex-value used in calculation of
Bristol Bay sockeye salmon shares of value is the same as for Figure 11. Source of Alaska wild
salmon ex-vessel value used to calculate Bristol Bay share of Alaska wild salmon ex-vessel
value is the same as for Alaska data for Figure 17. World wild salmon harvest value estimated
by multiplying world wild salmon harvests (from the same sources as for Figure 17) by Alaska
average ex-vessel prices (from the same sources as for Figure 17).  Source for United States Fish
and Shellfish Landed Value is NMFS, Fisheries of the United States, various years, available at:

http://www.st.nmfs.noaa.gov/stl/publications.html

Source for "Rank of Naknek-King Salmon among U.S. ports in annual landed value" is NMFS
Major Ports Data.

Figure 71.  Ex-Vessel and Wholesale Value of Bristol Bay Sockeye Salmon.  Same sources as
for Figure 46.

Table 41.  Economic Measures of the Bristol  Bay Salmon Industry:  Export Value.  Source for
U.S. export value is NMFS Foreign Trade in  Fisheries Products Data.  Source for estimated share
of Bristol Bay sockeye in total Alaska sockeye salmon harvests is the same as for Figure 18.
Source for first wholesale value of sockeye salmon roe production is ADFG Commercial
Operator Annual Report (COAR) Data.

Figure 72.  Estimated Value of US Exports of Bristol Bay Salmon Products. Same sources as for
Table 41.

Table 43.  Economic Measures of the Bristol  Bay Salmon Industry:  Employment.  Source for
estimated peak employment and estimated annual average employment is Table 43. Source for
Alaska totals used to calculate Bristol Bay share is the Alaska Department of Labor and
Workforce Development (ADLWD) Research and Analysis Division website for "Statewide
Data, Fishing and Seafood Industry" at:

http://labor.alaska.gov/research/seafood/seafoodstatewide.htm

Table 44.  Economic Measures of the Bristol  Bay Salmon Industry:  Permit Prices and Values.
Source for permits issued  and permit prices is CFEC Basic Information Tables.

Figure 74.  Bristol Bay Commercial Salmon Harvests. Same sources as for Figure 11.

Table 45.  Distribution of Harvests for Bristol Bay Fishing Districts.  See the data sources for
Figure 13 for the sources for harvests by district used to calculate the distribution data shown in
the table.
                                          167

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Figure 75. Estimated Shares of Bristol Bay Sockeye Salmon Production, 2010. Frozen, Canned,
Fresh and Roe share estimated from ADFG Commercial Operator Annual Report (COAR) Data.
Frozen fillet and frozen H&G shares and canned tails and canned halves shares estimated from
the shares of these products in frozen production and canned production reported in ADOR
Annual Salmon Price Reports.

Figure 76. Average Ex-Vessel and Wholesale Prices of Bristol Bay Sockeye Salmon. Same
sources as for Figure 30.

Figure 77. Ex-Vessel and First Wholesale Value of Bristol Bay Sockeye Salmon Production,
1980-2010. Same sources as for Figure 41.

Figure 78. Local Bristol Bay Resident Share of Bristol Bay Salmon Fisheries:  Selected
Measures. Same sources as for Figure 61.

Table 47. Relative Indicators of 2010 Salmon Fishery Participation and Earnings, Bristol Bay
Watershed Region. Calculated from data in Table 37.

Table 48. Selected Economic Measures of the Bristol Bay  Salmon Industry.  Selected data from
Table 40-Table 44.

Table 49. Distribution of Selected Economic Measures for the Bristol Bay Commercial Salmon
Fishing Industry. Sources for distribution calculations are as follows:  Harvest, ex-vessel price,
and ex-vessel value: Same data sources as for Figure 11. First wholesale prices and first
wholesale value: ADFG Commercial Operator Annual Report (COAR) Data. Permit prices and
estimated permit value: CFEC Basic Information Tables.
                                          168

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           Price Index Data for Converting from Nominal Dollars to Real Dollars

The Anchorage Consumer Price Index (CPI) was used to convert selected "nominal" price and
value data (not adjusted for inflation) presented in this report to "real" price and value data
(adjusted for inflation).

                              Anchorage and US Consumer Price Indexes
Year
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
Anchorage CPI
85.500
92.400
97.400
99.200
103.300
105.800
107.800
108.200
108.600
111.700
118.600
124.000
128.200
132.200
135.000
138.900
142.700
144.800
146.900
148.400
150.900
155.200
158.200
162.500
166.700
171.800
177.300
181.237
189.497
191.744
195.144
201.427

US CPI
82.400
90.900
96.500
99.600
103.900
107.600
109.600
113.600
118.300
124.000
130.700
136.200
140.300
144.500
148.200
152.400
156.900
160.500
163.000
166.600
172.200
177.100
179.900
184.000
188.900
195.300
201.600
207.342
215.303
214.537
218.056
224.939
Adjustment factor to convert to
2010 dollars using:
Anchorage CPI
2.282
2.112
2.004
1.967
1.889
1.844
1.810
1.804
1.797
1.747
1.645
1.574
1.522
1.476
1.446
1.405
1.368
1.348
1.328
1.315
1.293
1.257
1.234
1.201
1.171
1.136
1.101
1.077
1.030
1.018
1.000
0.969
US CPI
2.646
2.399
2.260
2.189
2.099
2.027
1.990
1.920
1.843
1.759
1.668
1.601
1.554
1.509
1.471
1.431
1.390
1.359
1.338
1.309
1.266
1.231
1.212
1.185
1.154
1.117
1.082
1.052
1.013
1.016
1.000
0.969
               (a) Anchorage CPI: Consumer Price Index for Anchorage Municipality; (b) US CPI:
               United States Consumer Price Index, All Urban Consumers. Source:  U.S. Dept. of
               Labor, Bureau of Labor Statistics (BLS), downloaded March 15, 2012 from Alaska
               Department of Labor & Workforce Development website:
               http://labor.alaska.gov/research/cpi/cpi.htm.

For any given year, the adjustment factor to convert from nominal dollars to real dollars is the
Anchorage CPI for 2010 (195.144) divided by the Anchorage CPI for the year.  For example, a
nominal price of $1.00 in 1990 would have a "real" 2010 value of (195.144 / 118.600) x $1.00 =
1.645 x $1.00 = $1.64.
                                             169

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This report uses the Anchorage CPI rather than the US CPI because it is the only available
measure of inflation for Alaska, and it is the most appropriate measure for accounting for the
effects of inflation for Alaskans. The table above also shows the corresponding alternative
adjustment factors using the US CPI. In practice, using the US CPI would have resulted in very
similar "real" prices and values, and would not have resulted in any meaningful changes in any
of the analysis or conclusions of this report. The source for both the Anchorage CPI and the US
CPI was the U.S. Dept. of Labor, Bureau of Labor Statistics (BLS). These data are available on
the  Alaska Department of Labor & Workforce Development website at
http://labor.alaska.gov/research/cpi/cpi.htm.
                                          170

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4.0 Economic Significance of Healthy Salmon Ecosystems in
the Bristol Bay  Region: Summary Findings

The purpose of this section is to assess the economic significance of commercial activities that
are dependent on ecosystems in the Bristol Bay watershed and important to the regional
economy and to the state economy of Alaska. The study region consists of the Bristol Bay
Borough, the Dillingham Census Area, and the Lake and Peninsula Borough. This economic
significance analysis measures how many annual average jobs and how much personal income
was generated in Alaska by expenditures associated with the Bristol Bay commercial salmon
industry, subsistence activities, as well as various types of recreational activities dependent on
Bristol Bay salmon ecosystems. We divide recreation into sport fishing, sport hunting, and non-
consumptive use, based on the primary activity reported by visitors to the Bristol Bay region.

For 2009, we estimate that about 6,300 annual average jobs are attributable to the wild salmon
ecosystem in the Bristol Bay region. Residents of Alaska hold more than 80 percent of all jobs.
About 60 percent of all Alaskans working in the Bristol Bay region live in other parts of Alaska.
About 20 percent of all jobs are held by non-residents from outside Alaska. At the peak of the
summer season, there are almost 15,000 jobs in the Bristol Bay region associated with the
commercial salmon fishery and recreation industries. In 2009, the total payroll traceable to this
economic activity amounts to more than $282  million of which $182 million went to Alaska
residents, and more than $100 million was received by non-residents from outside Alaska
working seasonally in the commercial salmon  fishery, recreation industries,  or service providing
industries. About $77 million went to local residents of the Bristol Bay region.

The commercial fishing industry provides the biggest contribution to the economic significance
of the Bristol Bay ecosystem. In terms of the overall direct employment in the region, half of all
jobs are in the fishing industry, followed by  government (32 percent), recreation (15 percent),
and mineral exploration (3 percent). The largest recreation related contributor of direct jobs in
the region is the non-consumptive recreational use sector providing 9 percent of the overall
employment followed by sport fishing (5 percent) and sport hunting (1 percent).
                                         171

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Table 50. Estimated Economic Significance of Bristol Bay Ecosystems

Direct jobs
Peak
Commercial fish
Recreation
Subsistence
Annual average
Commercial fish
Recreation
Subsistence
Multiplier Jobs
Total jobs
(annual average)
Direct wages
($000)
Commercial fish
Recreation
Subsistence
Multiplier wages
Total wages
Total
14,227
11,572
2,655
non-mkt.
2,811
1,897
914
non-mkt.
3,455
6,266
$166,632
$134,539
$32,093
non-mkt.
$115,976
$282,608
Non-local
4,365
3,257
1,114
non-mkt.
914
530
384
non-mkt.
2,008
2,922
$40,149
$22,698
$12,451
non-mkt.
$69,250
$104,399
Residents
Local
2,273
1,089
1,184
non-mkt.
585
177
408
non-mkt.
1,447
2,032
$31,048
$17,608
$13,440
non-mkt.
$46,724
$77,772
Total
6,639
4,341
2,298
non-mkt.
1,499
707
792
non-mkt.
3,455
4,954
$66,199
$40,307
$25,892
non-mkt.
$115,976
$182,175
Non-
Residents
7,587
7,237
356
non-mkt.
1,313
1,190
123
non-mkt.
-
1,313
$100,435
$94,233
$6,202
non-mkt.
-
$100,435
Note, table does not include jobs related to mineral exploration, commercial trapping, commercial fisheries other
than salmon, or government.
                                              172

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4.11ntroduction

The purpose of this section is to assess the economic significance of commercial activities that
are dependent on ecosystems in the Bristol Bay watershed and important to the regional
economy and to the state economy of Alaska.
"Economic significance" refers to how many annual average jobs and how much personal
income was generated in Alaska by expenditures associated with the Bristol Bay commercial
salmon industry as well as various types of recreational activities and subsistence activities
dependent on Bristol Bay ecosystems. Thus it represents the jobs and income supported by a
healthy Bristol Bay ecosystem. The study region consists of the Bristol Bay Borough, the
Dillingham Census Area,  and the Lake and Peninsula Borough. An economic significance
analysis is different from an economic impact analysis that quantifies the change in management
policy or some factor influencing the use of natural resources in the region. This analysis does
not attempt to quantify any changes in the ecosystem, rather seeks to estimate economic activity
dependent on a healthy Bristol Bay ecosystem.
Note the following important limitations of this analysis: the analysis does not measure the net
economic value of the natural resources occurring in the Bristol Bay region to Alaska and/or the
U.S. as a whole. For example, we do not measure the economic value visitors and non-visitors to
the region place on preservation offish, wildlife, and wilderness within the Bristol Bay region.
Second, the analysis shows the  contributions to the regional economy of Bristol Bay and the rest
of Alaska but excludes the contributions occurring in other states of the U.S.  or other parts of the
world. Fourth, the model shows only a one-year-snapshot of the economy. The analysis is based
on data sources of earlier years  that have been adjusted to reflect 2009 conditions or they are
based on 2009 data. Given the large annual variations that occur in catches for the commercial
salmon fishery and for visitation and expenditures related to tourism, the estimated economic
significance for 2009 is not necessarily representative of historical or future economic
significance.

The following sections of the report first describe the methods used to quantify the economic
significance of economic activity in the Bristol Bay region. We then provide  a brief regional
economic overview followed by the multiplier results for each economic activity. The rationale
and uncertainties related to assumptions relevant for the analysis are also discussed. Information
about all data sources used is also provided.

Except where noted, all values are expressed in 2009 dollars and where necessary were adjusted
using the Anchorage Consumer Price Index, the only available measure of inflation for Alaska.
We report employment estimates for residents of three different regions: the local Bristol Bay
region (local), other parts of Alaska (non-local residents), and residents of other states or
countries (non-residents).

Note, for the purpose of this study, we report peak employment as a point estimate of the
maximum count of workers observed, and state all other employment estimates (including
                                          173

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multiplier jobs) in terms ofannual average jobs. For example, six jobs held for 2 month of the
year in commercial salmon fishing would result in one annual average job.
4.2 Methods

An economic significance analysis measures the importance of economic activity occurring in a
region to the regional and statewide economies. We use jobs and income as two measures to
show this significance. To conduct this analysis, we first identify the expenditures and jobs
directly associated with the primary economic activity of the region including commercial
fishing, recreation, and subsistence. We then calculate the additional expenditures, annual
average jobs, and payroll generated by dollars re-circulating through the economy to support
industries located in the region and elsewhere in Alaska. These effects are commonly referred to
as multiplier effects. Note that these effects are only measuring trade flows in dollars and do not
account for non-market trade flows  such as bartering and the exchange of goods and services
related to subsistence activity.

The process by which purchases by an industry or by households stimulate purchases by other
businesses and households is known as the multiplier effect. For this study, we measure
multiplier effects for indirect and induced employment and wages. Indirect effects occur when
primary industry purchases inputs to their operation from support sectors. For example, fishing
boat captains purchase diesel fuel from local gas stations. Induced effects consist of the
additional jobs and payroll created when employees of the primary and support industries spend
their personal income on consumer goods and services. For example, the manager of the local
gas station, where the fishermen purchased fuel, buys bread from the local bakery.

In order to appropriately calculate the effects of re-circulating dollars through the  economy, we
use a regional Input-Output model developed by University of Alaska  Anchorage Economics
Professor Scott Goldsmith for the state of Alaska. Models are an imperfect representation of the
real world and while they are essential for understanding reality, they should not be confused
with that reality itself (Hilborn and Mangel, 1997). Thus the model results we represent are
suggestive rather than definitive. If we wished to definitively measure  the economic significance
of the Bristol Bay ecosystem, we would need to conduct a very large and comprehensive survey
of all the economic activity originating from the region and the payment flows that they generate.
Such a study would be far outside the scope of this analysis both in terms of its cost as well  as
the time that it would take to complete.

We refer to the model used in this analysis as the 'ISER Input-Output model" (Goldsmith, 2000).
The model reflects the simplified economic structure of the Alaska economy, consisting of four
regions, with the Southwest region encompassing the Bristol Bay study area. Since the model
represents the structure of the entire region of Southwest Alaska, it is dominated by the larger
urban area (Kodiak and Dutch Harbor), where most of the jobs are located. Other  more rural
communities, such as those of the Bristol Bay region,  have a more rudimentary market economy.
As a consequence, the Input-Output model may overstate the local economic activity in a rural
area compared to what that spending may actually generate locally In other words, in rural areas,
the local jobs multiplier tends to be  overstated. However, this slight distortion averages out

                                          174

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across the region of Southwest Alaska and statewide. Thus, the aggregate regional effects across
Southwest Alaska and the state-wide Alaska economy can be considered more accurate than the
estimated local effects within the Bristol Bay region.

Similarly to variation of economic activity within a region, there is also variation among regions.
For example, Anchorage serves as the trade and service center for the state. Thus, any spending
occurring in rural parts of the state has economic effects in the rural region and in the
Southcentral region, where Anchorage is located. An important feature of the ISER Input-Output
model is that wages paid in Anchorage can be attributed back to expenditures made in rural
areas.

Another important characteristic of the ISER Input-Output model is that it establishes supply
constraints. In Alaska, inter-industry purchases mainly occur with services and raw materials that
are supply-constrained due to resource scarcity and the limited availability of capital and labor to
extract the raw materials. "Off-the-shelf Input-Output models developed primarily for other less
resource-dependent states, such as IMPLAN, do not take this characteristic into account,  and
potentially overestimate multiplier effects within Alaska (MIG, 2011). Another important
attribute of the Alaska economy is that inter-industry purchases are less important in Alaska
compared to more mature economies. The absence of a developed manufacturing sector in
Alaska means that most goods must be purchased outside the state, creating large leakages and
small indirect multiplier effects.

Despite the outlined advantages of the ISER Input-Output model, there remain many challenges
to the analysis. One of these challenges is that the economic structure depends in large part on
determining where the workers reside when they are not working. Many workers, particularly in
the commercial fishing industry, don't live in the Bristol Bay region. These workers only come
to the region for a two to four months long period in the summer but live elsewhere the rest of
the year.

Another challenge is that there is no Input-Output model currently available that incorporates
subsistence activity as an industry. Current Input-Output models solely reflect market economies
and their sectors and ignore non-market sectors such as household work or subsistence activity.
Due to the importance of subsistence to the regional economy of the Bristol Bay region, we
believe that ideally the subsistence sector would be incorporated into input-output analysis of the
economies of rural Alaska regions such as Bristol Bay where it is an important part of the
economy. However, this kind of research would require additional effort and time far beyond the
scope of this analysis.

Sections 4.8 and 4.9 further discuss data sources used and the implications of assumptions made
on overall results. Due to a lack of certain kinds of data and other sources of uncertainty further
discussed in the appendix, the reader should  interpret the estimated impacts as suggestive rather
than definitive.

The following two tables show how many jobs and income are associated with $1 million in
2009 spending in Southwest Alaska. For example, $1 million dollars of in-state spending on air
transportation in  Southwest Alaska creates approximately six jobs in Southwest Alaska and one


                                          175

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job in Southcentral Alaska (Table 51). In addition, this spending generates $344,000 in payroll in
Southwest Alaska and $54,000 in payroll in Southcentral Alaska (Table 52).
Table 51. Annual average jobs associated with $1 million in spending in each sector in
Southwest Alaska, 2009

                                    SOUTH   SOUTH   SOUTH NORTH STATE
                                     EAST  CENTRAL  WEST         TOTAL
                                       I         II        III      IV
 Agriculture and AFF Services
 Forestry
 Fishing
 Crude Petroleum and Natural Gas
 Other Mining
 New Construction
 Maintenance and Repair
 Food and Kindred Products
 Paper and Allied Products
 Chemicals and Petroleum Processing
 Lumber and Wood Products
 Other Manufacturing
 Railroads
 Local and Interurban Transit
 Motor Freight and Warehousing
 Water Transportation
 Air Transportation
 Pipelines
 Transportation Services
 Communication
 Electric, Gas, Water, and Sanitary
 Wholesale Trade
 Retail Trade
 Finance
 Insurance
 Real Estate
 Hotels, Lodging, Amusements
 Personal Services
 Business Services
 Eating and Drinking
 Health Services
 Miscellaneous Services
 Federal Government Ent
 State & Local Government Ent
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.9
0.3
0.2
0.9
0.9
0.0
4.0
0.2
0.0
0.1
0.0
0.4
0.2
0.2
1.1
0.3
1.0
0.1
0.3
1.3
0.8
4.6
12.3
4.0
2.1
0.9
1.9
2.0
6.4
8.5
4.8
4.6
0.4
0.1
5.5
4.2
4.2
0.6
4.2
4.1
10.2
5.3
5.0
1.1
5.6
8.4
4.1
11.7
10.2
4.4
6.4
3.7
6.8
6.1
2.7
10.0
30.4
9.2
8.9
0.7
15.0
24.2
20.2
26.8
18.8
15.1
6.3
8.3
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
6.3
4.4
4.3
1.5
5.1
4.1
14.1
5.5
5.0
1.2
5.7
8.8
4.3
12.0
11.2
4.7
7.4
3.8
7.2
7.4
3.5
14.6
42.7
13.2
11.0
1.6
16.9
26.3
26.6
35.3
23.6
19.7
6.7
8.4
                                         176

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Table 52. Annual payroll associated with $1 million in spending in each sector in Southwest
Alaska, 2009
                                      SOUTH
                                       EAST
                                         I

Agriculture and AFF Services         $
Forestry                           $
Fishing                            $
Crude Petroleum and Natural Gas      $
Other Mining                        $
New Construction                   $
Maintenance and Repair              $
Food and Kindred Products           $
Paper and Allied Products            $
Chemicals and Petroleum Processing  $
Lumber and Wood Products          $
Other Manufacturing                 $
Railroads                          $
Local and Interurban Transit          $
Motor Freight and Warehousing       $
Water Transportation                $
Air Transportation                   $
Pipelines                          $
Transportation Services              $
Communication                     $
Electric, Gas, Water, and Sanitary      $
Wholesale Trade                    $
Retail Trade                         $
Finance                            $
Insurance                          $
Real Estate                         $
Hotels, Lodging, Amusements         $
Personal Services                   $
Business Services                   $
Eating and Drinking                 $
Health Services                     $
Miscellaneous Services              $
Federal Government Ent              $
State & Local Government Ent         $
Households                        $

Source: ISER Input-Output Model (Goldsmith, 2000).
SOUTH
SOUTH
CENTRAL
II
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
43
13
8
150
72

243
,276
,755
,821
,128
,014
254
,764
7,446

12
1
15
16
524
,003
,092
,244
,082
5,409
35
21
54
4
14
87
55
227
365
206
108
29
46
44
298
151
197
172
25
5
9
,723
,311
,410
,718
,772
,937
,677
,652
,739
,101
,765
,189
,021
,267
,171
,775
,932
,055
,818
,415
,129
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
WEST
III
274
209
209
92
326
254
626
181
165
97
211
299
296
269
336
316
344
268
296
423
186
494
904
476
463
23
360
526
940
479
785
565
403
360
22
,635
,563
,563
,746
,900
,526
,678
,843
,218
,505
,898
,200
,407
,956
,974
,516
,270
,972
,132
,144
,376
,997
,797
,973
,912
,538
,382
,104
,459
,206
,286
,071
,554
,384
,931
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
NORTH

  IV
                                           177

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4.3 Regional Economic Overview

The economy of the Bristol Bay Region depends on three main activities (basic sectors)—
publicly funded services through government and non-profits, commercial activity associated
with the use of natural resources (mainly commercial fishing and recreation), and subsistence.
Subsistence is a non-market activity in the sense that there is no exchange of money associated
with the subsistence harvest. However, local participants invest a significant portion of their time
and income to participate in subsistence and the harvest has considerable economic value and
their expenditures have significant economic effects.

Public services and commercial activities bring money into the economy (basic sectors) and
provide the basis for a modest support sector. The support sector (non-basic sector) consists of
local businesses that sell goods and services to the basic sectors including the commercial fishing
industry, the recreation industry, the government and non-profit sectors. The support sector also
sells goods and services to participants in subsistence activities.
The relative importance within the regional economy of government as contrasted with
commercial fishing and recreation can be measured by the annual average employment in each
sector. In 2009, more than two thousand jobs were directly associated with government spending
from federal, state, and local sources. Commercial fishing and recreation accounted for
approximately three thousand or 57 percent of total basic sector jobs (Table 53). Since much of
the recreation is using public lands and resources, a share of the government sector; for example
administration of the federal and state parks and wildlife refuges, is directly related to providing
jobs and opportunities in the recreation sector. Accordingly, the estimate of recreation-dependent
jobs is conservative.

The annual spending of federal dollars in the region is another indicator of the importance of the
government sector in the region. Table 54 shows that in 2009, $119 million in federal spending
flowed into the three labor market areas of the Bristol Bay region.

The support sector depends  on money coming into the regional economy from outside mainly
through government, commercial fishing, and recreation. The relative dependence of the support
sector on the three main sectors is difficult to measure. One reason for this is that government
employment is stable throughout the year, while employment in commercial fisheries and
recreation vary seasonally. Due to the seasonal stability of government jobs, the payroll spending
of people employed in government is likely to contribute more to the stability of support sector
jobs in the region than their share of basic sector jobs indicates.
                                           178

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Table 53. Employment Count by Place of Work in the Bristol Bay Region, 2009

Total jobs count
Basic
Fish harvesting
Fish processing
Recreation
Government & Health
Mineral Exploration
Non-basic
Construction

Trade/Transportation/Leisure
Finance
Other wage & salary
Non-basic self employed
Resident jobs count
.niiiiuai
Average
6,648
5,490
1,409
1,374
432
2,039
197
1,406
61
634

155
239
317
4,675
Summer
16,386
14,877
6,909
4,480
1,297
1,712
450
1,509
92
717

142
241
317
10,351
Winter
3,792
2,430
-
354
-
2,056
70
1,362
55
593

162
235
317
3,225
Swing
12,594
12,447
6,909
4,126
1,297
(344)
380
147
37
124

(20)
6
-
7,126
Note, estimates based on ISER Input-Output Model (Goldsmith, 2000).
Note, fish harvesting and processing includes all commercial fisheries in the region,thus employment
numbers cannot be compared with other tables shown in this report. Summer and winter employment
shown, are point estimates that either show the maximum or minimum job count. Swing refers to the
difference between maximum and minimum. See Appendix B for sources used.
Table 54. Federal Spending in the Bristol Bay Region, 2009 ($000)

Total
Retirement
Other direct to individuals
Grants
Procurement
Wages
Bristol Bay
$49,600
$6,934
$1,930
$32,867
$4,440
$3,430
Dillingham
$54,345
$6,764
$10,235
$32,467
$1,005
$3,874
Lake & Pen
$16,013
$545
$4,799
$7,878
$857
$1,934
Total
$119,958
$14,243
$16,964
$73,212
$6,302
$9,238
Source: U.S. Department of Commerce (2009).
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 Table 55. Estimated Residence of Workers in the Bristol Bay Region 2009
                                  T    .          Other        Outside         „   .
                                  Local          ...           ...           Total
	Alaska	Alaska	

 Bristol Bay
  State government                   24             14              9           47
  Local government                  126             12             18          156
  Private sector	273	332	1,916	2,521
  Sum                             423            358          1,943        2,724
Dillingham
State government
Local government
Private sector

90
877
1,033

24
66
270

8
94
728

122
1,037
2,031
  Sum                            2,000            360            830        3,190

 Lake & Pen
  State government                    7              7              3           17
  Local government                  417            105             66          588
  Private sector	179	322	685	1,186
  Sum                              603            434            754        1,791

 Total Private                     1,485            924          3,329        5,738
 Share                              26%           16%           58%        100%

 Source: ADOL (2009). Note, this is a count of workers (unique individuals) and not a measure of Full
       Time Equivalent or annual average jobs. Also, the table includes processing workers but excludes
       harvesters in the commercial fishery (private sector).
 The estimated personal income in the region varies by borough/census area. The Bureau of
 Economic Analysis (BEA) reports more than $58,000 as the 2009 per capita personal income for
 the Bristol Bay Borough. Per capital personal income in the Lake and Peninsula Borough or in
 the Dillingham Census Area is approximately equal to $35,000 (Table 56). For comparison, the
 2009 per capita personal income in Anchorage amounts to $48,598.

 The commercial  salmon fishery provides above average income to seasonal workers and
 residents of the region. Because of the large amounts of income received by seasonal workers
 that do not reside in the Bristol Bay region, BEA applies the Alaskan seasonal worker
 adjustment. This residence adjustment lowers the income generated in the region by the amount
 that is believed to be received by people working in Bristol Bay but not residing in the region. In
 part, it is a subjective measure for the amount of income flowing out of the Bristol Bay Borough
 to other areas of Alaska and to Washington State, Oregon, and California (BEA, 2007). Thus, the
 per capita income measures stated here are uncertain and  should be viewed as suggestive rather
 than definitive.

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 Table 56. Estimated Personal Income in the Bristol Bay Region, 2009  (000$)
	Bristol Bay    Dillingham    Lake & Pen
Total
 Wages                           $57,018        $96,654       $27,551     $181,223
 + Supplements to wages           $16,694        $28,021        $9,164      $53,879
 + Proprietor income                $9,421        $16,194        $2,605      $28,220
 = Earnings by place of work        $83,133       $140,869       $39,320     $263,322
 - Contributions for government      $8,799        $14,820        $3,736       $27355
 social insurance
 + Residence adjustment            -$39,175        -$4,530       -$1,055     -$44,760

 = Net earnings by place of         $35,159       $121,519       $34,529     $191,207
 residence
 + Dividends                       $7,382        $20,314        $7,980      $35,676
 + Transfers                       $9,189        $35,764       $11,981      $56,934

 = Personal Income                $51,730       $177,597       $54,490     $283,817
 Population                           881          4,957         1,485         7,323
 Per Capita Income	$58,717	$35,828	$36,694      $38,757
 Source: BEA (2009).
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4.4 Commercial Salmon Fisheries

The largest share of jobs and income generated in the Bristol Bay region comes from commercial
salmon fishing, including drift gillnet and set gillnet fisheries. The commercial salmon fishery is
described in detail in Section 3  of this report. Here we provide a brief summary description prior
to presenting estimates of the economic significance of the industry.

The number of commercial fishing jobs and income varies from year to year due to the varying
size and value of the salmon harvest. For example, the ex-vessel value paid to fishermen fell
from a peak of $214 million in  1989 to $32 million in 2002, and recovered to $148 million in
2009. The 2009 harvest was 192 million pounds. The whole sale value of these fish amounted to
$300.2 million.27

At the peak of the 2009 commercial salmon fishery, about 1,000 local residents and 6,000
seasonal workers from outside the region participated in the commercial salmon fishery's
harvest. In addition, approximately 4,500 non-local processing workers came to the Bristol Bay
region. At the peak of the season approximately 11,500 workers had jobs in harvesting and
processing combined. About 4,300 of these workers were Alaska residents and approximately
7,200 came from outside the state.

We estimate that total income to harvesters in 2009 was approximately $103 million of which
permit holders received $72 million (70 percent) and $31  million went to crew members.
Alaskans participating directly in harvesting and processing earned approximately $40 million
amounting to 42 percent of total direct wages. Local residents of the Bristol Bay region earned
$17.6 million (12 percent) of total direct income in processing and harvesting combined.
The commercial salmon season is highly seasonal. Almost all fishing and processing activity
occurs between June and August. For the purpose of our analysis, we assume that each seasonal
fishing job lasts two months. Therefore, six seasonal jobs equate to one annual average job.

The in-state spending by harvesters, processors, and workers in the region and  in other places of
Alaska created additional jobs in other sectors of the economy through the multiplier effect. We
estimate that on an annual average basis, 1,586 additional jobs (754 locally and 832 in the rest of
Alaska) and $54.7 million in indirect wages were traceable to commercial fisheries. These jobs
were in the trade, service, finance, and other support industries. Jobs created outside of the state
are not included in these estimates.

In 2009, the total income traceable to commercial salmon fishing in Bristol Bay equaled  $189
million. Accounting for the short two months summer season in commercial salmon fishing, the
11,500 direct commercial salmon fishing jobs translate to approximately 1,900 jobs on an annual
average basis.  With the addition of multiplier jobs, about 3,500 annual  average jobs would be
attributable to the commercial salmon fishing industry (Table 57).
27  Estimates of some year-specific commercial fishery total harvest and total sales vary slightly within this report.
This is due to differences in how these data are aggregated and reported by the Alaska Fish and Game, and the point
in time these statistics were accessed during the preparation of this report.

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Table 57. Estimated Economic Significance of Commercial Fishing

Direct jobs
Peak
Harvesting
Processing
Annual average
Harvesting
Processing
Multiplier Jobs
Total jobs
(annual average)
Direct wages
($000)
Harvesting
Processing
Multiplier wages
Total wages
Total
11,572
7,050
4,522
1,897
1,143
754
1,586
3,483
$134,539
$103,354
$31,185
$54,705
$189,244
Non-local
3,251
2,694
557
530
437
93
832
1,362
$22,698
$19,645
S3, 05 3
$28,101
$50,799
Residents
Local
1,089
1,013
76
111
164
13
754
931
$17,608
$16,609
$999
$26,604
$44,212
Total
4,341
3,708
633
707
601
106
1,586
2,293
$40,307
$36,255
$4,052
$54,705
$95,012
Non-
Residents
7,231
3,342
3,889
1,190
542
648
-
1,190
$94,233
$67,100
$27,133
-
$94,233
Note, estimates based on ISER Input-Output Model (Goldsmith, 2000).
                                         183

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4.5 Recreation

The second largest portion of jobs and income generated by spending dependent on Bristol Bay
salmon resources comes from the recreation sector which directly employs approximately 2,600
workers during peak season translating to about 900 annual average jobs with an annual payroll
of more than $32 million. Most recreational visits occur during the summer months, creating a
peak in economic activity that largely coincides with the peak of the commercial salmon fishery.
Recreational activity concentrates in Katmai National Park and Preserve, Lake Clark National
Park and Preserve as well as the National Wildlife Refuges: Alaska Peninsula/Becharof,
Ixembek, and Togiak.  Sport fishing activity occurs mainly in the Nushagak and Naknek River
watersheds, whereas sport hunting occurs predominately in the Mulchatna River watershed.
Visitors travel to Alaska by air, ferry,  highway,  and cruise ship. Each of these travel markets has
distinct visitor attributes, demographics and regional impacts. Visitation to Southwest Alaska is
primarily driven by independent travelers who predominately arrive by air.  Statewide visitation
declined 5.8 percent between 2008 and 2009 as  a result of the recession following the collapse of
financial markets in late 2008. Cruise  passenger volume remained essentially the same in 2009
because ship deployment decisions require a longer lead time than air. In contrast, air visitor
traffic decreased by  15 percent in 2009.

The rebound in Alaska visitation in  2010 was led by independent travelers arriving by air, and to
a lesser extent road,  ferry, and international visitors. This rebound is expected to continue in
2011 and again be comprised primarily of independent travelers. These independent visitors
tend to visit Alaska's more remote regions, while cruise visitors primarily visit the marine
accessible Southeast region and the  Southcentral and Interior regions including Denali National
Park and Preserve. Katmai National Park and  Preserve in Southwest Alaska showed a rebound in
visitor numbers in 2010 after declines in 2008 and 2009,  based on National Park Service
Commercial Use Authorization permit report  data. Among those that reported boosts in
independent-visitor traffic are lodges,  tour operators, and campgrounds, according to the Alaska
Travel Industry Association.

We estimate that there were approximately 40,964 non-consumptive recreation visitors to
Southwest Alaska in 2009 of which approximately 10 percent were Alaska residents. Visitor
related spending amounted to approximately $173.3 million in 2009. The average spending per
visitor and the average length of stay are higher in Southwest Alaska compared to respective
statewide averages. Based on the  Alaska Visitor Statistics Program (2011), non-residents visiting
Southwest Alaska spent  $2,873 per visitor and stayed 12.9 nights whereas the statewide average
visitor spent $992 and stayed 9.1 nights. Fay and Christensen (2010) estimate per visitor
spending in Katmai to amount to  $2,332. Also, recreational expenditures occurring inside
Katmai NPP are relatively high for a remote Alaska park because of the location of Brooks
Camp and concession businesses  located inside  the park. Based on the visitor spending reported
by the Alaska Visitor Statistics Program (2011)  and Fay and Christensen (2010), we estimate
non-consumptive visitor spending in the Bristol Bay region to equal $2,548 per visitor and year.

Among all recreational users of the region, non-residents spent the largest amount, equaling
$149.5 million or 86 percent of total spending. Alaskans from outside the region spent an
estimated $18.9 million, whereas  locals had the  smallest amount equaling $4.9 million in

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recreation related expenditures. The per-visitor expenditures to destinations in Southwest Alaska
are higher compared to other locations in Southcentral Alaska because most travelers go by air to
the more remote locations such as Bristol Bay, whereas the largest portion of visitors to
Southcentral Alaska come to Alaska by cruise ship.
Table 58. Estimated Recreational Visitors and Expenditures in the Bristol Bay Region,
2009
                                   Local        Non-local        Non-
                                 residents       residents       residents
Visitors
Non-consumptive
Sport fishing
Sport hunting

4,506
13,076 3,827
1,319

36,458
12,464
1,323

40,964
29,367
2,642
  Total                            13,076          9,652         50,245       72,973

Spending per visitor
  Non-consumptive                      -         $2,548         $2,548
  Sport fishing                      $373         $1,582         $3,995
  Sport hunting                          -         $1,068         $5,170

Spending (Sniillion)
  Non-consumptive                      -          $11.5          $92.9       $104.4
  Sport fishing                       $4.9           $6.0          $49.8        $60.7
  Sport hunting	-	$1.4	$6.8	$8.2
  Total                              $4.9          $18.9         $149.5       $173.3

Note that some visitors combine fishing with non-consumptive use activities. These visitors are included
here in sport fishing. Cost of travel to Alaska for non-residents not shown. Annual spending per non-
consumptive visitor is the weighted average of visitor spending related to Katmai and other locations in
the Bristol Bay Region.
The local economic impact of visitor spending occurs primarily through local purchases of goods
and services. This effect is captured in the multiplier jobs and wages in . The multiplier jobs are
held in the transportation, accommodation, and trade sectors of the economy. A large share of
these jobs is located outside the Bristol Bay region in Southcentral Alaska where most of the
goods and services originate from. The jobs in these sectors are more likely to be filled by
Alaska residents who live where they work, and they are more likely year-round rather than
seasonal jobs.

For 2009, we estimate the total annual average number of jobs that are traceable to recreational
visits to the Bristol Bay region to equal 2,715 with total payroll of $90.8 million. On an annual
average basis, the majority (44 percent) of the 914 direct jobs were held by local residents of the
region followed by other Alaska residents (384 jobs). Other Alaskans either moved into the

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region to fill a job during the summer season, or their job was located in Anchorage and
attributable to recreation occurring in the Bristol Bay region. A smaller share of total jobs (13
percent) was taken by non-residents. Also, some of the indirect jobs in transportation, trade, and
accommodations were probably filled by non-residents rather than residents. Important to note is
that due to a lack of data, the distribution of jobs and income by residency is uncertain. However,
total employment and total income estimates are more robust measures.

Note, since many of the goods and services consumed in Alaska, are produced outside of Alaska
and consequently have economic effects elsewhere, these spillover effects are not part of this
economic analysis.
Table 59. Estimated Economic Significance of All Recreation



Direct jobs
Peak
Non-cons.
Sport Fish
Sport Hunt
Annual average
Non-cons.
Sport Fish
Sport Hunt
Multiplier Jobs
Total jobs
(annual average)
Direct wages
($000)
Non-cons.
Sport Fish
Sport Hunt
Multiplier wages
Total wages

Total
i Ul
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4.5.1 Non-Consumptive Use

Most of recreational spending in the Bristol Bay region is related to non-consumptive use, for
example wildlife viewing of coastal brown bears and bird species, or kayaking and camping
activities. For this part of the analysis we estimate visitation based on the most recent studies of
non-resident visitors to the state and two studies that estimated visitation and economic impacts
related to Katmai National Park and Preserve. On an annual basis including summer and winter
visitation, approximately 2,300 residents and 18,900 non-residents visited Katmai NPP. Other
areas in the Bristol Bay region received approximately 2,300 resident visitors and 19,000 non-
resident visitors. Note, these estimates exclude visitation where sport fishing or sport hunting
was in part or the primary activity of choice. After adjusting the per capita expenditures to 2009
dollars we estimate per person expenditures to amount to $2,245 annually for Katmai NPP and
$2,873 per person annually for visiting other destinations in the Bristol Bay region.

To be consistent with the expenditure data for sport fishing and hunting, we assume that the visit
to the Bristol Bay region was the primary reason for their visit to Alaska. For these visitors we
include all their instate spending in the calculation of multiplier jobs and income.

We estimate a total of 1,681 annual average jobs to be attributable to non-consumptive use of
natural resources in the Bristol Bay region with a payroll of $54.8 million. The main proportion
(57 percent) of jobs are held by residents of Alaska that do not live in the Bristol Bay region
either because they move to Bristol Bay for the summer months to fill a seasonal job or because
they work in Anchorage for a supplier of goods and services to the Bristol Bay region. The total
income generated in 2009 for residents of Alaska amounted to $51.4 million.
Table 60. Estimated Economic Significance of Non-Consumptive Use
                        Total
                                    Non-local
Residents
  Local
Total
  Non-
Residents
Direct jobs
Peak
Annual average
Multiplier Jobs
Total jobs
(annual average)
Direct wages
($000)
Multiplier wages
Total wages
1,669
575
1,106
1,681
$19,107
$35,668
$54,775
735
253
703
956
$7,823
$24,059
$31,882
741
255
403
658
$7,925
$11,608
$19,533
1,475
509
1,106
1,615
$15,748
$35,668
$51,416
193
67
-
67
$3,359
$3,359
Note, estimates based on ISER Input-Output Model (Goldsmith, 2000). All direct jobs are in the Bristol
Bay region.
                                          187

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4.5.2 Sport Fishing

The second largest share of total recreational expenditures in the Bristol Bay region is associated
with sport fishing, either as the only or as the primary activity of the visitor. Non-residents
account for 53 percent of visitors that fish in the region and spend 82 percent of total  sport fish
related expenditures attributable to the region, excluding travel to Alaska.  Non-residents are
most likely to hire guides and stay at local lodges. Alaska residents account for 47 percent of
visitation and spend 10 percent of total sport-fish-related expenditures. We also include spending
on sport fishing by local residents, even though that spending does not bring in money from
outside the region to the Bristol Bay region. If there would not be any sport fishing opportunities
in the region, that local spending could likely shift to other areas outside the region and thus
provides the rationale for including it in our calculations.

At the peak of the fishing season in July, employment in sport fishing reaches 854 direct
seasonal jobs. The annual average employment traceable to sport fishing in the region amounts
to approximately 300  annual average jobs, of which almost half are taken by local residents. The
total estimated payroll attributable to sport fishing activities in the Bristol Bay  region amounts to
$31.4 million in 2009. We estimate that about a third of total payroll went to local residents of
the Bristol Bay region. After counting for multiplier jobs, more than 900 annual average jobs are
traceable to sport fishing occurring in the Bristol Bay region.
Table 61. Estimated Economic Significance of Sport Fishing
                                                     Residents
                                     Non-local        Local
Total
                                              Total
  Non-
Residents
Direct jobs
Peak
Annual average
Multiplier Jobs
Total jobs
(annual average)
Direct wages
($000)
Multiplier wages
Total wages
854
294
608
902
$11,279
$20,118
$31,397
328
113
371
484
$4,020
$13,339
$17,359
383
132
237
368
$4,777
$6,779
$11,556
712
245
608
853
$8,797
$20,118
$28,915
142
49
-
49
$2,482
$2,482
Note, estimates based on ISER Input-Output Model (Goldsmith, 2000). All direct jobs are in the Bristol
Bay region.
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4.5.3 Sport Hunting

Compared to other recreation activities, sport hunting accounts for the smallest share of total
recreational expenditures (3 percent) and the fewest visitors overall (5 percent) (Table 58). The
larger per person expenditure of $3,122 per visitor is related to higher travel costs. In addition,
non-residents are by law required to hire local guide services which adds to the cost for hunting,
including air service to remote hunting locations. Sport hunters are also more likely to hire
commercial operators for sport hunting. Of the 125 total annual average jobs in Alaska
attributable to sport hunting, most are taken by residents of the state with the majority of workers
residing outside the Bristol Bay region. The total payroll attributable  to spending traceable to
sport hunting in the Bristol Bay region is more than $4 million, with the majority going to non-
local residents of Alaska residing in the Southcentral region of Alaska.
Table 62. Estimated Economic Significance of Sport Hunting
                                                     Residents
                                     Non-local        Local
Total
                                              Total
  Non-
Residents
Direct jobs
Peak
Annual average
Multiplier Jobs
Total jobs
(annual average)
Direct wages
($000)
Multiplier wages
Total wages
132
45
87
132
$1,707
$2,886
$4,593
51
18
55
73
$608
$1,982
$2,590
60
21
32
53
$738
$903
$1,641
111
38
87
125
$1,347
$2,886
$4,233
21
7
-
7
$361
$361
Note, estimates based on ISER Input-Output Model (Goldsmith, 2000). All direct jobs are in the Bristol
Bay region.
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 4.6 Subsistence

 Subsistence is an important component of the regional economy even though it is not part of the
 market economy. Consequently there is no official measure for employment or the amount of
 payroll associated with the pursuit of subsistence resources. However, there remains a link
 between subsistence and the market economy in form of equipment, goods, and services
 purchased by households participating in subsistence. Typically these purchases include boats,
 rifles, nets, snow mobiles, and fuel used exclusively to take part in subsistence activities.
 Data on expenditures related to subsistence activities in the Bristol Bay region is not publically
 available. Our estimate of $3,054 per household relies on data from a survey conducted in 1993
 in the North Slope Borough (North Slope Borough, 1993; Goldsmith, 1998). Although, income,
 employment opportunities, and subsistence methods used in the North Slope Borough are
 different, there is evidence that suggests the estimate is justified. The results of a 1980s
 subsistence survey in Western Alaska communities are consistent with the 1993 North Slope
 estimate (Peterson et al., 1992).

 A large share of the 68 multiplier jobs occurs in the Southcentral region (47 jobs) with more than
 $1.8 million in payroll. Local multiplier jobs amount to approximately 16 and an annual payroll
 of $830,000. The small number of multiplier jobs that are generated by household spending on
 equipment is also affected by the limited capacity of local businesses to supply goods and
 services.
 Table 63. Estimated Economic Significance of Subsistence
                        T                           Residents                       Non-
	Non-local	Local	Total	Residents

 Direct jobs
   Peak                  Non-        Non-mkt.      Non-mkt.     Non-mkt.          Non-mkt.
                         mkt.
Annual average
Multiplier Jobs
Total jobs
(annual average)
Direct wages
($000)
Multiplier wages
Total wages

68
68
Non-
mkt.
$2,599
$2,599

47
47
Non-mkt.
$1,769
$1,769

21
21
Non-mkt.
$830
$830

68
68
Non-mkt.
$2,599
$2,599

-
-
Non-mkt.
-
 Note, estimates based on ISER Input-Output Model (Goldsmith, 2000). All direct jobs are in the Bristol
 Bay region.
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4.7 Conclusions

In 2009, the Bristol Bay salmon ecosystem supported more than 6,000 annual average jobs with
a payroll of $282 million. Non-residents of Alaska held one fifth of all jobs and received one
third of all income generated, about $100 million. Alaskans held approximately 5,000 jobs (80
percent of all jobs) and earned $182 million, one third of total income. Local residents of the
Bristol Bay region held about a third of all jobs and earned almost $78 million (28 percent) of
total income traceable to the Bristol Bay salmon ecosystem (Table 64).

The majority of jobs held by Alaskans are taken by residents from other regions of Alaska,
particularly by harvesters in the commercial salmon fishery. More than half of all jobs are held
by workers in the  support industries for commercial fishing and recreation, which are mainly
located in Southcentral Alaska. Multiplier wages amount to about a third of total income
generated.

The regional economy is primarily driven by the commercial salmon industry, followed by
tourism and participation in subsistence, considered to be a non-market economic activity. The
economy of the Bristol Bay is a mixed cash-subsistence economy, where subsistence activity
requires labor inputs without exchange of money for the labor performed. Subsistence creates
non-cash jobs to local residents of the region who are pursuing subsistence activities to support
their families' need for food. The subsistence economy provides a direct link between the health
of the Bristol Bay salmon ecosystem and human well-being.  Subsistence is integral to the local
way of life in the Bristol Bay region. However, even though it is an important part of the regional
economy, work related to subsistence similar to household work, is not officially measured and
neither is it subject to an  exchange of money for the work performed.  Thus, in the context of this
study which is solely focused on market values, we are unable to quantify the economic
significance of subsistence in the sense of direct jobs and income. Thus we present these jobs as
non-market jobs. However, we present multiplier jobs resulting from subsistence-related
spending on capital equipment and gasoline for example. These expenditures are necessary
inputs to participating in  subsistence activities and are included under multiplier jobs and wages
(Table 64).
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Table 64. Estimated Economic Significance of Bristol Bay Ecosystems

Direct jobs
Peak
Commercial fish
Recreation
Subsistence

Annual average
Commercial fish
Recreation
Subsistence

Multiplier Jobs
Total jobs
(annual average)
Direct wages
($000)
Commercial fish
Recreation
Subsistence

Multiplier wages
Total wages
Total
14,227
11,572
2,655
non-mkt.

2,811
1,897
914
non-mkt.

3,455
6,266
$166,632
$134,539
$32,093
non-mkt.

$115,976
$282,608
Non-local
4,365
3,257
1,114
non-mkt.

914
530
384
non-mkt.

2,008
2,922
$40,149
$22,698
$12,451
non-mkt.

$69,250
$104,399
Residents
Local
2,273
1,089
1,184
non-mkt.

585
177
408
non-mkt.

1,447
2,032
$31,048
$17,608
$13,440
non-mkt.

$46,724
$77,772
Total
6,639
4,341
2,298
non-
mkt.
1,499
707
792
non-
mkt.
3,455
4,954
$66,199
$40,307
$25,892
non-
mkt.
$115,976
$182,175
Non-
Residents
7,587
7,237
356
non-mkt.

1,313
1,190
123
non-mkt.

-
1,313
$100,435
$94,233
$6,202
non-mkt.

-
$100,435
Note, estimates based on ISER Input-Output Model (Goldsmith, 2000). All direct jobs are in the Bristol
Bay region.
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4.8 Key Assumptions and Uncertainties
        Description
               Potential Bias
Sensitivity
relative to
  overall
  results
GENERAL
The ISER Alaska Input-
Output model consists of four
regions. The Bristol Bay
region is only part of one of
these regions, the Southwest
region. Larger communities
outside Bristol Bay such as
Kodiak and Dutch Harbor are
part of the Southwest region.
The expenditures related to economic activity in
the Bristol Bay region overestimate the
employment generated in the region and
underestimate the employment generated in other
regions. The bias in overall Alaska economic
impact is unknown.
 Moderate
The commodity by industry
matrix is part of the Input-
Output model and allocates
commodity expenditures
among costs of goods,
transportation margins, trade
margins, and to industries,
based on statewide averages.
Transportation and trade margins may be higher
for purchases made in small, rural parts of Alaska
than for the state as a whole. This would result in
an underestimate of the transportation and trade
share of the total economic impact. Bias in
overall Alaska economic impact is unknown.
 Moderate
Composition of household
expenditures is based on
statewide averages.
The composition of rural household expenditures
may be different from the state average, which is
heavily weighted by urban households. Bias in
overall Alaska economic impact is unknown.
 Moderate
COMMERCIAL FISHING
Potential unrepresentative
base year for harvest and ex-
vessel value estimates
Given the large annual variations that occur in
catches for the commercial salmon fishery the
estimated economic significance for 2009 is not
necessarily representative of historical or future
economic significance.	
   High
Assumptions about the level
of expenditures per harvester
and processor	
Unknown
 Moderate
Assumptions about the
composition of harvester and
processor purchases	
Unknown
 Moderate
Assumption about the regional
allocation of expenditures by
harvesters and processors	
Unknown
 Moderate
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Description
Assumption about the
residence of harvesters and
processor employees
Travel cost related to non-
resident and Alaska resident
travel between place of
residence and place of work in
Bristol Bay.
Potential Bias
Unknown
While we consider the in-state economic impact
of all earnings for harvesters' and processors'
earnings, we ignore the in-state cost of travel
between place of residency and place of work for
participants in the commercial fishing industry.
Sensitivity
relative to
overall
results
Moderate
Negligible
RECREATION: NON-CONSUMPTIVE USE
Assumptions about the
number of local resident
visitors, non-local residents,
and non-residents
Assumptions about the level
of expenditures per trip
Regional allocation of non-
consumptive expenditures
Assumption about the regional
allocation of guide, charter,
and lodge purchases.
Assumption about the
residence of guide, charter,
and lodge employees
Underestimate due to the potentially higher
number of resident visitors (Fix, 2010).
Underestimate. Other sources state higher per trip
expenditures for Southwest Alaska destinations
ranging from $3,068 to $3,760 per person and
trip (Colt and Dugan, 2005; Littlejohn and
Hollenhorst, 2007).
Unknown
Unknown
Unknown
Moderate
Moderate
Negligible
Negligible
Negligible
RECREATION: SPORT FISHING & HUNTING
Assumptions about the
number of trips by local
residents, non-local residents,
and non-residents
Assumptions about the level
of expenditures per trip
Given the annual variations that occur in the
number of visitors to Southwest Alaska the
estimated economic significance for 2009 is not
necessarily representative of historical or future
economic significance.
Given the national recession and worldwide
economic slump the annual variations in visitor
expenditures, the estimated economic
significance for 2009 is not necessarily
representative of historical or future economic
significance.
Moderate
Moderate
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Description
Regional allocation of sport
fishing and sport hunting
expenditures
Assumption about the regional
allocation of guide, charter,
and lodge purchases.
Assumption about the
residence of guide, charter,
and lodge employees
Capital expenditures related to
residents' boats, cabins, and
other equipment
Potential Bias
Unknown
Unknown
Unknown
We ignore capital expenditures related to
equipment due to the difficulty of apportioning a
usage-share to specifically sport fishing or
hunting in the Bristol Bay region.
Sensitivity
relative to
overall
results
Negligible
Negligible
Negligible
Moderate
SUBSISTENCE
Assumption of number of
households engaged in
subsistence activities
Assumption about the level of
expenditures on subsistence
per household
Assumptions about the
composition of subsistence
related expenditures
Assumption about the regional
allocation of subsistence-
related expenditures
Unknown
Unknown. Estimate is from the North Slope of
Alaska where there is a different subsistence
culture compared to Bristol Bay. Similar
subsistence surveys in Western Alaska indicate
that the estimate used is justified. The direction
of bias is unknown.
Unknown
Unknown
Moderate
Moderate
Negligible
Negligible
Source: adapted from Goldsmith et al. (1998).
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4.9 Data Sources

(Methods).
Expenditures that are excluded from the Input-Output modeling exercise are tax revenues
generated through locally occurring economic activity, expenditures associated with natural
resource management, and the commercial trapping industry. In addition, the study excludes the
economic importance of herring fisheries in the Bristol Bay region.  Compared to salmon, herring
fisheries in Bristol Bay are much smaller amounting to $2.5 million in ex-vessel value in 2009
compared to salmon with $148 million (CFEC, 2009). We do not evaluate mineral exploration
because it is not dependent on healthy ecosystems in the Bristol Bay region.

 (Regional Economic  Overview). There are three data sources related to jobs reported in the
Bristol Bay region. The Alaska Department of Labor and Workforce Development offers annual
average employment for wage earners (ADOL, 2009e) and information on participation in the
commercial fisheries such as crew shares and processor employment (ADOL, 2009a-c). The
third data source is an annual count of proprietors provided by the U.S. Bureau of Economic
Analysis  (BEA, 2009). Data from ADOL does not include fishing employment, but BEA
provides  an estimate of proprietors (including  fish harvesters and other proprietors) in the region.
Since ADOL data is measured in annual average jobs and the BEA data is a count of workers,
we adjust the proprietor data to reflect seasonality assuming a six week harvesting season.
Proprietors include local resident crew and local resident captains which are based on crew
factors from ADOL (2004) and resident share  of crew from ADOL (2009c). In addition, we use
information on the number of local permits fished from CFEC (2009) to get an estimate of the
number of local captains participating in the fishery. It is important to note that the ADOL data
only provides employment estimates by place  of work. The BEA proprietor data is based on
income tax returns, thus the BEA proprietors counted in our analysis are only the ones that show
a business address in the Bristol Bay region. Our analysis does  not include businesses registered
elsewhere in Alaska or out of state. Consequently, the proprietor data used in this study and
shown in Table 2 is an underestimate of the jobs that likely exist. For this reason, employment
estimates in Table 2 are not comparable to employment estimates elsewhere in the report.

(Commercial fisheries). For this study we divide the commercial fisheries sector into harvesting
and processing. For the harvest sector, harvest data by residency of permit holder came from the
Commercial Fisheries Entry Commission's Basic Information Tables (CFEC, 2009). Residency
of captains is based on Iverson (2009). Residency of crew is unknown but was inferred from
crew license data available at ADOL (2009a) for all commercial fisheries in the Bristol Bay
region. ADOL (2009a) shows that local captains hire 1.46 local crew in all of Bristol Bay's
commercial fisheries. Since the salmon fisheries are by far the largest fisheries in the region we
assume that each local captain hires 1.46 local crew with the remainder of crew members coming
from other places in Alaska. Non-local captains are assumed to hire exclusively non-local crew
and non-resident captains exclusively non-resident crew. The crew size for Bristol Bay
commercial salmon fisheries amounts to three  including the skipper and is the same in the set net
and drift gill net fisheries (ADOL 2004). Crew shares for the set net and drift gill net fisheries
are based on a ten year average proportion of crew shares to gross earnings as stated in Schelle et
al. (2004). In addition, Schelle et al. (2004) provides expenditure categories for harvesters for

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the drift gillnet fishery. Due to a lack of data on expenditures in the set gill net fishery, we
assume costs to be about half of what they are in the drift gill net fishery with lower insurance,
moorage and storage and other boat related expenses due to the much smaller boats being used
for set net operations. We further allocate these expenditures within a commodity by industry
matrix to form a final demand vector that is passed to the ISERI-O Model following Goldsmith
(2000). For the processing sector, we assume that 95 percent of the harvest is processed in the
Bristol Bay region, including on-shore and off-shore processing. For simplicity, the Input-Output
model assumes processor expenditures for off-shore processing to be similar to on-shore
processing. Residency of processing workers is from ADOL (2009). Wholesale value for salmon
roe and non-roe combined are from ADF&G (2009). Average processor yield is calculated based
on the combined net product weight stated in ADF&G (2009) and pounds harvested (CFEC,
2009). Note, all direct jobs are in the Bristol  Bay region. Multiplier jobs are divided between
Bristol Bay and Southcentral Alaska. Multiplier jobs are assumed to be all taken by residents of
the region where they occur. Peak and annual average direct wages are assumed to be equal.

(Recreation).
No comprehensive analysis has been completed on the economic significance of recreation and
tourism in Southwest Alaska. One of the greatest challenges is estimating visitor volume for
residents and non-residents. A number of separate studies provide some indication of pertinent
levels and patterns of visitation activities. Non-resident visitation, length of stay, and expenditure
per visitor to Southwest Alaska are from McDowell  Group ( 2007a). Bluemink (2010) and the
Alaska Travel Industry Association provided information on current trends in visitation and so
did the National Park Service Commercial Use Authorization permit report data (National Park
Service, 2010).

For this study we separated visitor impacts by residency and by type of activity. For sport
fishing and sport hunting, Duffield and Neher (2002), estimated visitor volume and
expenditures for sport fishing and sport hunting based on license data and visitor specific
expenditure data from ADF&G (2009b). In addition, Duffield et al. (2007) conducted a lodge
survey in the Bristol Bay region that offered detailed angler expenditure categories by residency,
as well as expenditure detail for lodges and guiding outfits. After adjusting for inflation, we
develop separate final demand vectors for sport hunting and  fishing by residency. The analysis
follows Goldsmith (2000) and Duffield et al. (2007). According to ADF&G's hunting
regulations, the sport hunting season for moose, caribou and bear is mainly in the fall months and
varies by area. For the calculation of annual average jobs, we assume the main  season for sport
hunting to be three months long (ADF&G, 2011).

We define non-consumptive users as those who reported wildlife viewing, camping, kayaking,
hiking, or photography as their primary purpose of their visit. We adjust the most recent 2006
summer and winter visitor estimate for Southwest  Alaska excluding Kodiak by applying the
2006-2009 percent difference in air travelers for Alaska overall (McDowell Group, 2007a &
2007b). The trend in air travelers to Alaska serves as the best indicator for changes to visitation
in Southwest Alaska for two reasons. First, visitors to rural Alaska are mainly independent
travelers, and second they primarily arrive by air in comparison to the  statewide largest share of
visitors who arrive by cruise ship. The Southwest Alaska region closely matches the Bristol Bay
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study region with the exception of Kodiak and the Aleutian Islands. Our analysis excludes
Kodiak but includes an insignificant portion of visitors to the Aleutian Islands.
Since Alaska Visitor Statistics Program counts out-of-state visitors only, we calculate visitor
volume originating within the state based on Littlejohn and Hollenhorst (2007) and Colt and
Dugan (2005) resident share of between ten and eleven percent. We treat visitation to Katmai
NPP separate from other areas of the Bristol Bay region. Visitor volume and expenditure for
Katmai NPP are from Fay and Christensen (2010) and for the remaining Bristol Bay area are
from McDowell Group (2007a). We net out sport fishing and hunting visitation in Katmai NPP
using Littlejohn and Hollenhorst (2007) and for the rest of the region by applying the McDowell
Group (2007a and 2007b) estimate. We assume equal expenditures for residents and non-
residents because the non-resident per person  expenditure estimate in both cases does not include
the cost of travel to and from Alaska. For the expenditure categories associated with non-
consumptive use, we modeled the final demand vector based on Fay and Christensen (2010).
These expenditures categories include transportation within Alaska, food, lodging, guiding
services,  supplies, licenses, etc. For most non-residents all in-state travel expenditures are
included, based on the assumption that the primary reason for the travel to Alaska is the visit the
Bristol Bay region. We allocated these expenditures within a commodity by industry matrix to
form the final demand vector that's then passed to the ISERI-O Model developed by Goldsmith
(2000). For all of these estimates, we paid special attention to the potential for double counting
and addressed those issues.

Note, all  direct jobs are in the Bristol Bay region but the residency of workers and the location
where these workers spend their income is difficult to trace. Multiplier jobs are divided between
Bristol Bay and Southcentral Alaska. Multiplier jobs are assumed to be all taken by residents of
the region where they occur. Peak and annual average direct wages are  assumed to be equal.

 (Subsistence).
We estimate annual expenditures related to subsistence activities for households based on the
only publically  available source  (North Slope Borough, 1993) and adjust for inflation to 2009$.
This estimate is justified as results from similar subsistence surveys are similar (Peterson et al.,
1992). We assume that every household in the region participates in subsistence activities with
varying degrees of involvement  and expense.  We assume Native households to be participating
in subsistence extensively resulting in the entire per household expenditure, whereas Non-Native
households are assumed to be less involved with about a quarter of expenditures related to
subsistence activities compared to Native households as indicated by North Slope Borough
(1993). Due to the lack of data, the economic  significance is quite small if compared to
commercial fishing or non-consumptive use, both in terms of the market jobs and the payroll
generated. For the expenditure categories related to subsistence, we assume maintenance and
repair of boats and trucks to amount to 10% of total annual expense each, purchase of boats and
trucks (10% each), hunting equipment (7%), fuel, repair, and parts (13% each).

Note, all  direct jobs are in the Bristol Bay region. Multiplier jobs are divided between Bristol
Bay and Southcentral Alaska. Multiplier jobs  are assumed to be all taken by residents of the
region where they occur. Peak and annual average direct wages are assumed to be equal.
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5.0 Bristol  Bay Net  Economic Values

The second general accounting framework under which ecosystem services can be measured is
the Net Economic Value (NEV) framework. Net economic value is the value of a resource or
activity that is over and above regular expenditures associated with engaging in an activity or
visiting a resource area. The framework for this accounting perspective is the standard federal
guidelines for estimating net economic benefits  in a system of national accounts (Principles and
Standards, U.S. Water Resources Council 1985). EPA (2010) is a more recent and
complementary set of guidelines.
5.1 Commercial Fisheries

In addition to the regional economic impact of commercial fish harvest in the Bristol Bay, the
commercial fishery has a net economic value related to the expected differences over time
between the ex vessel revenues and the costs of participating in this fishery. One method for
estimating this value is to look at the market prices for commercial fishing permits in the Bristol
Bay. Bristol Bay commercial  fishing permits are of two types,  drift net permits and set net
permits. Regulations closely control many aspects of this permitted commercial harvest,
including types of nets, size of boats, areas fished, and start and end dates of season.  The value
of holding one of these perpetual commercial permits is reflected in the prices that these permits
command when they are transferred between owners. These market prices reflect the value that
commercial operators place on their right to fish the region. That value in turn is a judgment of
the  value of the net income stream that would reasonably be expected from operating the permit
given current and expected future salmon harvest levels and salmon prices.

In 2011, there were 1,862 salmon drift net permits in the Bristol Bay fishery and 981 salmon set
net  permits in the fishery. Every year a portion of these permits are sold and change hands.
Since 1991, an annual average of 155 drift net permits and 89 set net permits have been sold and
changed hands in the Bristol Bay fishery.28 Permit transfers each year generally account for
approximately 8% to 10% of all issued salmon permits in the fishery.

The Commercial Fish Entry Commission also reports average permit transfer prices annually
(and monthly) for the Bristol Bay salmon fishery.29 Over the period from 1991-2011 the average
sales price for Bristol Bay drift net permits has been $149,000  (in constant 2011 dollars). The
average price for set net permits over the same period has been $42,200. The 95% confidence
interval on the mean  drift net price for this period ranges from  $105,500 to $192,700. For the set
net  permit transfers, the 95% C.I. on the mean sales price was between $28,700 and $55,700.30
Table 65 presents the estimated 95% C.I. range of total Bristol Bay drift and  set net salmon
permit value based on the 1991-2011 permit transfer data.  For both types of permits it is
28 The Alaska Fish and Game Commercial Fish Entry Commission publishes annual data on permit transfers at,
http://www.cfec.state.ak.us/RESEARCH/12-lN/12-lN.htm
29 A long time series of monthly and annual permit transfer prices is continuously updated at,
http://www.cfec.state.ak.us/pmtvalue/mnusalm.htm
30 Over the period 1991-2011, a total of 3,246 Bristol Bay drift net salmon permits and 1,867 set net salmon permits
were reported sold by the Commercial Fish Entry Commission.

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estimated that the total value of the permits ranges from approximately $225 million to $414
million.

In order to be comparable to other annual net economic values in this analysis (such as sport
fishing or sport hunting) the market value of commercial fishing permits must be converted into
an annual value reflecting expected annual permit-related net income. The market value of the
permits can be annualized using an appropriate amortization (or discount) rate. The decision to
sell a commercial fishing permit at a given price is an individual (or private) decision. In
deciding on an acceptable sales price, a permit holder considers past profits from operating the
permit, risk associated with future operation of the permit (both physical and financial), and
many other factors. All these considerations weigh on how heavily a permit seller discounts
(reduces) potential future profits from fishing the permit in order to arrive at a lump-sum value
for the permit. Huppert et al. (1996) specifically looked at Alaska commercial salmon permit
operations and sales and estimated the individual discount rate on drift net permit sales in the
Bristol Bay and surrounding fisheries. This discount rate was estimated from both profitability
and permit sales price data. Huppert et al. estimated the implied discount rate appropriate for
annualizing permit sales prices in this setting at 13.52%. This estimate was consistent with
previous estimates for the fishery.31 Use of the 13.52% discount rate from Huppert results in an
estimated annual permit net profit or net income associated with Bristol Bay commercial salmon
fishing of between $30.4 million and $55.9 million.
Table 65. Current Bristol Bay Salmon Fishing Permit Numbers and sale prices, 2011
Permit type

Salmon (Drift net)
Salmon (Set net)
Total
Number
of
permits

1862
981
Current market value
Lower Value -
95%
Confidence
Interval
105,500
28,700

Estimated annual net income
(at 13.52% real discount rate)
Upper Value -
95%
Confidence
Interval
192,700
55,700


Total
Lower Value - 95%
Confidence Interval
196,500,000
28,100,000
224,600,000
$30,400,000
Upper Value -
95% Confidence
Interval
358,800,000
54,700,000
413,500,000
$55,900,000
Just as there is an implied net economic value associated with the fishing aspect of the Bristol
Bay commercial salmon fishery, as outlined above, there is also a net economic value associated
with expected future profits from investments in fish processing facilities in the region.  Data on
Bristol Bay salmon processor average aggregate profit levels is not published. Table 31, above,
shows estimated profit (loss) margins for two years. Clearly, as with permit prices, processor
31 Huppert, Ellis and Nobel (1996) estimated the real discount rate associated with sales of Alaska drift gill-net
commercial permits of 13.52%. Karpoff (1984) estimated the discount rate from sales of Alaska limited entry
permits at 13.95%.
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profits are highly variable year-to-year.  The average value-added associated with salmon
processing for the Bristol Bay fishery is generally equal to or more than the ex-vessel value.
Salmon processors in the Bristol Bay fishery have an "oligopsony" market structure, in that a
small number of buyers of raw fish exist in the market.  Additionally, these buyers are largely
"price makers" in that they set the price paid per pound to fishermen each season.  Given the
unique relationship between fisherman that the small number of processors in the Bristol Bay, it
is estimated that processors derive profits (net economic value) equal to that earned by
fishermen. Therefore, for the purposes of this report it is estimated that the NEV for salmon
producers is equal to that for the fishing fleet.

A second estimate of estimated annual net income for the Bristol Bay commercial salmon
harvest and processing sectors is derived from data presented in a 2003 study of the industry
(Link et al. 2003). The 2003 report, titled "An analysis of options to restructure the Bristol Bay
salmon fishery", includes estimates of both Bristol Bay harvester and processor annual profits
(net income) for the period 1990-2001.  These estimates can be scaled to 2011 values using both
changes in general price levels (CPI-U) and changes in harvester permit values.  The table below
(Table 66) shows the estimation of 2011 harvester  and processor net income estimated from the
Link et al. (2003) report.
Use of this second set of net income estimates and assumptions leads to a calculation of
estimated harvest and processing sector net income that is near the upper 95% bound of the
estimates calculated in this report.  While the analysis based on 1990-2001 data presented above
does suggest that the Table 65 analysis significantly undervalues the harvest sector, while the
assumption of an equal processing sector net income somewhat overvalues the processing sector.
The net effect is that the range of values for the combined harvest and processing sectors include
values significantly below the estimate developed by the second (Table 66) analysis above. For
purposes of presenting a conservative range of value estimates for the commercial salmon sector,
an estimate of total harvester and processor net incomes from $60.8 to $111.8 million is used.
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Table 66. Estimation of Total 2011 Net Income for the Bristol Bay Salmon Harvest and Processing Sectors
based on Reported 1990-2001 Net Income (Link et al. 2003).
Parameter
Assumption/operation
Value
(A) BB Commercial Salmon Harvester Sector Average Annual Net Income Estimation
Average 1990-2001 harvest
sector net income
Average annual BB
commercial salmon fishing
sector net income (1990-2001)
in 20 11 dollars
Adjusted 201 1 profitability
based on differences between
1990-2001 average permit
values and 201 1 permit values
Data from Link et al (2003). Table 12
(p.43).
Annual values updated to 201 1 dollars using
CPI-U
The correlation between profitability in year
X and permit sales price in year x+1 for this
period is 0.857. Based on this observed
close relationship, net income is scaled by
the ratio of 201 1 permit prices to the average
1990-2001 price, or by 79.27%
$93. 7 million
$113. 15 million
$89.69 million
(B) BB Salmon Processing Sector Average Annual Net Income Estimation
Average BB net income of the
salmon processing sector for
the years 1990-2001 in 201 1
$. (Link et al. 2003)
There is no observed correlation between
processor profits and permit prices
(r=0.053). Average processor profits are
assumed to be a constant 23.3% of harvester
profits (the average ratio observed in the
1990-2001 data by Link (2003))
$20.90 million
(QEstimated Sum of Harvest and Processing Sectors Average Annual Net Income
Total estimated annual harvester and processor net income (201 1$) derived
from 1990-2001 data
$110.59 million
(D) Estimated Range of Harvest and Processing Sector Average Annual Net Income
Range of estimates developed in this analysis
$60.8 to $111. 8
million
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5.2 Subsistence Harvest

The Alaska Department of Fish and Wildlife, Division of Subsistence reports that most rural
families in Alaska depend on subsistence fishing and hunting. ADF&G surveys of rural
communities find that from 92% to 100% of sampled households used fish, 79% to 92% used
wildlife, 75% to 98% harvested fish, and 48% to 70% harvested wildlife. Because subsistence
foods are widely shared, most residents of rural communities make use of subsistence foods
during the course of the year.  The subsistence food harvest in rural areas constitutes about 2% of
the fish and game harvested annually in Alaska. Commercial fisheries harvest about 97% of the
statewide harvest, while  sport fishing and hunting take about 1%. Though relatively small in the
statewide picture, subsistence fishing and hunting provide a major part of the food supply  of
rural Alaska (Subsistence in Alaska, a 2000 Update
http://www.subsistence.adfg.state.ak.us/download/subupdOO.pdf).

The Alaskan subsistence harvest is not traditionally valued in the marketplace. Because the
subsistence resources are not sold, no price exists to reveal the value placed on these resources
within the subsistence economy. The prices in  external markets, such as Anchorage, are not
really relevant measures of subsistence harvest value. The supply/demand conditions are unique
to the villages, many of which are  quite isolated. Native preferences for food are strongly held
and often differ from preferences in mainstream society. Additionally, because these are highly
vertically-integrated economies, substantial value-added may occur before final consumption
(such as drying, or smoking fish and meats). In their research on estimating the economic value
of subsistence harvests, Brown and Burch (1992) suggest that these subsistence harvests have
two components  of value, a product value, and what they call an "activity value." The product
value is essentially the market value of replacing the raw subsistence harvest. The activity value
would primarily include  the cultural value of participating in a subsistence livelihood. The
activity value component is also associated with the value of engaging in subsistence harvest and
food processing activities. This activity value would include maintaining cultural traditions
associated with a subsistence livelihood.

Duffield (1997) estimated the value per pound of Alaskan subsistence harvest though use of a
cross-sectional hedonic model of community-specific harvest per capita and community per
capita income levels.   This "wage-compensating differential model" essentially estimates the
average tradeoff across communities between per-capita subsistence harvest (in pounds of usable
harvest) and per capita income levels. In essence, residents of rural Alaskan communities
tradeoff the opportunity to have higher income in a less rural environment with the opportunity
to harvest larger amounts of subsistence resources in more rural communities.

There is a substantial  economics literature that utilizes the hedonic wage, or wage compensating
differential model.  For example, estimates of the trade-off of wages and workplace risk of
mortality are the  basis of the statistical value of life estimates widely used in regulatory analysis
of ambient air and other  standards  (EPA 2008). There is also a literature that relates wages and
amenity values as revealed through choice of location (e.g. Henderson 1982, Clark and Khan
1988). These later models are generally applied to intercity data sets, such as across U.S.
Standard Metropolitan Statistical Areas (SMSA) These models are also used to estimate the
benefits and costs of climate change (e.g. Maddison and Bigano 2003).

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The application of a compensating wage model to a cross-section of Alaska Villages and towns
is consistent with the view that these Alaska cash-subsistence economies are not just a transitory
phase in economic development.  Rather the village economies represent an equilibrium that is a
function of individual choice of where to live and work (Wolfe and Walker 1987; Kruse 1991).

Wolfe and Walker (1987) were the first to estimate a statistical relationship between wage
income and subsistence livelihoods using harvested usable pounds as a measure of subsistence
productivity.  Wolfe and Walker were interested in factors that influenced subsistence
productivity, including construction of roads, settlement activity and income. The data was
based on extensive surveys of Alaska villages undertaken by the applied anthropology group at
Alaska Fish and Game, Division of Subsistence.  Duffield (1997) used the Wolfe and Walker
dataset for 98 villages in a compensating wage specification to inform subsistence harvest
valuation in the context of the Exxon Valdez oil  spill litigation. Hausman (1993), who
represented the defendant in the case (Exxon) also estimated a compensating wage model using
the Wolfe and Walker dataset. Hausman introduced the use of applying an instrumental variable
approach to estimating the model, since wages and subsistence harvests are jointly  determined.

Hausman's (1993) estimate of the value of subsistence harvests (1982 dollars) was $33.60 per
pound and Duffield's (1997) was quite similar at $32.46. The estimated Hausman and Duffield
harvest income models are now based on 30 year-old data. Indexing these results using average
Alaska personal income per capita suggests that were this same relationship to hold today, total
subsistence harvest NEV would be on the order of $75.58 per pound.  In order to avoid making
the assumption that the income—harvest relationship observed in the early 1980s was still valid,
the Duffield  (1997) model was updated using the most recently available per capita income,32
subsistence harvest,33 education,  4 and cost of living data35 for the 90 communities included in
both the Hausman and the Duffield models.

The updated estimated wage compensating differential model shown in Table 67 uses a two-stage
least squares methodology and a linear specification.  The two-stage least squares method is used
to  statistically address the fact that income and harvest levels in the communities are at least
partly co-determined.  The first stage of the model uses an instrumental  variable (the percent of
adults in each community with 4 or more years of college education) along with the remaining
regional indicator variables to predict adjusted gross income per capita for each community.
This predicted income level then was used in the second stage regression. The model explains
54% of the observed variation in harvest levels across communities, and a large majority of the
14 explanatory variables are significant at the 90% level of confidence or greater. The implied
value per pound of subsistence harvest is calculated from the parameter estimate for Adjusted
Gross Income Per Capita.  The implied value per pound is the negative inverse of the income
parameter (-0.01162). [(1/-0.01162)*-! = $86.06]
32 American Community Survey 5-year averages 2006-2010 (Table B19301) www.census.gov/acs/
33 Alaska Fish and Game Department of Subsistence ,  http://www.adfg.alaska.gov/sf/publications/
34 American Community Survey 5-year averages 2006-2010 (Table GCT1502) www.census.gov/acs/
35 McDowell Group, Alaska Geographic Differential Survey: 2008.
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Table 67. Estimated Two-Stage Least Squares Wage Compensating Differential Model of Subsistence
Harvest in 90 Alaska Communities (Duffield 1997).
Variable
Intercept
Adjusted Gross Income Per
Capita
Alaska Peninsula
Copper Basin
Kenai Peninsula
Kodiak
North Slope
NW Arctic
N Cook Inlet
Prince William Sound
South East
South West
Upper Xanana
Urban
West
Observations
R-Squared
Endogenous Variable
Instrumental Variable
Parameter Estimate
936.45
(137.89)***
-0.01162
(0.0051)**
-174.227
(119.08)
-522.132
(86.37)***
-448.975
(120.61)***
-465.551
(111.31)***
227.2387
(172.49)
-112.557
(227.61)
-548.580
(230.87)**
-248.607
(173.95)
-314.787
(103.27)**
-265.364
(101.56)**
-514.022
(130.35)***
-590.972
(169.66)***
-22.1552
(105.28)
90
0.536
Adjusted Per Capita personal income (BEA 2010) (adjusted to
Anchorage dollars using cost-of-living index)
% of adults with 4 or more years of college (plus region indicator
variables)
*=significant at 90% confidence level; **=significant at 95% confidence level; ***=significant
at 99% confidence level.
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One difference between the Hausman and Duffield models and the updated subsistence model is
in the per capita income measure used. Hausman and Duffield both used Alaska Department of
Revenue data on community level adjusted gross income (AGI).  However, Duffield's updated
model utilized average community per capita personal income. This second measure is the more
appropriate income measure in that it includes certain amounts that are deducted from total
income in the calculation of AGI. The updated income measure is consistently larger than the
Alaska AGI originally used, with the latter being on average an estimated 70% of the former.36
The magnitude of the income measure used is directly proportional to the estimated value of
subsistence harvest NEV per pound calculated from the estimated model income parameter.  For
purposes of this report, a  range of values in the following analysis uses both the estimated $86.06
value, based on the updated dataset and adjusted per capita personal income, and a lower bound
estimate of $60.24 per pound ($86.06*0.70) based on the assumption of consistently using
Alaska AGI.

Based on both the Hausman (1993) and Duffield (1997) analyses, in principle the correct way to
value subsistence harvests is to use the compensating wage differential approach. With reference
to the Brown and Burch (1992) perspective, the compensating wage estimate includes both
product and activity value. Duffield (1997) also reports a replacement cost estimate of just
product values for  subsistence harvests at $13.28 per pound.37 In 2009 dollars, this product
                                    TO
value is estimated at $18.86 per pound.

Table 68 shows the accounting of ADF&G Division of Subsistence estimates of total annual
subsistence harvest in most communities in Bristol Bay. This total has been adjusted to include
population in the region not included in the ADF&G subsistence harvest estimates.  In total, we
estimate that about 2.6  million usable pounds of subsistence harvest per year occur in the Bristol
Bay region.  Valued at  an estimated range of $60.24 to $86.06 per pound, this harvest results in
an estimated net economic value  annually for subsistence harvest of between $154.4 and  $220.6
million (Table 69).
36 http://www.irs.gov/uac/SOI-Tax-Stats—Historical-Data-Tables "Table 4. Comparison of Personal Income in the
National Income and Product Accounts (NIPA) with Adjusted Gross Income (AGI). For Specified Tax Years, 1990-
2005).
37 This value is the simple average of the replacement cost of lost harvest between two definitions of households in
the Duffield (1997) paper, p. 109, Table 4.
38 It should be noted that a significant component of subsistence harvest in some communities is marine mammals, a
resource with a very high market replacement cost.

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Table 68. Estimated Total Annual Bristol Bay Subsistence Harvest (usable pounds of harvest)
Bristol Bay Area Community /year of harvest
data
Aleknagik 1989
Clark's Point 1989
Dillingham 1984
Egegik 1984
Ekwok 1987
Igiugig 2005
Iliamna 2004
King Salmon 2008
Kokhanok 2005
Koliganek 2005
Levelock 2005
Manokotak 2000
Naknek 2008
New Stuyahok 2005
Newhalen 2004
Nondalton 2004
Pedro Bay 2004
Pilot Point 1987
Port Alsworth 2004
Port Heiden 1987
South Naknek 2008
Ugashik 1987
Togiak City 2000
Twin Hills 2000
Total surveyed communities
Un-surveyed communities (estimated)
Total including un-surveyed areas
Total Usable Pounds Raw Subsistence
Harvest
64,824
75,020
563,618
41,856
91,655
27,100
51,121
117,062
115,600
187,891
36,363
131,716
143,616
198,390
131,480
58,712
12,852
26,112
21,147
41,616
21,172
9,768
200,982
36,926
2,406,599
156,714
2,563,313
Source: Estimates of community-specific subsistence harvest levels are contained within the Subsistence Technical
Report Series, available at, http://www.adfg.alaska.gov/sf/publications/
It should be noted that although the total annual value of subsistence harvests implied by the
wage compensating differential model is large, simply the market replacement cost of these
resources is fully 32% of the lower-bound estimate and 22% of the upper-bound estimate.  In
addition to simply procuring the usable pounds of raw subsistence harvest, many of these
resources have substantial value-added in the form of processing by drying, smoking, or other
preserving, cleaning, or other processing methods. This value-added is also captured within the
context of the wage compensating differential model.

Another perspective on the revealed economic significance of subsistence harvests in Bristol Bay
is seen by comparing the implied NEV associated with subsistence activities and reported per
capita income in the region.  For the 7,475 Bristol Bay residents (74% of who are Native
Alaskan) subsistence harvests valued at $60.24 per pound imply that the value of these harvests
are about 34% of their total combined per capita 2009 personal income (as reported by BEA)
plus estimated total subsistence value. Valued at $86.06 per pound, subsistence harvest value is
                                           207

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about 42% of total income and subsistence value.  Another component of subsistence value is the
relative effort or allocation of time put into the subsistence sector instead of spending time in the
cash income sector. The effort put into the subsistence sector is estimated to be the same or more
than the full-time equivalent jobs included in the cash sector.
Table 69. Estimated Net Economic Annual Value of Bristol Bay Area Subsistence Harvest
Estimates of Subsistence Value
Value based on Harvested Product
Value
Value based on Wage Compensating
Differential Approach (Adjusted to AK
DOR AGI income measure))
Value based on Wage Compensating
Differential Approach (Based on BEA
per capita personal income measure)
Per Pound
Value
$18.86
$60.24
$86.06
Total
Subsistence
Harvest
2,563,313
2,563,313
2,563,313
Total Annual Value
(Million 2009 $)
$48.3
$154.4
$220.6
5.3 Sport Fishing Net Economic Value

In addition to the direct expenditures that Bristol Bay area sport anglers make each year, there is
substantial net economic value attached to the trips these anglers take to the region.  A measure
of the net economic value of sport fishing trips is the amount anglers are willing to pay over and
above the costs of their trips.  The 2005 Bristol Bay angler survey asked respondents a series of
questions relating to what they spent on their fishing trip, and how much, if any, more they
would have been willing to spend to have the same experience.  This willingness to pay is also
referred to as net economic benefit. There is a large economics literature on estimating sport
fishing net economic benefits (Rosenberger and Loomis 2001).  The method for estimating these
benefits here is contingent valuation using the so called "payment card" question format.

Respondents were presented with a set of amounts ranging from  $0 to $2,000, and asked to mark
the greatest additional increase in spending they would have made to take the same trip. Table
72 shows the mean willingness to pay estimate for the two groups. The net economic value from
the survey data was estimated using an interval estimation model.
Following questions on their trip expenditures, survey respondents were asked whether they felt
their trip was worth more than the amount they actually spent. Those who answered "yes" were
then asked, "What is the largest increase over and above your actual costs that you would have
paid to be able to fish your primary destination?"  Respondents were presented with a series of
dollar amounts ranging from $10 to $2,000.  Table 70 shows the percentage of both resident and
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nonresident Bristol Bay anglers who responded that they would have paid the various additional
amounts to take their Bristol Bay fishing trip.

Table 70. Responses to Current Trip Net Economic Value Question


Willing
$
$
$
$
$
$
$
$
$
$

to Pay More
10
25
50
100
250
500
750
1,000
1,500
2,000
Other amount
NONRESIDENTS
Percent
63.0%
1.1%
0.3%
0.2%
6.2%
16.2%
15.9%
2.5%
9.1%
3.7%
2.3%
4.3%
RESIDENTS
Percent
73.3%
0%
2.1%
3.6%
16.5%
20.5%
7.5%
3.6%
0%
0%
3.6%
15.7%
The estimates of willingness to pay models based on the Table 70 data were developed using a
maximum likelihood interval approach (Welsh and Poe 1998). As noted, respondents were
asked to choose the highest amount he or she was willing to pay from a list of possible amounts.
It was inferred that the respondent's true willingness to pay was some amount located in the
interval between the amount the respondent chose and the next highest amount presented. The
SAS statistical procedure LIFEREG was used to estimate the parametric model of willingness to
pay based on the underlying payment card responses.
Table 71 shows the estimated parametric willingness to pay for trips to Bristol Bay fisheries.
Nonresident anglers state their trip was worth approximately $500 more, on average, than they
actually paid.  Resident Bristol Bay anglers stated they were willing on average to pay an
additional $352 for their most recent trip.  These estimates are similar to other estimates for
Alaska sport fishing (Duffield et al. 2002; Jones and Stokes 1987).
Table 71: Estimated Mean Willingness to Pay for Anglers' Recent Trip to Bristol Bay
Statistic
Estimated mean willingness to pay in addition to trip
costs for those willing to pay more
Percent of respondents willing to pay more for their
trip
Net willingness to pay for Bristol Bay fishing trips for
all anglers
Non-residents
$793
63.0%
$500
Residents
$480
73.3%
$352
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The net economic value per trip estimates shown in Table 71 were calculated from the results of
a bivariate statistical model of the payment card response data using a variant of survival
analysis to examine censored interval data.  The chi-square test of significance for the key
parameters from these models show the estimated coefficients to be statistically significant.

Based on an estimated annual use level of 12,464 trips for nonresidents, and 16,903 trips for
Alaska residents, we estimate that the annual net economic value of fishing trips in the Bristol
Bay region is approximately $12.2 million.
Table 72. Estimated Willingness to Pay for Sportfishing Fishing in the Bristol Bay Region

Estimated mean net willingness to pay
Estimated number of trips/year
Total estimated Net Economic Value
Total annual value
Residents
$ 352
16,903
$5,950,093
Nonresidents
$ 500
12,464
$6,228,350
$12,178,443
5.4 Sport Hunting Net Economic Value

As in the case of sport fishing, there is additional value associated with sport hunting, above
what is actually spent on the activity.  Table 73 details the estimation of annual net economic
value of big game hunting in the Bristol Bay region. Table 73 utilizes ADF&G estimates of
hunter numbers in the game management units associated with the Bristol Bay area, and on
estimates of net willingness to pay per trip for hunting (from Miller and McCollum 1994,
adjusted to current, 2009 dollars).  It is estimated that nonresident net economic value of Bristol
Bay hunting is approximately $1 million annually.  The annual net economic value of big game
hunting in the Bristol Bay  region for Alaska residents is estimated at about $380,000. Therefore
the total annual estimated net economic value of big game hunting in this region is $1.4 million.

Table 73. Estimated annual big game hunting net economic value for Bristol Bay region
Species / Statistic

Moose
Caribou
Brown bear

trips
352
230
741
Total
Nonresidents
Value/ trip
$581
$640
$897

Non-local residents
NEV
$ 204,549
$ 147,298
$ 665,028
$ 1,017,000
Trips
291
311
717

Value/ trip
$268
$250
$307

NEV
$ 77,998
$ 77,892
$ 220,535
$ 376,000
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5.5 Wildlife Viewing and Tourism Net Economic Value

The 1991 study by McCollum and Miller estimated the net economic value of wildlife watching
trips in Alaska. These values adjusted to current dollars results in an estimated value per trip of
$199. Using the 40,164 visitor trips to the region we estimate a 2009 net economic value of
wildlife watching of about $8.1 million.
5.6 Total Net Economic Value and Present Value and Inter-temporal
Issues

Commercial salmon fishery net economic values for fishermen are derived by annualizing the
total value of the perpetual permits to fish the Bristol Bay waters held by fishermen. The value of
these permits is reflected in the prices paid for them when they are exchanged in an open market
and reported by the Commercial Fish Entry Commission. These are on the order of $156,000 for
a drift gillnet permit in 2011, and have been as high as $200,000 as recently as 1993.

The total value of Bristol Bay permits—calculated as the number of permits multiplied by the
permit price—provides an estimate of the total present discounted value of expected future
profits from the fishery. Based on 1991-2011 average permit sales prices (in constant 2011
dollars) the estimated 95% confidence interval on the total value of Bristol Bay permits (both
drift net and set net fisheries combined) was between $224.6 million and $413.5 million.

Multiplying the total value of a permit by the rate of return a permit holder demands on a permit
investment provides a measure of the annual profit permit holders expect to earn. Using a
13.52% amortization (or discount) rate estimated by  Huppert et al. (1996) suggests that annual
expected profits (net economic value) from Bristol Bay commercial fishing is currently between
$30.4 million and $55.9 million.  Note that this does not include expected profits from fish
processing.

Net income for the processing sector is more difficult to estimate. Relative to the fishing sector,
with ex-vessel value of $181 million in 2010,  the processing sector provides an approximately
equal value added of $209 million in 2010 (first wholesale value of $390 million in 2010 less the
cost of buying fish at the ex-vessel cost of $181 million (Figure 79). However, information on
profits or net income for this sector is difficult to obtain.  For purposes of this report, net income
in the processing sector is assumed to be equal to the value for the fishing fleet.
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                      Selected Bristol Bay Salmon Processor Costs, 2001-2009
       "o
       T3
          300
          250
          200
          150
          100
       =   50
                                               III
                 III
             miiiiii
                                         I Other costs
                                          and profits
                                    0 Cost of labor
                                     (fish processing
                                     earnings)
                                         I Cost of fish
                                          (ex-vessel
                                          value)
               8
               CM
CM
8
CM
CO
8
CM
8
CM
in
8
CM
CD
8
CM
8
CM
00
8
CM
O)
8
CM
                                 Source: ADFG.ADLWD
           Figure 79. Selected Bristol Bay Salmon Processor Costs: 2001-2009
The sportfish net economic values are angler recreational benefits (consumer surplus) in Duffield
et al. (2007). These estimates are consistent with values from the extensive economic literature
on the value of sportfishing trips (for example Duffield, Merritt, and Neher 2002). Sport hunting
values are based on studies conducted in Alaska by McCollum and Miller (1994). Annual direct
use net economic values for recreation use of the Bristol Bay area is estimated to be $22.1
million, including $12.2 million for sport fishing, $1.8 million for sport hunting, and $8.1 million
for wildlife viewing and other tourism. In addition to recreationist's net benefits, net income
(producer's surplus) is recognized by the recreation and tourism industry.  This is a component
that remains to be estimated.

Subsistence harvests are valued based on the willingness-to-pay revealed through tradeoffs of
income and harvest in choice of residence location (Duffield 1997).

Based on the National Research Council panel on guidelines for valuation of ecosystem services
(NRC 2005), it is important to include intrinsic or passive use values (aka "non-use" values) in
any net economic accounting of benefits (Figure 80).
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                                      ECOSYST  ;M
  HUMAN ACTIONS
  (PRIVATE/PUBLIC)
                                     ECOSYSTEM GOODS
                                         & SERVICES
             Ce/fts-utijftltva uyj
             if Damning *ralw
Figure 80. Flows of Ecosystem Services (adapted from (National Research Council 2005))
A major unknown is the total value related to existence and bequest motivations for passive use
values. Goldsmith et al. (1998) estimated the existence and bequest value for the federal wildlife
refuges in Bristol Bay at $2.3 to $4.6 billion per year (1997 dollars). There is considerable
uncertainty in these estimates, as indicated by the large range of values. Goldsmith's estimates
for the federal wildlife refuges are based on the economics literature concerning what resident
household populations in various  areas (Alberta, Colorado) (Adamowicz et al. 1991; Walsh et al.
1984; Walsh et al. 1985) are willing to pay to protect substantial tracts of wilderness. Similar
literature related to rare and endangered fisheries, including salmon, could  also be applied here.
It is possible that from a national perspective the Bristol Bay wild salmon ecosystems and the
associated economic and cultural  uses are sufficiently unique and important to be valued as
highly as wilderness in other regions of the U.S. Goldsmith et al.'s (1998) estimates assume that
a significant share of U.S. households (91 million such households) would  be willing to pay on
the order of $25 to $50 per year to protect the natural environment of the Bristol Bay federal
wildlife refuges. The number of these households used in Goldsmith's analysis is based on a
willingness to pay study (the specific methodology used was contingent valuation) conducted by
the State  of Alaska Trustees in the Exxon Valdez oil spill case (Carson et al. 1992). These
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methods are somewhat controversial among economists, but when certain guidelines are
followed, such studies are recommended for use in natural resource damage regulations (for
example, see Ward and Duffield 1992). The findings of the Exxon Valdez study were the basis
for the $1 billion settlement between the State and Exxon in this case. Willingness-to-pay
analyses have also been upheld in court (Ohio v. United States Department of Interior, 880 F.2d
432-474 (D.C. Cir.1989)) and specifically endorsed by a NOAA-appointed blue ribbon panel
(led by several Nobel laureates in economics) (Arrow et al. 1993).

While the primary source of passive use values for Bristol Bay are likely to be with national
households (lower 48), it is important to note that the Alaska natives living in Bristol Bay also
likely have significant passive use values for the wild salmon ecosystem. For example, Boraas &
Knott (2011) quotes Bristol Bay natives in saying "We want to give to our children the fish, and
we want to keep the water clean for them.. .It was a gift to us from our ancestors, which will then
be given to our children.) (Boraas & Knott p. 33).

Goldsmith's estimates for just the federal refuges may be indicative of the range of passive use
values for the unprotected portions of the study area. However, there are several caveats to this
interpretation.  First, Goldsmith et al. estimates are not based on any actual surveys to calculate
the contingent value specific to the resource at issue in Bristol Bay. Rather, they are based on
inferences from other studies a method referred to as benefits transfer. Second, these other
studies date from the 1980's and early 1990's and the implications of new literature and methods
have not been examined.  Additionally, the assumptions used to make the benefits transfer for
the wildlife refuges may not be appropriate for the larger Bristol Bay study area which includes
not only the wildlife refuge, but also two large national parks.  This topic is an area for future
research.
Table 74. Summary of Bristol Bay Wild Salmon Ecosystem Services, Net Economic Value
per Year (Million 2009 $)
Ecosystem Service
Commercial salmon fishery
Fishing Fleet
Fish Processing
Sport fishing
Sport hunting
Wildlife viewing / tourism
Subsistence harvest
Total Direct Use Value
Low estimate

$30.4
$30.4
$12.2
$1.4
$8.1
$154.4
$236.90
High estimate

$55.9
$55.9
$12.2
$1.4
$8.1
$220.6
$354.10
Table 74 details the estimates of annual net economic values for the major sectors tied to the
Bristol Bay Ecosystem. The scope of this characterization report is to use existing data,
information, and estimates to provide a comprehensive picture of the economic structure and
associated values related to the Bristol Bay Ecosystem.  The estimates shown in the table are
based on a variety of sources and methods, and based on data and estimates from a range of
years.  These estimates have been presented in constant 2009 dollars.
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Differences in net economic values across sectors are driven by several factors, including the
number of individuals impacted, the type of market structure, and the scope of resources and
resource services included in the estimates.  For instance, the estimates for subsistence NEV are
between 38% and 73% higher than for the commercial salmon fishery (and processing) sectors.
These two sectors have several key differences, however.  The market for commercial salmon is
highly competitive, with other fisheries (as well as farmed salmon) providing strong price
competition and thus keeping profits and implied NEV low in the sector.  Additionally, the
estimates of commercial fishery NEV are based on commercial fishing permit sales prices.
These sales of generally less than 10% of active permits in a given year represent "marginal"
prices, rather than the "average permit value" to all permit holders.  Those permit holders who do
not sell value their permits more highly than those who do. The commercial fishery NEV
estimates, therefore, are based on conservative marginal values while the subsistence values are
less conservative "average" values.  A third difference between these estimates is that the
commercial fishery NEV is narrowly tailored to salmon fishing and processing, while the
subsistence harvest NEV includes all resources used (including land and marine mammals, fish,
shellfish, and plants).  Salmon harvest only accounts for about one-half of all Bristol Bay
subsistence harvest (in usable raw harvest weight).

The estimates in Table 74 are for annual net economic values. Since these are values for
renewable resource services that in principle should be available in perpetuity, it is of interest to
also consider their present value (e.g. total discounted value of their use into the foreseeable
future). Recent literature (OMB 2003;  EPA 2010; Weitzman 2001) provides some guidance on
the use of social discount rates for long term (intergenerational) economic comparisons.

The controlling guidance document for discounting in Federal cost benefit analysis, OMB
Circular A-4 (2003), generally requires use of discount rates of 3% and 7%, but allows for lower,
positive consumption discount rates, perhaps in the 1 percent to 3 percent range, if there are
important intergenerational values.  The circular states,

       "Special ethical considerations arise when comparing benefits and costs across generations.
       Although most people demonstrate time preference in their own consumption behavior, it
       may not be  appropriate for society to demonstrate a similar preference when deciding
       between the well-being of current and future generations. Future citizens who are affected by
       such choices cannot take part in  making them, and today's society must act with some
       consideration of their interest.

       One way to do this would be to follow the same discounting techniques described above and
       supplement the analysis with an explicit discussion of the intergenerational concerns (how
       future generations will be affected by the regulatory decision). Policymakers would be
       provided with this  additional information without changing the general approach to
       discounting.

       Using the same discount rate across generations has the advantage of preventing time-
       inconsistency problems. For example, if one uses a lower discount rate for future generations,
       then the evaluation of a rule that has short-term costs and long-term benefits would become
       more favorable merely by waiting a year to do the analysis. Further, using the same discount
       rate across generations is  attractive from an ethical standpoint. If one expects future

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       generations to be better off, then giving them the advantage of a lower discount rate would in
       effect transfer resources from poorer people today to richer people tomorrow.

       Some believe, however, that it is ethically impermissible to discount the utility of future
       generations. That is, government should treat all generations equally. Even under this
       approach, it would still be correct to discount future costs and consumption benefits generally
       (perhaps at a lower rate than for intragenerational analysis), due to the expectation that future
       generations will be wealthier and thus will value a marginal dollar of benefits or costs by less
       than those alive today. Therefore, it is appropriate to discount future benefits and costs
       relative to current benefits and costs, even if the welfare of future generations is not being
       discounted. Estimates of the appropriate discount rate appropriate in this case, from the
       1990s, ranged from 1 to 3 percent per annum." (p. 35)

The key question in deciding on an appropriate discount rate or range of rates for analysis is
whether the Bristol Bay ecosystem is a resource of intergenerational significance. Clearly, this
resource base and ecosystem that has been relied on for thousands of years by Alaska natives,
and now has a long-term significance to a growing number of nonnatives, is the very definition
of an intergenerational resource.

Weitzman (2001), conducted an extensive survey of members of the American Economic
Association, and suggests a declining rate schedule, which may be on the order of 4 percent
(real) in the near term and declining to near zero in the long term. He suggests a constant rate of
1.75% as an equivalent to his rate schedule. Weitzman's work is cited both in the EPA guidance
(EPA 2000) and in OMB guidance (Circular A-4 (2003)).  Table 75 shows the estimated net
present value in perpetuity of direct use values within the Bristol Bay Ecosystem.  The table
shows  a range of alternative discount rates from the standard "intragenerational" rates of 7% and
3% to the more appropriate "intergenerational" rates for the Bristol Bay case of 1.75% and 1.0%.
The entire range of NPV estimates in the table is from $3.4 to $35.4 billion. The range of
estimated direct use NPV of the resource using the more appropriate intergenerational discount
rates is from $13.5 to $35.4 billion. These estimates may be quite conservative as they do not
include estimates of passive use values held by those living outside the Bristol Bay Region, but
are limited to direct economic uses of the wild salmon ecosystem services.
Table 75. Estimated Net Present Value of Bristol Bay Ecosystem Net Economic Use Values
and Alternative Assumed Perpetual Discount Rates

                                               Net Present Value (million 2009 $)
Estimate
	Annual Value  7% Discount  3% Discount  1.75% Discount    1% Discount
Low Estimate          $236.9       $3,384        $7,897        $13,537          $23,690
High Estimate	$354.1       $5,059       $11,803       $20,234	$35,410
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References

Ackley, D. 1988. "An Economic Evaluation of Recreational Fishing in Bristol Bay, Alaska."
       Masters Thesis, University of Alaska. Juneau, Alaska.

Adamowicz, W, J, Asapu-Adjaye, P. Boxall, and W. Phillips. 1991. "Components of the
       Economic Value of Wildlife: An Alberta Case Study."  The Canadian Field Naturalist. V.
       105, No. 3. pp. 423-429.

ADOL (Alaska Department of Labor and Workforce Development). 2004. Alaska Department of
       Labor and Workforce Development, Research and Analysis Division, Excel file
       "crewfactor.xls" provided by ADOL to Gunnar Knapp (ISER), 2004.

ADOL (Alaska Department of Labor and Workforce Development). 2008. Nonresidents working
       in Alaska, Economic Trends, March 2008, available at:
       http://labor.alaska.gov/trends/mar08.pdf.

ADOL (Alaska Department of Labor and Workforce Development). 2009a. Bristol Bay Region:
       Fishermen by Residency, available at:
       http://labor.alaska.gov/research/seafood/BristolBay/BBFHVPermRes.pdf.

ADOL (Alaska Department of Labor and Workforce Development). 2009b. Bristol Bay Region:
       Harvesting and Processing Workers and Wages, available at:
       http://labor.alaska.gov/research/seafood/BristolBay/BBoverall.pdf.

ADOL (Alaska Department of Labor and Workforce Development). 2009c. Bristol Bay Region:
       Local Resident Crew Members, available at:
       http://labor.alaska.gov/research/seafood/BristolBay/BBFHVCrewLic.pdf.

ADOL (Alaska Department of Labor and Workforce Development). 2009d. Population data -
       Current place estimates, available at:
       http://labor.alaska.gov/research/pop/estimates/data/TotalPopulationPlace.xls.

ADOL (Alaska Department of Labor and Workforce Development). 2009e. Quarterly Census of
       Employment and Wages, available at: http://labor.alaska.gov/research/qcew/llee.xls.

ADF&G (Alaska Department of Fish and  Game). 2005. "Annual Management Report 2004
       Bristol Bay Area." Report by the Divisions of Sport Fisheries and Commercial Fisheries

ADF&G (Alaska Department of Fish and  Game). 2009a. Commercial Operator Annual Report
       (COAR) database. Excel data file provided by Shellene Hutter (ADF&G) to Gunnar
       Knapp (ISER), August 1, 2011.

ADF&G (Alaska Department of Fish and  Game). 2009b. Sport fishing and sport hunting license
       database.
                                         217

-------
ADF&G (Alaska Department of Fish and Game). 2011. Alaska Hunting Regulations, available
       at: http://www.adfg.alaska.gov/index.cfm?adfg=wildliferegulations.hunting.

Arrow, K., R. Solow, P. Portney, E. Learner, R. Radner, and H. Schuman.  1983. Report of the
       NOAA Panel on Contingent Valuation.

BEA (Bureau of Economic Analysis). 2007. Local Area Personal Income and Employment
       Methodology, Section VIII Residence Adjustment, page VIII-5, available at:
       http://www.bea.gov/regional/pdf/lapi2007/resadj.pdf

BEA (Bureau of Economic Analysis). 2009. Local Area Personal Income and Employment
       Summary, available at: http://www.bea.gov/regional/reis/.

BEA (Bureau of Economic Analysis). 2011. Consumer Price Index for all urban consumers,
       available at: http://www.bls.gov/cpi/.

Bluemink, Elizabeth, 2010, Independent tourists pickup some cruise ship slack, Anchorage
       Daily News, October 20, 2010.

Boraas, A., and C. Knott. 2011. "Traditional Ecological Knowledge and Cultural Assessment of
       the Nushagak and Kvichak Watersheds, Alaska." Report for the U.S. EPA. October 16,
       2011.

Brown, Thomas C., and Earnest S. Burch, Jr.,  "Estimating the Economic Value of Subsistence
       Harvest of Wildlife in Alaska," in George L. Peterson et al., eds., Valuing Wildlife
       Resources in Alaska,  Westview, Boulder, Colo., 1992, 203-254.

Byerly, Mike; Beatrice Brooks, Bruce Simonson, Herman Savikko and Harold Geiger.  1999.
       Alaska Commercial Salmon Catches, 1878-1997.   Alaska Department of Fish and Game
       Regional Information Report No. 5J99-05. March 1999.

Carlson, Stefanie M. 2005. Bristol Bay Salmon Drift Gillnet and Set Gillnet Fisheries: Permit
       Holdings and Participation Rates by Age and Resident Type, 1975-2004, CFEC Report
       05-2N.
       http://www.cfec.state.ak.us/RESEARCH/05  2n/BBResidAgeRpt 060605.pdf.

Carothers, C. 2010. Tragedy  of Commodification: Transitions in Alutiiq Fishing Communities in
       the Gulf of Alaska. MAST 90(2): 91-115
Carson, R., R. Mitchell, W. Hannemann, S. Presser, and P. Ruud. 1992. "A Contingent Valuation
       Study of Lost Passive Use Values Resulting from the Exxon Valdez Oil Spill." Report to
       the Attorney General of the State of Alaska.

CFEC (Commercial Fisheries Entry Commission). 2008. Appendix C . Summary of Net Changes
       in the Distribution of Permit Ownership by Fishery and Resident Type, 1975-2008. page


                                         218

-------
       417 and 420, available at:
       http ://www. cfec. state. ak.us/RESEARCH/09_4N/ChapterAppC%2008 .pdf.

CFEC (Commercial Fisheries Entry Commission). 2009. Fisheries Statistics - Participation and
       Earnings: Basic Information Tables (BITS), available at:
       http://www.cfec. state. ak.us/fishery_stati sties/earnings, htm.

Colt, S. and Dugan, D. 2005. Spending Patterns of Selected Alaska Bear Viewers: Preliminary
       Results from a Survey, Institute of Social and Economic Research, University of Alaska
       Anchorage. Available at:
       http://www.iser.uaa.alaska.edu/Publications/Bearviewing_17march2005.pdf

Champ, P. and R. Bishop. 2006. "Is Willingness to Pay for a Public Good Sensitive to Elicitation
       Format." Land Economics 82(2) 162-73.

Clark, D. and J. Kahn. 1988. :The Social Benefits of Urban Cultural Amenities." Journal of
       Regional  Science 28(3):  363-377.

Dillman, D. 2000. Mail and Internet Surveys: the Tailored Design Method, New York. John
       Wiley and Sons.

Duffield, J. 1997. "Nonmarket Valuation and the Courts: The Case of the Exxon Valdez."
       Contemporary Economic Policy. V. XV. Pp. 98-109.

Duffield, J. P. Merritt, and C. Neher. 2002. "Valuation and Policy in Alaskan Sport Fisheries."  In
       Recreational Fisheries: Ecological Economic and Social Evaluation Pitcher, T. and
       Hollingworth, C. Eds. Blackwell Science. Bangor, Wales, UK.

Duffield, J.; Patterson, D.; Neher,  C.;  and Goldsmith, S. 2007. Economics of Wild  Salmon
       Ecosystems: Bristol Bay, Alaska. USDA Forest Service Proceedings RMRS-P-49,
       available  at: http://www.fs.fed.us/rm/pubs/rmrs_p049/rmrs_p049_035_044.pdf

Fall, J., D. Holen, B. Davis, T. Krieg, and D. Koster. 2006. "Subsistence Harvests  and Uses of
       Wild Resources in Diamna, Newhalen, Nondalton, Pedro Bay, and Pork Alsworth,
       Alaska." Technical Paper 302. Division of Subsistence, Alaska Department of Fish and
       Game. Juneau, Alaska.

Fall, J., T. Krieg, and D. Holen.  2009. "An Overview of the Subsistence Fisheries of the Bristol
       Bay Management Area." Special Publication No. BOF 2009-07. Aladka Deprtment of
       Fish and Game, Department of Subsistence. November 2009.

Fay, G. and Christensen, N. 2010. Katmai National Park and Preserve Economic Significance
       Analysis and Model Documentation prepared for: National Park Conservation
       Association and National Park Service, Katmai National Park and Preserve, 60 pp.,
       available  at: http://www.npca.org/alaska/reports/Katmai_Economic_Report.pdf.
                                         219

-------
Fay, G. and Colt, S. 2007. Southwest Alaska Network Long-Term Visitor Use Monitoring
      Protocol Development, Final Report, prepared for National Park Service, Southwest
      Alaska Network, Inventory and Monitoring Program, October 11, Contract Agreement
      Number: CA9088A0008.

Fix, PJ. 2009. Alaska Residents Statistics Program Final Report, School of Natural Resources
      and Agricultural Sciences, Department of Resources Management, University of Alaska
      Fairbanks, Fairbanks, AK March.

Ghaffari, H., R. Morrison, M. de Ruijter, A. Zivkovic, T. Hantelmann, D. Ramsey, and S. Cowie.
      2011. Preliminary assessment of the Pebble project, Southwest Alaska. Report of
      Wardrop Engineering Inc., a Tetra Tech Company to Northern Dynasty Minerals Ltd.,
      Vancouver, BC.

Gho, Marcus, K. Iverson, C. Farrington, and N. Free-Sloan. 2011. Changes in the Distribution
      of Alaska's Commercial Fisheries Entry Permits, 1975-2010. CFEC Report 11-3N.
      http://www.cfec.state.ak.us/RESEARCH/12-lN/12-lN.htm.

Goldsmith, O., A. Hill, T. Hull, M. Markowski, and R. Unsworth. 1998. "Economic Assessment
      of Bristol Bay Area National Wildlife refuges: Alaska Penninsula/Becherof, Izembek,
      Togiak." Report of the U.S.  Department of Interior, Fish and Wildlife  Service.

Goldsmith, O. "The ISER Alaska Input-Output Model", ISER Working Paper 98.1, revised
      April, 2000.

Hadland, Jeff. "non-Residents Working in Alaska—2002", Alaska Economic  Trends, February
      2004.

Hausman,  J.A. 1993. Deposition of Jerry A. Hausman Ph.D. 11-11-1993, in the U.S. District
      Court for the District of Alaska, in the Exxon Valdez Oil Spill Litigation, Case No. A-89-
      095.

Henderson, J. 1982. "Evaluating Consumer Amenities and Interregional Welfare Differences."
      Journal of Urban Economics. 11:32-59.

Hilborn, R. and M. Mangel. 1997. "The Ecological Detective Confronting Models with Data"
      Princeton University Press, Princeton, New Jersey.

Hoehn, J.,  and A. Randall. 1989. "Too Many Proposals Pass the Benefit Cost  Test." American
      Economic Review. Pp.544-551.

Huppert, D., G. Ellis, and B. Noble. 1996. "Do Permit Prices Reflect the Discounted Value of
      Fishing? Evidence from Alaska's Commercial Salmon Fisheries." Can. J. Fish. Aquat.
      Sci. 53: 761-768.
                                         220

-------
Iverson, K. 2009. CFEC Permit Holdings, Harvests, and Estimated Gross Earnings by Resident
       Type in the Bristol Bay Salmon Gillnet Fisheries. Commercial Fisheries Entry
       Commission, available at: http://www.cfec.state.ak.us/RESEARCH/09_lN/09_lN.pdf.

Jones & Stokes Associates, Inc. 1987. "Southcentral Alaska Sport Fishing Economic Study."
       Study for the Alaska Department of Fish and Game. Anchorage, Alaska.

Kanninan, Barbara J., David J. Chapman, and Michael Hanemann. 1992.  Survey Data
       Collection: Detecting and Correcting for Biases in Responses to Mail and Telephone
       Contingent Valuation Surveys.  Paper presented at the 1992 Annual Research
       Conference, U.S. Bureau of the Census, Washington, D.C.

Karpoff, J.M. 1984. "Insights from Markets for Limited Entry Permits in Alaska." Can. J. Fish.
       Aquat. Sci. 41: 1160-1166.

Knapp, G. 2004. "Projections of Future Bristol Bay Salmon Prices." Available at:
       www.iser.uaa.alaska.edu/iser/people/knapp

Knapp, G. 2011. An Economic Overview of the Bristol Bay Commercial  Salmon Industry.
       available at: www.iser.uaa.alaska.edu.

Knapp, Gunnar. 2011.  Local permit ownership in Alaska salmon fisheries. Marine Policy 35
       (2011)658-666.

Koslow, A. 1986. Limited Entry Policy and Impacts on Bristol Bay Fishermen. Pages 47-62 in S.
       Langdon (ed) Contemporary Alaskan Native Economies. Lanham, MD: University Press
       of America
Krieg, T., J. Fall, M. Chythlook, R. LaVine, and D. Koster. 2007. "Sharing, Bartering, and Cash
       Trade of Subsistence Resources in the Bristol Bay Area, Southwest Alaska." ADF&G
       Technical Paper No. 326.

Krutilla, J. 1967. "Conservation Reconsidered." American Economic Review.

Kruse, J.A. 1991. "Alaska Inupiat Subsistence and Wage Employment Patterns: Understanding
       Individual Choice." Human Organizations 50(4):317-326.
Langdon, S. (Ed.) 1986. Contemporary Alaskan Native Economies. Lanham, MD: University
       Press of America
Link, M., M. Hartley, S. Miller, B. Waldrop, J. Wilen, and J. Barnett. 2003. "An Analysis of
       Options to Restructure the Bristol Bay Salmon Fishery." Bristol Bay Economic
       Development Corporation: Dillingham, AK.

                                         221

-------
Littlejohn, M. and Hollenhorst, S. 2007. Katmai National Park and Preserve Visitor Study
       Summer 2006, University of Idaho Park Studies Unit, Visitor Services Project, Report
       182. Available at: http://www.psu.uidaho.edu/files/vsp/reports/!82_KATM_rept.pdf.

Littlejohn, M. and Hollenhorst, S. 2006, Katmai National Park and Preserve Visitor Study
       Summer 2006 Survey Instrument, University of Idaho Park Studies Unit, Visitor Services
       Project.

Maddison, D., and A. Bigano. 2003. "The Amenity Value of the Italian Climate." Journal of
       Environmental Economics and Management. 45(2):319-332.

McCollum, D. and S. Miller.  1994. "Alaska Hunters: Their Hunting Trip Characteristics and
       Economics." ADF&G, Anchorage, Alaska.

McDowell Group, 2006, A Profile of Visitors to Rural Alaska and the Western Alaska Region,
       Alaska Travelers Survey, prepared for the  State of Alaska, Department of Commerce,
       Community and Economic Development. Available at:
       http://www. commerce, state. ak.us/ded/dev/toubus/pub/Western_Alaska.pdf

McDowell Group, DataPath Systems, Davis, Hibbitts & Midghall,  Inc., 2007a, Alaska Visitor
       Statistics Program, Alaska Visitor Volume and Profile, Summer 2006, prepared for the
       Alaska Department of Commerce, Community and Economic Development. Available
       at: http://dced.state.ak.us/ded/dev/toubus/research.htm.

McDowell Group, DataPath Systems, Davis, Hibbitts & Midghall,  Inc., 2007b, Alaska Visitor
       Statistics Program, Alaska Visitor Volume and Profile, Fall/Winter 2006-2007, prepared
       for the Alaska Department of Commerce, Community and Economic Development.
       Available at: http://dced.state.ak.us/ded/dev/toubus/research.htm.

McDowell Group, 2011, Alaska Visitor Statistics Program VI Interim Visitor Volume Report
       Summer 2010, DRAFT prepared for the State of Alaska, Department of Commerce,
       Community, and Economic Development, Division of Economic Development, February
       2011.

MIG (Minnesota IMPLAN Group). 2011. IMPLAN economic modeling, available at:
       http://implan.com/V4/Index.php.

Montana Department of Justice. 2011. Natural Resource Lawsuit Settlements and Litigation.
       http://doj.mt.gov/lands/lawsuit-history-and-setttlements-2/  Accessed Dec 13, 2011.

National Marine Fisheries Service, Office of Science and Technology. 2011. Fisheries of the
       United States, 2010. http://www.st.nmfs.noaa.gov/stl/publications.html.

National Park Service, Southwest Alaska Network, Long-Term Visitor Use Monitoring
       Commercial Use Authorization database, 2005-2010 data.
                                         222

-------
National Research Council. 2005. Valuing Ecosystem Services: Toward Better Environmental
       Decision Making. National Academy Press, Washington, D.C.

North Slope Borough. 1993. North Slope Borough 1993/94 Economic Profile and Census
       Report. North Slope Borough Department of Planning and Community Services.

Northern Economics. 2009.  The Importance of the Bristol Bay Salmon Fisheries to the Region
       and its Residents. Report prepared for the Bristol Bay Economic Development
       Corporation.  193 pages. October 2009.

Northern Economics. 2011. 2010 Bristol Bay Processor Survey.  Prepared for Bristol Bay
       Regional Seafood Development Association, February 2011.
       http://www.bbrsda.com/layouts/bbrsda/files/documents/
       bbrsda_reports/BB-RSDA%202010%20Survey%20Final%20Report.pdf

Peterson, G., et al., eds.  1992. Valuing Wildlife Resources in Alaska, Westview, Boulder, Colo.

Polome, P., A. vanderVeen, and P. Geurtz. 2006. "Is Referendum the Same as Dichotomous
       Choice Contingent Valuation?" Land Economics, 82(2) 174-88.

Randall, A. and J.  Stoll. 1983. "Existence Value in a Total Valuation Framework." IN Managing
       Air Quality and Scenic Resources at National Parks and Wilderness Areas. (Rowe and
       Chestnut, Eds. 1983).

Romberg, W. 1999. Market Segmentation, Preferences and Management Attitudes of Alaska
       Nonresident Anglers." Master's Thesis, Virginia Polytechnic Institute and State
       University, Blacksburg, VA.

Rosenberger, R., and J. Loomis. 2001. "Benefit Transfer of Outdoor Recreation Use Values: A
       Technical Document Supporting the Forest Service Strategic Plan (2000 revision). Ft.
       Collins, CO.  59p.

Sears, J., N. Free-Sloan, C. Tide, and K. Iverson. 2009. Changes in the Distribution of Alaska's
       Commercial Fisheries Entry Permits, 1975-2008. CFEC Report 09-4N.
       http://www.cfec.state.ak.us/RESEARCH/09 4N/09 4N.htm.

Schelle, K., K.Iverson, N. Free-Sloan and S.  Carlson. 2004. Bristol Bay Salmon Drift Gillnet
       Fishery Optimum Number Report.  CFEC Report 04-3N.
       http://www.cfec.state.ak.us/RESEARCH/04 3N.htm.

Schelle, K., N. Free-Sloan, and C. Farrington. 2009. Bristol Bay Salmon Drift Gillnet Two-
       Permit Operations: Preliminary Estimates from 2009 District Registration Data. CFEC
       Report 09-6N. http://www.cfec.state.ak.us/RESEARCH/09-N/bbr final  v4 121409.pdf.
                                         223

-------
Schindler, D., R. Hilborn, B. CHasco, C. Boatright, T. Quinn, L. Rogers, and M. Webster. 2010.
       "Population Diversity and the Portfolio Effect in an Exploited Species." Nature 465, pp.
       609-612.

Subsistence in Alaska, a 2000 Update
       http://www.subsistence.adfg.state.ak.us/download/subupdOO.pdf).

U.S. Bureau of the Census. 2011. http://quickfacts.census.gov/

U.S. Department of Commerce. 2009. Consolidated Federal Funds Report for Fiscal Year 2009,
       State and County Areas. U.S. Census Bureau, available at:
       http ://www. census .gov/prod/201 Opub s/cffr-09. pdf

U.S. Department of the Interior, Bureau of Land Management and Minerals Management
       Service. 2005. "Northwest National Petroleum Reserve-Alaska: Final Amended
       IAP/EIS." Anchorage, AK January, 2005.

U.S. Environmental Protection Agency (U.S. EPA). 2000. Guidelines for Preparing Economic
       Analyses. EPA 240-R-00-003.

Viscusi, W. and J. Aldy. 2003. "The value of a Statistical Life: A Critical Review of Market
       Estimates throughout the World." The Journal of Risk and Uncertainty. 27(l):5-76.

Walsh, M. and G. Poe. 1998. "Elicitation Effects in Contingent Valuation: Comparisons to a
       Multiple-bounded Discrete Choice Approach." Journal of Environmental Economics and
       Management 36(2): 170-185.

Walsh, R., J. Loomis, and R. Gillman. 1984. "Valuing Option, Existence, and Bequest Demands
       for Wilderness." Land Economics , Vol. 60, No. 1, pp. 14-29.

Walsh, R, R. Bjonback, D. Rosenthal, and R. Aiken. 1985. "Public Benefits of Programs to
       Protect Endangered Wildlife in Colorado, Symposium on Issues and Technology in
       Management of Impacted Western Wildlife." Thorne Ecological Institute, Glenwood
       Springs,  CO.

Ward, K. and  J. Duffield. 1992. Natural  Resource Damages: Law and Economics John Wiley
       and Sons, Inc.

Weisbrod, B.  1964. "Collective Consumption Services  of Individual Consumption Goods."
       Quarterly Journal of Economics. 78 pp. 471-477.

Weitzman, M.L. 2001. Gamma Discounting. American Economic Review 91(1): 260-271.

Wolfe, R. and L. Ellanna (compilers). 1983.  "Resource Use and Socioeconomic Systems: Case
       Studies of Fishing and Hunting in Alaskan Communities." Technical Paper 61. Division
       of Subsistence, Alaska Department of Fish and Game. Juneau, Alaska.


                                         224

-------
Wolfe et al. 1984. "Subsistence-based Economies in Coastal Communities of Southwest
       Alaska." Technical Paper 89. Division of Subsistence, Alaska Department of Fish and
       Game. Juneau, Alaska.

Wright, J., J. Morris, and R. Schroeder. 1985. "Bristol Bay Regional Subsistence Profile."
       Technical Paper 114. Division of Subsistence, Alaska Department of Fish and Game.
       Dillingham, Alaska.
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DRAFT                                                 EPA910-R-12-004Bc
DO NOT CITE OR QUOTE                                   April 2013
                                                      Second External Review Draft
                                                      www.epa.gov/bristolbay
      An Assessment of Potential Mining Impacts on Salmon
                  Ecosystems of Bristol Bay, Alaska


                   Volume 3 of 3 -Appendices E-J


       Appendix F: Biological Characterization: Bristol Bay
      Marine Estuarine Processes, Fish and Marine Mammal
                             Assemblages
                                 NOTICE
   THIS DOCUMENT IS AN EXTERNAL REVIEW DRAFT. It has not been formally released by
   the U.S. Environmental Protection Agency and should not be construed to represent Agency
   policy. It is being circulated for comment on its technical accuracy and policy implications.
                       U.S. Environmental Protection Agency
                                Seattle, WA

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       Biological Characterization:



   Bristol Bay Marine Estuarine Processes,



   Fish and Marine Mammal Assemblages







                February 2013
                  Prepared for




  U.S. Environmental Protection Agency, Region 10




     1200 6th Avenue, Seattle Washington, 98101








                  Prepared by




  National Oceanic and Atmospheric Administration




Habitat Conservation Division, Anchorage Field Office




         National Marine Fisheries Service




 222 West 7th Avenue Anchorage, Alaska 99513-7577

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Page Intentionally Left Blank

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                                 Acknowledgements

This report was compiled and written by Douglas Limpinsel, NOAA's National Marine Fisheries
Service, Habitat Conservation Division, Alaska Region. Acknowledgements are extended to all
of the following people (In alphabetical order by affiliation and last name) for verbal or literary
contributions, direction and content of the discussion, wholly or in part.

Alaska Department of Fish and Game:  Timothy Baker, Lowell Fair, Laura Jemison, Lori
Quakenbush

Bristol Bay Native Community and Associates: Robert Andrew, Gregory Andrew, Peter
Andrew, Daniel Chythlook, Susan Flensburg, Tina Tinker

NOAA/NMFS - Alaska Fisheries Science Center and National Marine Mammal Lab:
Robin Angliss, Kerim Aydin, Steve Barbeaux, Troy Buckley, Daniel Cooper, Keith Cox,
Douglas Demaster, Edward Farley, Robert Foy, Sarah Gaichas, Jeffry Guyon, Paula Johnson,
Sonja Kromann, Robert Lauth, Robert McConnaughey, Jamal Moss, Philip Mundy, James
Murphy, Daniel Nichol, Olav Ormseth, Elizabeth Sinclair, Thomas Wilderbuer

NOAA/NMFS - Alaska Region, Habitat Conservation Division: Matthew Eagleton, Jeanne
Hanson, Jon Kurland, Brian Lance, John Olson, Eric Rothwell

NOAA/NMFS - Alaska Region, Protected Resources Division: Michael Williams

University of Alaska - Fairbanks and Bristol Bay Campus: Ken Coyle, Todd Radenbaugh

University of Washington - School of Fisheries and Joint Institute for the  Study of the
Atmosphere and Ocean:  Nancy Kachel, Katherine Myers (retired), Thomas  Quinn, Daniel
Schindler.
                                         m

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             IV

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                                      ABSTRACT

Bristol Bay consists of a large, shallow sub-arctic marine estuary with distinct inner and outer
bay processes. The entire bay is defined as waters east of the 162° longitude line. The outer bay is
heavily influenced by marine currents, tides, and oceanic processes from the Southeastern Bering
Sea. The inner bay, generally defined as waters between Cape Constantine in the north and
Ugasik Bay in the south (Nushagak and Kvichak bays), are heavily influenced by high volumes
of fresh water from several river systems.  This fresh water influence dominates the head of
Bristol Bay and much of the northern Togiak Bay nearshore zone.  Nearshore currents in the
larger bay generally follow a counter-clockwise gyre, moving east along the Alaska Peninsula
before moving north and eventually west around Cape Newenham.  Species assemblages and
trophic interactions between marine invertebrates and anadromous, groundfish, and forage
species are complex.  Walleye pollock, yellowfin and rock sole,  and red king crab represent
marine species that in larval and juvenile phases are transported  along currents into nearshore
estuarine nursery habitat.  Recent studies suggest complex predator-prey assemblages in nutrient-
rich convergence zones between the inner and outer bay complex and along the northern
nearshore zone. All five species of Pacific salmon are well established in these waters with
historically stable and productive populations.  Salmon, a unique keystone species, facilitate
energy and nutrient transfer across multiple trophic levels from terrestrial head waters through
pelagic marine ecosystems.  Outbound migrations of billions of salmon smolt provide nutrition
for numerous trophic levels and marine species. As juveniles, salmon smolt are recognized as a
forage fish species. In their returning adult phase, they provide a valuable nutrient source to
marine mammals and subsidize watersheds in the form of Salmon Derived Nutrients or Marine
Derived Nutrients. These outwelling nutrients flushed into estuaries further contribute nutrient
to estuarine processes.  The range and distribution of Bristol Bay salmon have been documented
throughout the Bering Sea, north into the Chukchi Sea and south into the North Pacific and Gulf
of Alaska. Several marine mammal species such as killer and beluga whales, seals, and Steller
sea lions are all known to inhabit Bristol Bay and pursue juvenile and adult salmon up rivers in
the  region.

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             VI

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Table of Contents




BRISTOL BAY	1




  Estuarine Processes - Marine Influence	2




  Estuarine Processes - Terrestrial Influence	2




Bristol Bay Marine Fish Assemblages	3




  Inner Estuarine Fish Assemblage	3




  Nearshore Fish Assemblages	4




  Offshore Fish Assemblages	4




Bristol Bay Salmon	6




  Range and Distribution	6




  Salmon Contribution to Trophic Levels	7




Bristol Bay - Marine Mammals	8




  Pinnipeds	9




  Toothed Whales	10




  Baleen Whales	11




Discussion:	11




  Habitat Condition	11




  Water	12




  Estuaries	12




  Salmon Food Habits	13




  Critical Size	13




  Trophic Contribution	14




  Summary	15
                                          Vll

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Bibliography: By Section	16




  Bristol Bay Marine and Estuarine Processes	16




  Bristol Bay Fish Assemblages	18




  Bristol Bay Salmon	20




  Bristol Bay Marine Mammals	25




  Discussion	29




Tables	38




  Table 1: Fish and Invertebrate Species List	38




  Table 2: Marine Mammals Species List	48
                                          vm

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                                   BRISTOL BAY
For the purpose of this discussion, we define Bristol Bay as the marine waters east of the 162°
West longitude line along the shoreline from Cape Newenham to Cape Lieskof (Fig 1).  In this
context, Bristol Bay comprises approximately 1,300 kilometers of linear shoreline and nearly
65,400 square kilometers of semi-pelagic, nearshore, and estuarine habitat.

Bristol Bay consists of a large, shallow sub-arctic marine estuary with distinct inner and outer
bay processes. The inner bay processes are continuously fed large volumes of fresh water from
several watersheds and river systems, with salinity gradients increasing toward the 162 longitude
line. The benthic topography is essentially flat (average gradient of 0.02 percent) with minimal
variations in relief toward the continental slope. Within this gentle contour, Bristol Bay achieves
an approximate maximum depth of 70m (Moore 1964, Buck et al. 1974).
      SOUTHEAST
      BERING SEA
                                                                           KuichakBay
                                                                        EgegikBay
                                                             UgashikBay
                                                                        GULF OF ALASKA
 UnimakPass
                                     1«2 LomjiUKleLine
Figl. Bristol Bay: Showing general current patterns (green arrows), benthic contour lines (50 and 100m
blue dash), 162° West longitude line (brown dash), and significant land marks as reference (labeled).

Historically, Bristol Bay has been identified as having two relatively distinct current zones
referred to as the inner and outer bays.  Currents were generally characterized as moving in a
counter-clockwise gyre under the influence of 3- to 23-foot tides (Buck et al. 1974, Straty 1977,
Straty and Jaenicke 1980). Recent investigations describe the same waters as three current-
                                             1

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driven domains essentially based on depth: coastal or inner domain (0-50 m depth), a middle
domain (50-100 m depth), and an outer or shelf domain (100-200 m) (Kinder and Coachman
1978, Kinder and Schumacher 1981, Coachman 1986, Schumacher and Stabeno 1998, Stabeno et
al. 2001).  The distinct physical properties can be documented (salinity, temperature, turbidity) at
defined depths. However, the waters within each domain are highly interactive, constantly
shifting under seasonal weather patterns and tides and currents. Bristol Bay and associated
marine and estuarine processes are heavily influenced by often severe Eastern Bering Sea and
Arctic weather. The earlier descriptions of the inner and outer bay complexes lie within these
more recent descriptions of the middle and inner domains.


Estuarine Processes - Marine Influence

Outer Bristol Bay is essentially an extension of the Eastern Bering Sea. Flood tides from the
North Pacific enter the Eastern Bering Sea through several Aleutian Island passes contributing to
the Aleutian North Shore Current (Schumacher et al.  1979, Reed and Stabeno 1994, Stabeno et
al. 2002 and Stabeno et al. 2005). To the east of Unimak Pass, the remnant of this current
continues as the Bering Coastal Current, moving northeasterly along the Alaska Peninsula
toward Bristol  Bay (Kachel 2011, pers. comm.). Much of this current diverts north along the 50-
meter contour forming a subtle, always shifting boundary between inner and outer bay waters
(Coachman 1986).  These currents eventually flow north and west around Cape Newenham
toward Nunivak and Pribilof Islands. Seasonal levels of upwelling marine nitrates, carbon,
phosphates and silica are quite high throughout the estuaries' inner domain contributing to the
species complexity of Bristol Bay (Buck et al. 1974, Stockwell et al. 2001, Kachel et al. 2002,
Coyle and Pinchuk 2002, Stabeno and Hunt 2002, Ladd et al. 2005).  Considerable mixing
occurs at the convergence of the inner and outer bay waters, often the area between Cape
Constantine and Cape Newenham. Benthic substrate in the outer bay generally consists of silts
and mud to vast aggregates of sand, gravel, cobble, and boulder (Sharma et al. 1972, NOAA
1987, Smith and McConnaughey 1999).

Estuarine Processes - Terrestrial Influence

Marine characteristics of the inner bay are heavily influenced by continual freshwater runoff
from several river systems (Straty 1977, Straty and Jaenicke 1980).  Four large rivers flow into
Nushagak Bay: the Igushik, Snake, Wood-Tikchik and Nushagak, and three rivers flow into
Kvichak Bay: the Naknak, Alagnak, and Kvichak.

The contributing discharge has been assessed  as 112x10 9 cubic meters of fresh water annually
(-125,400-cubic feet per second [cfs] annual  average) contributed to the inner bay and estuary
complex (Buck et al. 1974).  The Nushagak and Kvichak Rivers drain 22,172  square miles
(14,190,134 acres) of watershed (USGS 2011). The Nushagak River has a mean annual
discharge of 28,468 cfs, based on the summation of the Nushagak River gage (USGS No.
15302500, 23,645 cfs) and the Wood River gage (USGS No. 15303000, 4,823 cfs). The
Kvichak River USGS gage (USCS No. 15300500) located at Iguigig (the outlet of Lake Iliamna)
has an average annual flow of 17,855 cfs.  Assuming these three gauges represent an accurate
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estimate, the total discharge is 46,323 cfs, or approximately 33,536,000-acre-feet per year1.
There are many other sources of fresh water contribution not monitored or included in this
estimate.

This fresh water influence dominates the head of the bay between April and November.  Out-
welling water contributions are significantly higher in the summer than winter due to freezing
surface water conditions in the watersheds. As a result, summer ebb tide currents often
considerably exceed the flood tides.  Discharges from these watersheds keep the inner bay waters
colder than the outer bay in early spring; however, by mid-summer these temperatures reverse
with much warmer terrestrial discharges (Buck et al. 1974). Additionally, the counter-clockwise
gyre of the inner bay concentrates these freshwater discharges in Nushagak Bay and maintains
lower salinity compared to Kvichik bay. The highest recorded sea surface salinity measurement
in the middle estuary of the Nushagak is 10 parts per thousand (ppt), compared to 20ppt in the
Kvichik (Radenbaugh 2011, pers. comm.).

The inner Bristol Bay coastal domain exhibits the least fluctuation in saline but the greatest
fluctuation in temperature of the three domains, because of the tremendous freshwater influences
(Straty and Jaenicke 1980).  Earlier studies characterizing temperature and salinity gradients
illustrate differences in salinity and temperature between the innermost bay (salinity 28.9% and
temp 11.4°C) and the outermost bay (salinity 32.7% and temp 7.4°C) (Buck et al. 1974, NOAA
1987). Recent analysis of oceanographic currents, condition, and nutrients of the inner domain
(inner and outer bay) confirms generally shallow, wind-driven, well-mixed, homogenous,
nutrient-laden waters (Coyle and Pinchuk 2002, Kachel et  al. 2002, Stabeno and Hunt 2002).
Benthic substrate in the inner bay consists of mostly a composite of mud, silts, sands, and patchy
gravels (Sharma et al. 1972, NOAA 1987, Smith and McConnaughey 1999).
Bristol Bay Marine Fish Assemblages

Inner Estuarine Fish Assemblage

Recent biological surveys in the Nushagak Bay estuary indicate that the dominant species in
numbers and biomass include bay shrimp (Crangon alaskensis) and two species of Gammarus:
Gammarid amphipods and mysiids (Radenbaugh 2010, pers. comm.). Walleye pollock
(Theragra chalcogramma), generally recognized as a semi-pelagic  species, have been identified
in these nearshore surveys between Protection and Etolin Points.  Flatfish species
(Pleuronectiformes) such as yellowfm sole (Limanda asperd) have  also been confirmed in
nearshore habitats. Numerous other fish and invertebrate species are also abundant.
 The total discharge for the three river systems calculated as the annual sum of the daily mean discharges for respective periods of record.
Kvichak River 1967-1987, Nushagak River 1977-1993, Wood River 1957-1970.

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Nearshore surveys conducted by NOAA's Alaska Fisheries Science Center (NOAA-AFSC) in
Nushagak and Togiak bays further illustrate the diversity of nearshore fish and invertebrate
species (Olmseth 2009), identifying over 40 fish and invertebrate species. Most captured
individuals were less than 20 cm in length. Of these species, shrimp (Crangonidae) and rainbow
smelt (Osmerus mordax) were the most abundant species encountered, occurring in almost every
trawl and beach seine. The dominance of these species in catches was especially high in very
shallow water with mud and silt bottoms. Forage fish species identified were salmon smolt
(Salmonidae), capelin (Mallotus villosus) and herring (Clupea pallasif), as well as poachers
(Agonidae), sculpin (Cottoided), flatfish (Pleuronectiformes), and greenling (Hexagraaidae).

Nearshore Fish Assemblages

The importance and contribution of forage fish populations to marine trophic levels and
ecosystems are widely recognized. Forage fish species such as Pacific herring,  eulachon
(Thaleichthyspacificus), capelin, and rainbow smelt are all well documented in different
nearshore zones of Bristol Bay (Warner and Shafford 1981, Mecklenburg et al.  2002, Bernard
2010). Pacific herring are known to spawn in nearshore waters of Togiak and along the northern
shoreline of the Alaska Penninsula (Bernard 2010). Sand lance (Ammodytes hexapterus) have
been found in particular abundance in these nearshore waters of the Alaska Peninsula (McGurk
and Warburton 1992). Bristol Bay salmon smolt are also considered forage fish (Gaichas and
Ay din 2010).

Surveys conducted primarily to characterize the presence and distribution of forage fish species
(sand lance and rainbow smelt) in Bristol Bay nearshore waters also identified several species of
groundfish: Pacific cod (Gadus macrocephalus) and walleye pollock as well as  juvenile sockeye
salmon (Oncorhynchus nerkd) (Isakson et al. 1986, Houghton 1987).  In  one phase of this
survey, researchers found juvenile  sockeye salmon to be more abundant than any forage fish or
juvenile ground fish species encountered. Present again, though in lesser numbers, were Pacific
herring, capelin, pond and surf smelt, and eulachon.  The presence, abundance,  and biodiversity
of these species in Bristol Bay estuaries and nearshore  habitat reflect our current understanding
of these areas as nutrient-rich fish nurseries.

Similar surveys of nearshore habitat conducted in neighboring Alaskan waters further illustrate
the complexity and diversity offish and invertebrate assemblages (Norcross et al. 1995,
Abookire et al. 2000, Abookire and Piatt 2005, Arimitsu and Piatt 2008,  Thedinga et al. 2008,
Johnson et al. 2010). Anadromous species, as well as groundfish, forage fish and invertebrate
species are all well represented in many of these nearshore and estuarine areas in a variety of
different habitat and substrate types throughout Alaskan nearshore and estuarine zones.

Offshore Fish Assemblages

NOAA-AFSC has conducted annual  surveys of the Eastern Bering Sea (BBS) offshore and outer
Bristol Bay waters since 1982.  These surveys provide  a representation of the numerous
groundfish species that inhabit the BBS and Bristol Bay deeper than the 15-20m contour (Lauth

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2010). Data from these surveys are used to monitor status of stocks, assist in establishing annual
commercial catch limits, and evaluate trends in ecosystem and trophic level complexity.

Hundreds offish and invertebrate species inhabit Bristol Bay waters and contribute to countless
trophic levels at various life stages. Description of all known species is beyond the scope of this
discussion. However, all species identified in these surveys are listed to provide some context
(Table 1). To summarize the more commonly recognized species: represented are cod and
pollock (Gadidae), fifteen species of flatfish (Pleuronectiformes), and forage fish species such as
herring, eulachon, capelin, smelts, sand lance and sandfish. Dozens of other species of skate
(Rajidae), poachers (Psychrolutidae\ greenling (Hexagrammos), rockfish (Scorpaenidae),
sculpin (Cottidae), crab (Cancer), and salmon are also well represented.

The transport and distribution of larval marine fish and invertebrate species from offshore to
nearshore nursery areas are widely recognized (Norcross et al. 1984, Lanksbury et al. 2007).
This relationship between species presence and oceanic and estuarine processes is represented in
Bristol Bay in the life histories of species such as red king crab (Paralithodes camtschaticus),
yellow fin and rock sole, and walleye pollock. Larval forms of each species are transported and
concentrated in nutrient rich nearshore and estuarine habitat in the inner bay.

The second-largest population of red king crab is located in Bristol Bay (Dew and
McConnaughey 2005, Chilton et al. 2010). Although red king crabs at several stages of maturity
are found throughout central Bristol Bay, immature larvae and juveniles are often concentrated
along nearshore areas in the inner bay depending on environmental influences. A key habitat
feature supporting this life history strategy is the "unbroken coastal shelf and longshore current"
which transports larval king crab from the BBS and outer Bristol Bay to the inner bay complex.
As previously discussed, this current is driven by the Aleutian North Shore Current and Bering
Coastal Current. As a result of nektonic and planktonic drift through the Bristol  Bay gyre, larval
red king crab settle in cobble and gravel substrates of Kvichak Bay (Loher et al.  1998) and are
present along nearshore zone in the Togiak district (Olmseth 2009).

The nearshore benthic substrates of inner and outer Bristol Bay are optimal habitat for several
species of flatfish and invertebrates that inhabit the BBS (McConnaughey and Smith 2000).
Flatfish species are well  represented in this nearshore coastal domain as well (Lauth 2010 -
Table 1). Life histories of several flatfish species,  specifically yellowfm and rock sole, take
advantage of similar current mechanisms that transport larvae into favorable nursery areas
(Nichol 1998, Wilderbuer et al. 2002, Norcross and Holladay 2005, Lanksbury et al. 2007,
Cooper et al. 2011). Larval and juvenile yellowfm sole are present (Olmseth 2010) and abundant
in shallow nearshore  areas along the northern shore and Togiak Bay (Nichol 1998, Wilderbuer et
al. 2002).

Walleye pollock are a semi-pelagic species spawning in open marine waters (Bailey et al. 1999).
As discussed in Coyle (2002), pollock in their larval and juvenile forms are also known to be
transported into nearshore nursery zones. The presence of pollock eggs and larvae along the
north shore of the Alaska Peninsula is apparently fairly common (Bailey et al., 1999). Prevailing
currents are northward, along the eastern shore of Bristol Bay (Napp et al., 2000).  The eggs and
                                            5

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larvae from the Alaska Peninsula region are apparently transported northward by the current and
by August-September the zero year class juveniles are observed off Cape Newenham and
Nunivak Island (Bailey et al., 1999).

The trophic relationship between fish (predator) and invertebrate (prey) species is intuitive. A
recent investigation of trophic interactions using stable isotopes provides further explanation and
illustrates a stronger correlation between pollock and euphasiid populations near the convergence
zone within the inner domain (Aydin 2010).  Pollock, found in northern nearshore zones feeding
on mysiids show "a higher 515N ratio than pollock in the southwest along the Alaska Peninsula."
The results further suggest "Mysiids are more abundant in the diets of pollock in the northern
near shore zone than deepwater forage fish". These findings further substantiate our
understanding of nearshore and estuarine zones as nutrient rich fish nursery areas, but may also
suggest evidence of a terrestrial driven nutrient contribution to a marine estuary.
Bristol Bay Salmon

The ecological role of Bristol Bay salmon is complex. Salmon facilitate energy and nutrient
exchange across multiple trophic levels from terrestrial headwaters through marine ecosystems.
Each species migrates through these ecotones at slightly different times depending on life history
and watershed of origin. Bristol Bay sockeye salmon, because of their abundance, distribution,
and overall economic importance, have been more extensively studied than other salmonids in
the region.  Generally, once in marine waters juvenile salmon spend their first summer in
relatively shallow waters on the southeastern Bering Sea shelf, feeding, growing and eventually
moving offshore into the Bering Sea basin and North Pacific Ocean (Meyers et al. 2007, Farley
et al. 2011, Farley 2012, pers. comm.).

Range and Distribution

Essential Fish Habitat (EFH) for juvenile salmon, because of their broad range and distribution,
is generally defined as all marine waters over the continental shelf within the Bering Sea
extending north to the Chukchi Sea, and over the continental shelf throughout the Gulf of Alaska
and within the inside waters of the Alexander Archipelago (Echave et al. 2011). EFH for
immature and mature Pacific salmon includes nearshore and oceanic waters, often extending
well beyond the shelf break, with fewer areas in the Alexander Archipelago (Echave et al. 2011).
The Magnuson-Stevens Fisheries Conservation and Management Act defines EFH as waters and
substrate necessary to fish for spawning, breeding, feeding, or growth to maturity. For salmon,
EFH comprises those fresh and marine waters needed to support healthy stocks and provide
long-term sustainable salmon fisheries (Eagleton 2012, pers. comm.).

In their emigration phase, anadromous juvenile salmon occupy shallows of estuaries and
nearshore zones though timing, duration, and abundance vary throughout the year depending on
species, stock, and life history stage (Groot and Margolis 1991, Quinn 2005).  Nearshore and
estuary habitats act as a physiologic transition zone supporting the smoltification process and
osmoregulatory changes between fresh and saltwater ecotones (Hoar 1976 and 1988, Clarke and
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Hirano 1995, Dickhoff et al. 1997). Some sub-yearling salmon (Northwest stocks) have been
shown to repeatedly move through zones of low and high salinity (Healey 1982, Levings 1994,
Levings and Jamieson 2001).  These habitats and associated processes are integral to the survival
and growth of salmonid (Simenstad et al. 1982, Simenstad 1983, Thorn 1987).

The BBS shelf is important nursery grounds for juvenile Bristol Bay sockeye salmon (Farley et
al. 2009).  Early models of BBS and North Pacific salmon stocks describe migrations and broad
distributions to the south and east in winter and spring, and to the north and west in summer and
fall (French et al. 1975, French et al. 1976, Rogers 1987, Burgner 1991, Shuntov et al. 1993).
These studies were the first to suggest population migrations crossed the Aleutian Island chain
into the North Pacific (Meyers et al. 1996, Myers 2011 pers. comm.). Recent investigations
incorporating genetic (DNA) and  scale pattern analysis validate these observations (Bugaev
2005, Farley et al. 2005, Habicht et al. 2005, Habicht et al. 2007, Myers et al. 2007).
Investigations conducted in the autumn 2008 and winter 2009 substantiate the migration of
juvenile Bristol Bay sockeye salmon from the BBS shelf to the North Pacific, south of the
Aleutian Island chain (Habitch et  al. 2010, Farley et al. 2011,  Seeb et al. 2011):

       "In their first oceanic summer and fall, juveniles are distributed on the eastern Bering Sea
       shelf, and by the following spring immature salmon are distributed across a broad region
       of the central and eastern North Pacific. In their second summer and fall, immature fish
       migrate to the west in a band along the south side of the Aleutian chain and northward
       through the Aleutian passes into the Bering Sea. In subsequent years, immature fish
       migrate between their summer/fall feeding grounds in the Aleutians and Bering Sea and
       their winter habitat in the North Pacific. In their last spring, maturing fish migrate across
       a broad, east-west front from their winter/spring feeding grounds in the North Pacific,
       northward through the Aleutian passes into the Bering Sea, and eastward to Bristol  Bay."
       (Farley 2011)

More than 55% of ocean age-1 sockeye salmon sampled during those winter surveys in the North
Pacific came from Bristol Bay stocks. These broad seasonal shifts in distribution likely reflect
both genetic adaptations and behavioral responses to environmental cues (e.g., prey availability
and water temperature) that are mediated by bioenergetic constraints (Farley et al. 2011).

Salmon Contribution to Trophic Levels

A recent evaluation was conducted by the NOAA-AFSC Ecosystem Modeling Team to assess
the contribution of the Nushagak and Kvichak River sockeye salmon to trophic dynamics in the
BBS shelf and North Pacific ecosystems (Gaichas and Aydin 2010).  This evaluation provides
additional insight into the role and contribution of outbound salmon  smolt to Bristol Bay and
BBS trophic interactions.  Using estimates of outbound salmon smolt survival and adult returns,
researchers found that these two rivers account for nearly 70% (56,000 of 81,100 tons) of adult
salmon biomass in the BBS. Depending on environmental influences and number of out-
migrating and surviving smolt, juvenile sockeye salmon from these two river systems may rank
among the top ten forage groups.  When compared with only single species stock groups, they
rank between fifth and seventh in importance, comparable to Pacific herring or eulachon. In the

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open ocean, sockeye salmon represent 47% of total estimated salmon biomass present in the
eastern subarctic gyre (Aydin et al. 2003).  Bristol Bay sockeye salmon from the Nushagak and
Kvichak River systems comprise 26% of total sockeye salmon biomass, and 12% of total
salmonid biomass in the entire eastern subarctic gyre. The Nushagak and Kvichak River systems
produce a significant portion of all salmon in offshore marine ecosystems and the majority of
salmon on the BBS shelf; these salmon represent the majority of juvenile and returning adult
salmon biomass (Gaichas and Aydin 2010). Results from an unrelated study indicate outbound
salmon smolt may export more nitrogen and phosphorus than adult salmon transported into
watersheds from the ocean (Moore and Schindler 2004).

It is well documented that returning adult salmon subsidize watersheds in the form of salmon
derived or marine-derived nutrients (Gende et al. 2002, Schindler et al. 2003, Wilson et al.
2004). The contribution of out-welling marine-derived nutrients, mass transport of nutrient back
to estuarine processes further expands upon this concept.  Nutrient transport is facilitated in the
form of partial and whole salmon carcasses or particulates and dissolved nutrients (carbon,
nitrogen and phosphorous) moving from watersheds back to estuaries.  Earlier studies identified
the flow of salmon carcasses out of the coastal watersheds into marine estuaries as a result of
high precipitation events (Brickell and Goering 1970, Richey et al.  1975). Salmon-derived
nutrients stimulate primary production in estuaries where nitrogen and phosphorus are often
limiting nutrients (Rice and Ferguson 1975). Estuarine algae use dissolved marine-derived
nutrients, in turn feeding copepods which feed juvenile salmon (Fujiwara and Highsmith 1997).
One investigation identified several species of marine invertebrates feeding on salmon carcasses
(Reimchen 1994). Stationary whole salmon carcasses were completely consumed in a week.
Gende (2004) estimated that 43% of the tagged salmon carcasses washed into the study estuary
within days.  More recent investigations conducted in Alaskan waters estimate that the
contribution of marine-derived nutrients to marine estuarine processes may be as high as 60%, or
two thirds of potential nutrient transported back to the estuary (Johnston et al. 2004, Mitchell and
Lamberti 2005).

In the Nushagak and Kvichak Bays, marine-derived nutrients liberated from tens of millions of
decomposing adult salmon likely have a significant influence on trophic interactions and
biodiversity.  Estuarine processes such as primary and secondary production and countless
marine fish and invertebrate species benefit from this mass transport.  These and a multitude of
similar studies indicate marine and estuarine vegetation, and larval  and juvenile invertebrate and
fish populations benefit from outwelling marine-derived nutrients washed back into estuaries.
Bristol Bay - Marine Mammals

The EBS supports numerous species of marine mammals including whales (Cetacea) of the
suborders Odontoceti (toothed whales and porpoise) and Mysticeti (baleen whales). Several
species of seals (pinnipeds) are also found (Otariidae, Phocidae, and Odobenidae) in these waters
(Allen and Angliss 2010). Of marine mammals present in the EBS, twenty species occur in
Bristol Bay in significant numbers and regularity to be  distinguished in this discussion (Table 2).
Three species of baleen whale (fin, right and humpback whales) and one pinniped species

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(Western DPS Steller sea lion) found in Bristol Bay are recognized by federal or state agencies
as threatened,  endangered, or listed as species of concern.

In Bristol Bay, the presence of marine mammals and prey species varies depending on seasonal
range and migratory patterns.  The variability in seasonal range of sea lions or fur seals, for two
examples, prevents us from accurately identifying annual presence  and feeding habitats.
Because scat and stomach content studies can be conducted only while specimens are on the
rookery, the only prey species represented in dietary analysis are those close to the rookeries.

Some data on marine mammal diets show seasonal dependence on  salmon.  Several studies
demonstrate that salmon are a nutritional source for several marine mammal species (Pauly et al.
1998a). Many marine mammals, especially pinniped and ondontocete species, prey on adult and
juvenile salmon in nearshore zones.

Pinnipeds

Sea lion predation on salmon has been confirmed from scat and stomach content studies, from
which researchers have estimated the level and frequency of consumption (NMFS  1992, Merrick
1995, Merrick et al. 1997, Sinclair and Zeppelin 2002,  Trites and Donnelly 2003, Jemison 2011,
pers. comm.).  Depending on seasonal range and migratory patterns, salmon ranked high as a
selected prey species in Steller sea lion diets (Sinclair and Zeppelin 2002). During the summer,
the endangered western stock  of Steller sea lions relies on salmon, which rank second in
frequency of occurrence in summer diets in all regions between 1990 and 1998 (Sinclair and
Zeppelin 2002). During the winter, the level of salmon in Steller sea lion diets increased due to
out-migrating juvenile Bristol Bay salmon (Sinclair and Zeppelin 2002).

An investigation conducted to determine prey species of northern fur seals in the Pribilof Islands
(Sinclair et al. 2008) found that salmon composed part of the diet of fur seals on St. George and
St. Paul Islands. Pacific salmon (Oncorhynchus spp.) had a mean annual frequency of
occurrence of 14.4%, and 10% in any one year on St. George and St. Paul Islands respectively.
In similar nutrition studies of BBS northern fur seals, salmon rank second among fish in
frequency of occurrence for animals on both Pribilof Islands from late July though September,
1990-2000 (Gudmundson et al. 2006). Another study  indicates that salmon constitute a portion
of fur seal diets throughout the Pacific, from California to the species' western Alaskan range
(Perez and Bigg 1986).

Harbor seals are also found throughout Bristol Bay and the BBS and also prey upon species of
Pacific salmon (Jemison et al. 2000, Small et al. 2003,  Hauser et al. 2008, Allen and Angliss
2010, Jemison 2011, pers. comm.). Lake Illiamna supports one of two recognized fresh water
populations of harbor seals (Smith et al. 1996). This population is defined as relatively small
with maximum aerial counts of hauled-out harbor seals ranging from 137 to 321.  These counts
do not reflect absolute abundance (Mathisen and Cline 1992, Small 2001). Though this
population has colonized Lake Iliamna from Bristol Bay via the Kvichak River, there is no
evidence that populations move to and from the salt water estuary to the fresh water lake
(Mathisen and Kline 1992, Hauser et al. 2008). Current information indicates the Lake Illiamna
population is resident. Harbor seals have also been identified in the Nushagak and Wood River
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systems.  In the Wood River system, Harbor seals are observed in Lake Aleknagik (B. Andrew
2011, pers. comm., Chythlook 2011, pers. comm., Tinker 2011, pers. comm.).  Spotted seals
tagged in both Alaskan and Russian sectors of the Bering Sea showed clear seasonal preference
for nearshore habitat and associated fisheries.  These populations fed mostly on fishes, such as
salmon (Onchorhynchus spp.), saffron cod (Eleginus gracilus), and herring (Burkanov 1989,
Lowery et al. 2000).

Toothed Whales

Beluga whales are abundant in Bristol Bay from spring through fall near the mouths of the
Kvichak, Nushagak, Wood, and Igushik Rivers.  Earlier studies document the importance and
contribution of sockeye salmon in beluga nutrition (Brooks 1955). Lensink (1961) noted that
belugas fare poorly in Bristol Bay when migratory (anadromous) fish are not available.  In
addition to following the general movements of its prey, belugas appear to feed specifically
where its prey species are most concentrated. The frequency of occurrence of salmon species in
beluga stomachs is correlated with the abundance of each species during their respective
migrations (Brooks 1955). Studies conducted by Brooks in the 1950s further indicate that
belugas feed on both juvenile and adult salmon, as well as on several other forage fish and
invertebrate species (Klinkhart 1966).

From 1993 to 2005, the beluga population increased in abundance by 4.8% per year, and while
thresholds of prey abundance needed for belugas to thrive are not fully understood, the larger
size of red salmon runs before and during the period covered by aerial surveys may partially
explain the increased beluga numbers (Lowry et al.  2008). Belugas are well known to travel  up
these rivers in pursuit of salmon. They have been seen feeding on salmon in the Kvichak River
past Levelock to the Igiugig Flats (Cythlook and Coiley 1994, G. Andrew 2011, pers. comm.).
In summer, belugas are routinely observed in the Nushagak River (P. Andrew 2011, pers.
comm.).  In the Wood River system, belugas have been observed in Lake Aleknagik (Fried et al.
1979, B. Andrew, 2011, pers. comm., Tinker 2011,  pers. comm.).

Killer whales also inhabit Bristol Bay waters.  They have been  seen in nearshore waters and
frequent the lower river reaches chasing and preying upon salmon and beluga whales (Frost and
Lowry 1981, Frost et al.  1992, Allen and Angliss 2010, Quakenbush 2011, pers. comm.). In  a
recent observation (July 17, 2002), killer whales displayed cooperative feeding behaviors near
the Nushagak spit.  A pod formed a circle with their tails facing toward the center, fluke  slapping
on the surface of the water. A male killer whale emerged through the center of the circle with a
mouth full of salmon (Tinker 2011,  pers. comm.). In the Nushagak River, killer whales have
been observed chasing both belugas and coho salmon (Cythlook 2011,  pers. comm.). In  late  fall,
in the absence of beluga whales, killer whales pursue late run and fall coho up the Nushagak iver
(P. Andrew 2011, pers. comm.).

Though opportunistic feeders, fish-eating killer whales show an affinity to salmon. The results
of a 14-year study of the diet and feeding habits of killer whales in Prince William Sound
identify two non-associating groups of killer whale, termed resident and transient (Bigg  et al.

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1987). The resident group (fish eaters) appears to prey principally on salmon, preferring coho
(O. kisutch) over other more abundant salmon species (Saulitis et al. 2000). Another distinct
population of Alaskan fish-eating killer whales off the coast of British Columbia moves
seasonally to target salmon populations (Nichol and Shackleton 1996). Field observations of
predation and stomach content analysis of stranded killer whales collected over a 20-year period
document 22 species offish and  1 species of squid that dominated the diet offish-eating resident
killer whales (Ford et al. 1998).  Despite the diversity offish species taken in these studies, fish-
eating resident killer whales showed a clear preference for salmon: 96% offish taken were
salmonids. Of the six salmonid species identified,  by far the most common was Chinook,
representing 65% of the total sample.  The second most common was pink at 17%, followed by
chum (6%), coho (6%), sockeye  (4%), and steelhead (2%) (Ford et al.1998). Though likely a
separate population, Bristol Bay  killer whales are likely to have similar feeding behaviors.

Sperm whales, another species of toothed whales not identified in Bristol Bay waters as defined
in this discussion, have been known to prey upon salmon in the BBS. Though feeding primarily
on mesopelagic squid in the North Pacific, the species has  also been documented as consuming
salmon as well as several other species offish (Tomilin 1967, Kawakami 1980).

Baleen Whales

Investigations of baleen whale feeding habits in the North Pacific and Bering Sea have
documented species such as humpbacks targeting small schooling fish populations, including
salmon among numerous species offish identified  (Nemoto 1959, Tomilin 1967, Kawamura,
1980). More recently, humpback whales have been observed off Cape Constantine in the spring,
presumably feeding on schooling herring and possibly outmigrating  salmon smolts (Cythlook
2011, pers. comm.). In southeast Alaska, humpback whales have been observed preying upon
both wild and hatchery out-bound salmon smolts as well as adult pink salmon (Straley et al.
2010, Straley 2011, pers. comm.). Humpback whales have been shown to exhibit site fidelity to
feeding areas, and return year after year to the same feeding locations (Baker et al.  1987,
Clapham et al. 1997). There is very little interchange between feeding areas (Baker et al.  1986,
Calambokidis et al. 2001, Waite  et al.  1999, Urban et al. 2000).
Discussion

Habitat Condition

Natural hydrology and associated ecosystem processes in the Bristol Bay region remain
functionally intact and in pristine condition, from head water tributaries through marine estuary
and nearshore zones.  This condition and the connectivity and complexity of intact hydrologic
processes are the key habitat attributes accountable for the current abundance and resilience of
all existing fisheries.  The historic sustainability of the region's salmon populations is the key
indicator of this pristine habitat condition.  The current abundance of salmon stocks contribute to
the productivity of the species, the strength of individual stocks and strength of other regional
fisheries at multiple trophic levels. Bristol Bay is identified as EFH for salmon and numerous

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fish and invertebrate species that at some stage in their life histories migrate through, rear, or
spawn in these waters.  As previously noted, these marine estuarine and near shore waters are
"fishery nurseries."

Water

Estuary and nearshore habitat is no longer simply viewed as hard substrate or vegetation.  Water
is recognized as habitat identified as soft substrate on moving convergence zones.  Water
chemistry, trace elements, salinity and temperature gradients all influence habitat condition,
nutrient production, and species abundance. The availability, complexity, and interaction of
water and nutrient sources are fundamental to all trophic levels. Water quality influences
nutrient availability, in turn influencing all trophic levels, interactions, and the fundamental
quality of the habitat.  If foraging and prey opportunities are not available, the quality of the
habitat is significantly diminished.

Bristol Bay resembles other Alaskan estuaries as subarctic and allochthonous in nature.  As
discussed above, the inner Bristol Bay estuary is dominated by terrestrial freshwater runoff from
seasonal snow melt and rains. Turbidity may minimize photosynthetic influence, production,
and associated algal blooms; however, nutrient sources and production are supported in part by
the outwelling discharge of detritus, dissolved organic material, and salmon-derived nutrients or
marine-derived nutrients, as discussed below.  These dissolved organic materials provide an
essential energy source for lower trophic levels supporting abundant assemblages of minute
bacteria and fungi, through larval and adult stages of plankton, invertebrates, juvenile fish and
salmon smolt. The abundance and availability of nutrient sources are essential to the survival of
salmon smolt in their early estuarine and marine phase. Successful smolt survival is reflected
years later in the strength of returning adult runs and escapement.

Estuaries

In the Columbia River, Rich (1920) recognized young Chinook salmon were found throughout
the estuary at various age and size classes throughout the year. Rich concluded that this presence
represented; 1) independent populations whose separate movements and rearing patterns
reflected different environmental conditions across the basin, and 2) increased estuarine
residence time increased growth rates over freshwater cohorts suggesting improved rearing
conditions in the estuary (Bottom 2005). Other studies and associated literature on this  subject
substantiate these conclusions and have increased our understanding of the importance of
estuarine habitat to salmon smolt survival (Healey 1982, Levy 1992, Thorpe 1994, Groot and
Margolis 1998, Quinn 2005, Koski 2009).

As Koski discussed (2009), several studies in Alaska document different life-history strategies
used by Chinook, coho and sockeye juveniles, which reflect increased survival in estuarine
habitat (Murphy et al.  1984, Heifetz et al. 1989, Johnson et al. 1992, Thedinga et al. 1993  and
1998, Koski and Lorenz 1999, Halupka et al. 2003).  Studies identify marine estuaries as an often
preferred habitat choice for coho salmon, providing increased food and growth, expanding their

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nursery area, and increasing the overall production from the watershed. These cited studies and
numerous others suggest that estuaries are important for the early life history phase of Chinook
and sockeye salmon as well.  The high productivity of some estuarine habitats in Alaska allows
expression of an array of life history patterns (Healeyl983). One successful survival strategy
involves a combination of both riverine and estuarine rearing allowing salmon to migrate and
rear in the estuaries for a summer and in some cases return and over winter in rivers (Reimers
1971, Murphy et al.  1984, 1997, Harding 1993, Koski and Lorenz 1999, Miller and Sadro 2003,
M. Wiedmer 2013, pers. comm.). Moving between estuarine and riverine ecotones increases
feeding opportunity, allows smolt to achieve critical size (discussed below), and supports
osmoregulatory change in their early marine phase. The dominant freshwater influence of inner
Bristol Bay facilitates osmoregulatory adjustment prior to exposure to the highly saline marine
phase.

Salmon Food Habits

Brodeur and Pearcy  (1990) published a review that documented prey of all five North Pacific
salmon and ocean phase trout.  Feeding habits vary by species, life stage, region, and seasonal
prey availability; however, prey species repeatedly identified were euphausiids, hyperiids,
amphipods, copepods, pteropods, and chaetognaths. Egg, larval, and juvenile stages of
numerous forage fish, groundfish, and invertebrate species were also identified.  Landingham
and Sturdevant (1997) reported that the prey spectrum for juvenile salmon species was composed
of 30 taxa. The six taxa groups of most importance were calanoid copepods, hyperiid
amphipods, euphausiids, decapods, larval tunicates and fishes. Other studies identify  similar
prey assemblages: euphausiids, hyperiids,  amphipods, copepods, pteropods, chaetognaths, and
polychaetes (Auburn and Ignell 2000, Orsi et al. 2000, Powers et al. 2006, Weikamp and
Sturdevant 2008).

Food habit studies conducted in Cook Inlet and Knik Arm further illustrate the importance of
estuarine invertebrate prey assemblages for smolt (Houghton 1987, Moulton 1997, summarized
in USFWS 2009). These studies analyzed stomach content data and revealed that  salmon smolt
ingest substantial quantities of food during their residency in estuaries.  Salmon smolt tend to be
well  nourished and in some cases demonstrate prolonged estuarine residence time  feeding
extensively on plentiful larval and juvenile invertebrate and fish species. Although these studies
pertain exclusively to Cook Inlet and Knik Arm, the prey species identified in these studies are
also abundant in the Bristol Bay estuary and are discussed and listed in this review (pages 3 and
4, and table 1).

Critical Size

Reliance on abundant prey in the estuary during the early marine phase has been illustrated in the
"critical size" discussion. Earlier studies suggested slower growing salmon smolt  experience
greater size-selective predation (Parker 1968, Willette et al. 1999). Smolt that fail to achieve a
critical threshold size by late spring and early summer fail to survive their first winter (Mahnken
et al.  1982).  Stunted smolt and juveniles suffer protein  energy deficiency and are more likely to

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become prey for other marine species rather than becoming adult predators. Salmon smolt need
to reach a critical size and strength to survive their first year in the open ocean (Beamish 2001
and 2004).  Studies of Bristol Bay salmon in their marine phase in the Eastern Bering Sea
indicate that reduced growth  of some salmon during their first year at sea may lead to substantial
mortality (Moss et al. 2005, Farley et al. 2007).  Greater nutrition and prey availability lead to
larger juvenile salmon which gain a survival advantage over smaller individuals (Farley et al.
2007 and 2011).

Trophic Contribution

Salmon-derived nutrients or marine-derived nutrients subsidize watersheds with organic
nutrients such as carbon, nitrogen, and phosphorus, first in the form of whole carcasses and large
solids and later as dissolved particulates (Willson et al. 1998, Cederholm et al. 1999, Gende et al.
2002, Naiman et al. 2002). Salmon carcasses, which are considerably enriched in stable isotopes
13 Carbon and 15 Nitrogen (513C and 515N), contribute to primary production in freshwater
streams, lakes and estuaries (Stockner 1987, Cederholm et al. 1989 and 2000, Kline et al. 1990
and 1993, Bilby et al. 1996, Wipfli et al. 1998).  As discussed above, terrestrial and aquatic
species, invertebrates and insects through mammals, as well as aquatic and riparian vegetation,
are all influenced by and receive benefit from seasonal pulses of salmon- or marine-derived
nutrients (Reimchen 1994, Wilson and Halupka 1995, Bilby et al.  1996 and 1998, Ben-David et
al. 1997 and 1998, Wipfli et al. 1998, Cederholm et al. 1999, Gende and Wilson 2001, Helfield
and Naiman 2001, Chaloner et al 2002, Chaloner and Wipfli 2002, Darimont and Reimchen
2002, O'Keefe and Edwards 2002, Reimchen et al. 2002 and 2003, Darimont et al. 2003,
Mathewson et al 2003, Johnston et al. 2004, Lessard and Merritt 2006, Moore et al. 2007,
Christie 2008, Christie and Reimchen 2008, Janetski 2009).

Coastal watersheds drain to the ocean and influence marine estuaries (Milliman 2010, Dade
2012).  Stream and riparian productivity can influence downstream estuarine areas through the
transport of terrestrial and freshwater dissolved organic material (Murphy 1984, Jauquet et al.
2003, Jonsson and Jonsson, 2003, Cak 2008).  It is intuitive then to consider the influence and
contribution of salmon- or marine-derived nutrients to the marine estuary production of seasonal
larval and juvenile plankton,  invertebrate and fish species. One early study to suggest the
influence of salmon- or marine-derived nutrients on estuary water chemistry was conducted in
Port Walther, Alaska. Brickell and Goering (1970) found that salmon carcasses in Sashin Creek
were flushed into the estuary  and elevated levels of organic nitrogen. Richey (1975) observed
similar flushing of salmon carcasses into estuaries.  Reimchen (1994) observed entire salmon
carcasses rapidly consumed by several species of estuarine invertebrates.  Gende (2004) reported
that 43% of tagged carcasses  in one watershed washed into the estuary within days. Fujiwara
(1997) presented evidence that dissolved salmon- or marine-derived nutrients fuel estuarine
productivity and associated bacteria and algae, in turn increasing the numbers of harpacticoid
copepods that serve as primary prey for out-bound juvenile salmon.  Recent nutrient mass
transport estimates indicated  "substantial amounts of salmon- or marine-derived nutrients, 46%-
60% depending on elemental  speciation and environmental influences move directly back to the
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estuary" (Mitchell and Lambert! 2005). A similar study suggests marine bivalves in estuaries
also benefit from salmon- or marine-derived nutrients as a nutrition source (Chow 2007).

These studies indicate the influence of salmon- or marine-derived nutrients  on trophic
productivity in marine estuaries.  They also suggest a positive feedback mechanism in salmon
production, given that decomposing adult salmon provide nutrient subsidizing lower trophic
levels and prey species to their out bound prodigy (Fujiwara and Highsmith 1997, Gende et al.
2004). As Aydin explained (2010), "Mysiids, as an inshore zooplankton (appearing in diets
primarily in shallow waters of Bristol Bay) have a nitrogen isotope (515N) level higher than
deepwater forage fish."  This strong nitrogen signal was observed in euphausiid and walleye
pollock inhabiting northern Bristol Bay nearshore waters (page 6). Though this unusually high
nitrogen signal is not fully explained, it may be the result of the seasonal increase of dissolved
organic material  flushed into the estuary by seasonally high freshwater discharge, both entrained
in the current gyre along the northern shore of the inner Bristol Bay. Furthermore, smolt
emigration theoretically exports more nutrient to the estuary than previously recognized.  Salmon
smolt are recognized within the forage fish guild and also contribute later in sub-adult and adult
phases in the Bering Sea and North Pacific.  The seasonal transfer of nutrient and energy in
different forms from terrestrial watersheds to the marine estuary may be represented in this
nutrient signal [nitrogen isotope (515N)].

Summary

Pacific salmon are viewed as a keystone species influencing the condition of terrestrial and
marine ecosystems (Willson and Halupka 1995; Cedarholm et al.1999; Helfield andNaiman
2001; Piccolo et al. 2009). Due to their life history, anadromy, range, and distribution, Bristol
Bay salmon clearly represent a link between fresh water, estuarine, and marine systems.
Seasonal freshwater discharges transport dissolved organic material and salmon- or marine-
derived nutrients to the estuary. This freshwater also provides a buffer to highly saline marine
waters and facilitates osmoregulatory adjustment in smolt. The estuary provides rich foraging
opportunity and rearing environment that support salmon smolt growth and allows smolt to
achieve the size essential for survival in the early marine phase.

At the beginning of their life cycle, emigrating smolt contribute to estuarine and marine
productivity as a forage fish species. At the end of their life cycle, adult salmon provide the
salmon- or marine-derived nutrients that influence nutrient productivity from watersheds
through the estuary. It is suggested these nutrient sources provide a feedback mechanism to their
out bound prodigy fueling lower trophic levels, from minute bacteria and  fungi, through a
multitude of plankton, invertebrate, fish, and marine mammal species.

The Bristol Bay estuary provides EFH for salmon at various life stages as well as countless other
marine species.  The estuary provides a nutrient rich transition zone where salmon smolt can
achieve critical size while acclimating to the marine environment. At an ecosystem level, this
pristine condition and connectivity in natural processes are the key habitat attributes responsible
for the sustainability of salmon populations as well as other regional fisheries.
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Bibliography: By Section

Bristol Bay Marine and Estuarine Processes

Buck, E.H., R.T. Buffler, C.D. Evans, H.W. Searby, F.F. Wright, and the University of Alaska
       Anchorage. 1974. The Bristol Bay Environment. A Background Study of Available
       Knowledge. Prepared for the U.S. Army Corps of Engineers.

Coachman, L.K.  1986. Circulation, water masses, and fluxes on the southeastern Bering Sea
       shelf. Continental Shelf Research 5, 23-108.

Coyle, K. O., and A.I. Pinchuk. 2002. The abundance and distribution of euphausiids and zero
       age pollock on the inner shelf of the southeast Bering Sea near the Inner Front in
       1997-1999. Deep Sea Research II, 49: 6009-6030.

Kachel, N.B., G.L. Hunt Jr., S.A. Salo, J.D. Schumacher, P.J. Stabeno, and T.E. Whitledge.
       2002. Characteristics of the inner front of the southeastern Bering Sea. Deep-Sea
       Research II, this issue (PII:  80967-0645(02)00324-7).

Kachel, N.B. 2011. Research Scientist, University of Washington, Joint Institute for the study of
       the Atmosphere and Ocean  (JISAO). Personal Communication. Discussion regarding the
       influence of Bering Sea ocean currents in inner Bristol Bay.

Kinder, T.H. and L.K. Coachman. 1978. The front overlying the continental slope in the eastern
       Bering Sea. J. Geophys. Res. 83:4551±4559.

Kinder, T.H. and J.D. Schumacher. 1981. Hydrographic structure over the continental shelf
       of the southeastern Bering Sea. In: Hood, D.W., Calder, J.A. (Eds.), The Eastern Bering
       Sea Shelf: Oceanography and Resources, Vol. 1. US Government Printing Office,
       Washington, DC, pp. 31-52.

Ladd, C., G.L. Hunt Jr., C.W. Mordy, S. Salo, and Stabeno, P. 2005. Marine environment
       of the eastern and central Aleutian Islands. Fish. Oceanogr. 14 (Suppl. l):22-38.

Moore, D .G. 1964. Acoustic-Reflection Reconnaissance of Continental  Shelves: Eastern Bering
       and Chukchi Seas. In: Papers in Marine Geology, Shepard Commemorative Volume. R.L.
       Miller, ed. The Macmillan Company, New York; Collier-Macmillan Limited, London.
NOAA. 1987. Bering, Chukchi, and Beaufort Seas: Coastal and Ocean Zones. Strategic
       Assessment: Data Atlas. United States Department of Commerce.
                                           16

-------
Radenbaugh, T. 2011. Assistant Professor Environmental Science. University of Alaska
       Fairbanks, Bristol Bay Campus, Bristol Bay Environmental Science Lab. Personal
       Communication. Discussion regarding recent surveys and data collection in Nushagak
       and Kvichak Bays.

Reed, R.K. and PJ. Stabeno. 1994. Flow along and across the Aleutian Ridge. J. Mar. Res.
       52:639-648.

Schumacher, J.D., T.H. Kinder, DJ.  Pashinski, and R.L. Charnell, 1979. A structural front over
       the continental shelf of the eastern Bering Sea. Journal of Physical Oceanography 9, 79
       87.

Schumacher, J.D. and PJ. Stabeno. 1998. The continental shelf of the Bering Sea. In:  The Sea:
       the Global Coastal Ocean Regional Studies and Synthesis, Vol. XI. A.R. Robinson and
       K.H. Brink (eds). New York: John Wiley and Sons, pp. 869±909.

Sharma, G. D., A.S. Naidu, and D.W. Hood. 1972. A model contemporary graded shelf.
       American Association of Petroleum Geologists Bulletin, 56: 2000-2012.

Smith, K. R. and R.A. McConnaughey. 1999. Surficial sediments of the eastern Bering Sea
       continental shelf: EBSSED database documentation. U.S. Department of Commerce,
       NOAA Technical Memorandum. NMFS-AFSC-104. 41 pp.

Stabeno, P.J., N.A.  Bond, N.B. Kachel, S.A. Salo, and J.D. Schumacher. 2001. On the
       temporal variability of the physical environment over the south-eastern Bering Sea,
       Fisheries Oceanography, 10,  81-98.

Stabeno, PJ. and G.L. Hunt Jr. 2002. Overview of the inner front and southeast Bering Sea
       carrying capacity programs. Deep-Sea Research II, this issue (PII:  S0967
       0645(02)00339-9).

Stabeno, P J., R.K. Reed, and J.M. Napp, 2002. Transport through Unimak Pass, Alaska. Deep
       Sea Res. 1149:5919-5930.

Stabeno, P J., N.B. Kachel, and M.E. Sullivan. 2005. Observations from moorings
       in the Aleutian Passes: temperature, salinity and transport. Fish. Oceanogr. 14
       (Suppl. l):39-54.
Stockwell, D.A., T.E. Whitledge, S.I. Zeeman, K.O. Coyle, J.M. Napp, R.D. Brodeur, A.I.
       Pinchuk, and G.L. Hunt Jr. 2001.  Anomalous conditions in the southeastern Bering Sea,
       1997: nutrients, phytoplankton, and zooplankton. Fisheries Oceanography  10,  99-116.

Straty, R. R.  1977. Current Patterns and Distribution of River Waters in Inner Bristol Bay,
       Alaska. NOAA Technical Report, NMFS SSRF-713. U.S. Dept of Commerce.
                                          17

-------
Straty, R. R. and I. W. Jaenicke. 1980. Estuarine influence of salinity, temperature and food on
      the behavior, growth and dynamics of Bristol Bay sockeye salmon, p. 247-265. In W. J.
      McNeil and D. C. Himsworth (eds.), Salmonid Ecosystems of the North Pacific. Oregon
      State University Press, Corvallis, Oregon.

Thorn, R. M. 1987. The biological importance of Pacific Northwest estuaries. Northwest
      Environmental Journal 3(l):21-42.

United States Geological Survey (USGS). 2011. USGS- GIS Topography Data Sets.
      URL: http://nhd.usgs.gov/wbd data citation.html.  Last accessed on Tuesday, September
      6,2011 at 4:05 PM

Bristol Bay Fish Assemblages

Abookire, A,A., J.F. Piatt, and M.D. Robards. 2000. Nearshore fish distributions in an Alaskan
      estuary in relation to stratification, temperature, and salinity. Estuar Coast Shelf Sci
      50:45-49

Abookire, A.A. and J.F. Piatt. 2005. Oceanographic conditions structure forage fishes into lipid
      rich and lipid-poor communities in lower Cook Inlet, Alaska, USA. Mar Ecol Prog Ser
      287:229-240

Arimitsu, M.L. and J.F. Piatt. 2008. Forage Fish and their Habitats in the Gulf of Alaska and
      Aleutian Islands: Pilot Study to Evaluate Opportunistic Use of the U.S. Fish and Wildlife
      Refuge Support Vessel for Long-term Studies. North Pacific Research Board Final
      Report 630, 42 p.

Aydin, K.Y. 2010. Analysis of fall, winter, and spring predation of key Bering Sea and Gulf of
      Alaska groundfish through food habits and stable isotope analysis. North Pacific
      Research Board Final Report 622, 202 p.

Bailey, K.M., T.J. Quinn, P. Bentzen, and W.S. Grant. 1999. Population structure and dynamics
      of walleye pollock, Theregra chalcogramma. Advances in Mar. Biol. 37:179-255.

Bernard, A.C. 2010. Alaska Peninsula-Aleutian Islands Management Area herring sac roefishery
      management plan, 2010. Alaska Department of Fish and Game, Fishery   Management
      Report No. 10-12, Anchorage.

Chilton, E. A.,  C. E. Armistead, and R. J. Foy. 2011. The 2010 Eastern Bering Sea continental
      shelf bottom trawl survey: Results for commercial crab species. U.S. Dep. Commer.,
      NOAA Tech. Memo. NMFS-AFSC-216, 139 p.

Cooper,  D., J. Duffy-Anderson, B. Norcross, B. Holladay, and P. Stabeno. 2011. Northern rock
      sole (Lepidopsettapolyxystrd) juvenile nursery areas in the eastern Bering Sea in relation
      to hydrography and thermal regimes.

                                           18

-------
Dew, C.B., and R.A. McConnaughey. 2005. Did trawling on the brood stock contribute to the
       collapse of Alaska's king crab? Ecological Applications 15, 919-941.

Gaichas, S., and K. Aydin. 2010. The importance of Bristol Bay salmon in North Pacific Ocean
       ecosystems. Unpublished Report. Resource Ecology and Ecosystem Modeling Program,
       NOAA NMFS Alaska Fisheries Science Center, Seattle, WA 98115. March 1, 2010.

Johnson, S.W., J.F. Thedinga, A.D. Neff, P.M. Harris, M.R. Lindberg, J.M. Maselko, and  S.
       D. Rice. 2010. Fish assemblages in nearshore habitats of Prince William Sound, Alaska.
       Northwest Sci. 84:266-280.

Houghton, J. P. 1987. Forage fish use of inshore habitats north of the Alaska Peninsula. In:
       Proceedings, forage fishes of the southeastern Bering Sea. Anchorage, AK: U.S.
       Department of the Interior, Minerals Management Service.

Isakson, J.S., J.P. Houghton, D. E. Rogers, and S.S. Parker. 1986. Fish use of inshore habitats
       north of the Alaska Peninsula June-September 1984 and June-July 1985. Dames and
       Moore and Univ. Washington, Seattle, WA. Final report to MMS and NOAA. 236 p.

Lanksbury, J.A., Duffy-Anderson, J.T., Busby, M., Stabeno, P.J., and Mier, K.L. 2007.
       Abundance and distribution of northern rock sole (Lepidopsetta polyxystra) larvae in
       relation to oceanographic conditions in the Eastern Bering Sea. Prog. In Oceanogr. 72,
       39-62.

Lauth, R. R. 2010. Results of the 2009 eastern Bering Sea continental shelf bottom trawl survey
       of groundfish  and invertebrate resources. U.S. Dep. Commer., NOAA Tech. Memo.
       NMFS-AFSC-204, 229 p.

Loher,  T., P.S.  Hill, G.A. Harrington, and E. Cassano. 1998. Management of Bristol Bay red
       king crab:  a critical intersections approach to fisheries management. Annu. Rev. Fish. 6
       (3), 169-251.

McConnaughey, R.A. and K.R. Smith. 2000. Associations between flatfish abundance and
       surficial sediments in the eastern Bering Sea. Can. J. Fish. Aquat. Sci. 57, 2410- 2419.

McGurk, M. D. and D.H. Warburton. 1992. Fisheries Oceanography of the Southeast Bering
       Sea: Relationships of growth, dispersion and mortality of sand lance larvae to
       environmental conditions in the Port Moller Estuary. OCS Study MMS 92-0019, U. S.
       Dept. Interior.

Mecklenburg, C.W., T.A. Mecklenburg, and L.K. Thorsteinson, 2002. Fishes of Alaska.
       Bethesda, MD: American Fisheries Society.

Moss, J.H. E. V. Farley Jr., A.M. Feldmann  and J.N. lanelli. 2009. Spatial Distribution,
       Energetic Status, and Food Habits of Eastern Bering Sea Age-0 Walleye
       Pollock, Transactions of the American Fisheries Society, 138:3, 497-505
                                          19

-------
Nichol, D.R. 1998. Annual and between sex variability of yellowfm sole, Pleuronectes asper,
       spring-summer distributions in the eastern Bering Sea. Fish. Bull., U.S. 96: 547-561.

Norcross, B. L. and R.F. Shaw. 1984 Oceanographic and estuarine transport offish eggs and
       larvae: a review. Transactions of the American Fisheries Society 113, 153-165.

Norcross, B.L., B.A. Holladay, and FJ. Muter. 1995. Nursery area characteristics of
       pleuronectids in coastal Alaska, USA. Neth. J. Sea Res. 34 (1-3), 161-175.

Norcross, B.L. and B.A. Holladay. 2005. Feasibility to design and implement a nearshore
      juvenile flatfish survey - Eastern Bering Sea. Final Technical Report to the Cooperative
       Institute for Arctic Research. Award # NA17RJ1224. 42 pp.

Ormseth, O. 2009. Utilization of nearshore habitat by fishes in Nushagak and Togiak Bays.
       NOAA- AFSC/REFM, EFH Status Report for Project 2009-12.

Radenbaugh, T., 2011. Assistant Professor Environmental Science. University of Alaska
       Fairbanks, Bristol Bay Campus, Bristol Bay Environmental Science Lab. Personal
       Communication. Discussion regarding recent surveys and data collection in Nushagak
       and Kvichak Bays.

Radenbaugh, T.  2012. Benthic Faunal Zones of Nushagak Bay, In Press.

Thedinga J.F., S.W. Johnson. A.D. Neff and M.R. Lindeberg. 2008. Fish assemblages in shallow
       nearshore habitats of the Bering Sea. Trans Am Fish Soc 137:1157-1164

Warner, I. M., and P. Shafford. 1981. Forage fish spawning surveys: southern Bering Sea. Pages
       1-64 in Environmental assessment of the Alaskan continental shelf. National Oceanic
       and Atmospheric Administration, Final Report 10, Boulder, Colorado.

Wilderbuer, T.K., A.B. Hollowed, WJ. Ingraham Jr, P.D. Spencer, M.E. Conners, N.A. Bond,
       and G.E. Walters, 2002. Flatfish recruitment response to decadal climatic variability and
       ocean conditions in the eastern Bering Sea. Prog. Oceanogr. 55, 235-247.

Bristol Bay Salmon

Aydin, K.Y., G.A. McFarlane, J.R. King, and B.A. Megrey, 2003. PICES-GLOBEC
       international  program on climate change and carrying capacity. The BASS/MODEL
       report on trophic models of the Subarctic Pacific basin ecosystems. PICES Sci. Rpt. 25,
       1-93.

Brickell, D.C., and JJ. Goering. 1970. Chemical  effects of salmon decomposition on aquatic
       ecosystems. In First international  symposium on water pollution control in 70 cold
       climates. Edited by R.S. Murphy. U.S. Government Printing Office, Washington, D.C.
       pp. 125-138.

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-------
Bugaev, A.V. 2005. Identification of local stocks of sockeye and Chinook salmon by scale
       pattern analysis from trawl catches of R/V "TINRO" worked by program of the Bering-
       Aleutian Salmon International Survey (BASIS) in September-October 2002. N. Pac.
       Anadr. Fish Comm. Tech. Rep. 6: 88-90.

Burgner, R.L. 1991. Life history of sockeye salmon (Oncorhynchus nerka). In Pacific salmon
       life histories. Edited by C. Groot and L. Margolis. UBC Press, Vancouver, pp. 1-117.

Clarke, W. C., and T. Hirano. 1995. Osmoregulation. Pp. 319-377 in C. Groot, L. Margolis, and
       W. C. Clarke, eds. Physiological ecology of Pacific salmon. Univ. of British Columbia
       Press, Vancouver.

Dickhoff, W. W., B. R. Beckman, D. A. Larsen, C. Duan, and S. Moriyama. 1997. The role of
       growth in endocrine regulation of salmon smoltification. Fish Physiology and
       Biochemistry 17:231-236.
Eagleton, M. 2012. Personal Communication. Discussion regarding Essential Fish Habitat
       (EFH), the Magnuson-Stevens Fisheries Conservation and Management Act and the
       Salmon Fisheries Management Plan (Salmon FMP). EFH Coordinator, NOAA Fisheries
       Alaska Region, Habitat Conservation Division, Anchorage Alaska.

Echave, K., M. Eagleton, E. Farley, and J. Orsi. 2011. Refined description of essential  habitat for
       Pacific Salmon within the Alaska Exclusive Economic Zone. In Press. Alaska Fisheries
       Science Center. National Marine Fisheries  Service. National Oceanic and Atmospheric
       Administration. 17109 Pt. Lena Loop Rd. Juneau, AK 99801.

Farley, E.V. Jr, J.M. Murphy, B.W. Wing, J.H. Moss, and A. Middleton. 2005. Distribution,
       migration pathways, and size of western Alaska juvenile salmon along the eastern Bering
       Sea shelf. Alaska Fisheries Research Bulletin 11, 15-26

Farley, E. V., J.M. Murphy, J.H. Moss, A. Feldmann, and L. Eisner. 2009. Marine ecology of
       western Alaska juvenile salmon. In Pacific Salmon: Ecology and Management  of
       Western Alaska's Populations, pp. 307-329. Ed. by C. C. Krueger, and C. E.
       Zimmerman. American Fisheries Society Symposium, 70.

Farley, E.V., A. Starovoytov, S. Naydenko, R. Heintz, C. Guthrie, L. Eisner, and J.R. Guyon.
       2011.  Implications of a warming eastern Bering Sea for Bristol Bay sockeye salmon.
       ICES J. Mar. Sci. (2011) first published online April 13, 2011.

French, R.R., R. Bakkala, and D.F. Sutherland. 1975. Ocean distribution of stocks of Pacific
       salmon, Oncorhynchus spp., and steelhead trout, Salmo gairdnerii, as shown by tagging
       experiments: charts of tag recoveries by Canada, Japan, and the United States, 1956-69.
       National Oceanic and Atmospheric Administration Tech. Rep. NMFS SSRF-689. 89 pp.
                                          21

-------
French, R., H. Bilton, M. Osako, and A. Hartt. 1976. Distribution and origin of sockeye salmon
      (Oncorhynchus nerkd) in offshore waters of the North Pacific Ocean. Int. N. Pac. Fish.
      Comm. Bull. 34. 113 pp.

Fujiwara, M., andR. C. Highsmith. 1997. Harpacticoid copepods: potential link between
      inbound adult salmon and outbound juvenile salmon. Marine Ecology Progress Series
      158:205-216.

Gaichas, S., and K. Aydin. 2010. An Evaluation: The importance of Bristol Bay salmon in
      North Pacific Ocean ecosystems. Resource Ecology and Ecosystem Modeling Program,
      NOAA NMFS Alaska Fisheries Science Center, Seattle, WA 98115. March 1, 2010.

Gende, S.M., R.T. Edwards, M.F. Willson, and M.S. Wipfli. 2002. Pacific salmon in aquatic
      terrestrial  ecosystems. BioScence 52: 917-28

Gende, S.M., T.P. Quinn, M.F. Willson, R. Heitz, and T.M. Scott. 2004. Magnitude and fate of
      salmon-derived nutrients and energy in a coastal stream ecosystem. J. Freshw. Ecol.
      19:149-160.

Groot, C. and L. Margolis. 1991. Pacific Salmon Life Histories. University of British Columbia
      Press.

Habicht, C., N.V. Varnavskaya, T. Azumaya, S. Urawa, R.L. Wilmot, C.M. Guthrie III, and I.E.
      Seeb. 2005. Migration patterns of sockeye salmon in the Bering Sea discerned from stock
      composition estimates offish captured during BASIS studies. N. Pac. Anadr. Fish
      Comm. Tech. Rep. 6: 41-43.

Habicht, C., L. W. Seeb, and J. E. Seeb. 2007. Genetic and ecological divergence defines
      population structure of sockeye salmon populations returning to Bristol Bay, Alaska, and
      provides a tool for admixture analysis. Transactions of the American Fisheries Society
      136(l):82-94.

Habicht C., L.W.  Seeb, K.W. Myers, E. Farley, and I.E. Seeb. 2010. Summer-fall distribution of
      stocks of immature sockeye salmon in the Bering Sea as revealed by single-nucleotide
      polymorphisms (SNPs). Transactions of the American Fisheries Society 139, 1171-1191.

Healey, M. C. 1982. Juvenile Pacific salmon in estuaries:  The life support system. In V. S.
      Kennedy (ed.), Estuarine comparisons, p. 315-341. Academic Press, New York.

Hoar, W. S. 1976. Smolt transformation: evolution, behavior, and physiology. Journal of the
      Fisheries Research Board of Canada 33:1233-1252.

Hoar, W.S. 1988. The physiology of smolting salmonids.  In Fish physiology. Vol. XIB. Edited
      by W.S. Hoar and D.J. Randall. Academic Press, New York. pp. 275-343.
                                          22

-------
Johnston, N.T., E.A. Maclsaac, P.J. Tschaplinski, and KJ. Hall. 2004. Effects of the
       abundance of spawning sockeye salmon (Oncorhynchus nerka) on nutrients and algal
       biomass in forested streams. Canadian Journal of Fisheries and Aquatic Sciences 61:384
       403.

Levings, C.D. 1994. Feeding behaviour of juvenile salmon and significance of habitat during
       estuary and early sea phase. Nordic Journal of Freshwater Research 69:7-16.

Levings, C.D. and G. Jamieson. 2001. Marine and estuarine riparian habitats and their role in
       coastal ecosystems, Pacific region. Canadian Science Advisory Secretariat Research
       Document 2001/109. Ottowa, Canada.

McConnachie, J.L., and E.L. Petticrew. 2006. Tracing organic matter sources in riverine
       suspended sediment: Implications for fine sediment transfers. Geomorphology. 79(1-2):
       13-26.

Mitchell, N. L., and G A. Lamberti. 2005. Responses in dissolved nutrients and epilithon
       abundance to spawning salmon  in  southeast  Alaska streams. Limnology and
       Oceanography 50:217-227.

Moore, J.W., and D.E.  Schindler.2004. Nutrient export from freshwater ecosystems by
       anadromous sockeye salmon (Oncorhynchus nerka). Can. J. Fish. Aquat. Sci. 61(9):
       1582-1589.

Myers, K.W., K.Y. Aydin, R.V. Walker, S. Fowler, and M.L. Dahlberg.  1996. Known ocean
       ranges of stocks of Pacific salmon and steelhead as shown by tagging experiments, 1956
       1995. FRI-UW-9614. Fisheries Research Institute, University of Washington, Seattle.
       225 pp.

Myers, K.W., N.V. Klovach, O.F. Gritsenko, S. Urawa, and T.C. Royer. 2007. Stock-specific
       distributions of Asian and North American salmon in the open ocean, interannual
       changes, and oceanographic conditions. N. Pac. Anadr. Fish Comm. Bull. 4: 159-177.

Myers, K.W. 2011. Personal Communication. Discussion regarding historic and recent
       investigations regarding the known range of Bristol Bay salmon. Fisheries Research
       Biologist, University of Washington,  School of Fisheries,  Seattle Washington.

Quinn, T.P. 2005. Behavior and Ecology of Pacific Salmon and Trout. University of
       Washington Press and the American Fisheries Society.

Reimchen, T.E. 1994. Further studies of black bear and chum salmon in stream and estuary
       habitats at Bag Harbour, Gwaii Haanas. Canadian Parks Service.
                                          23

-------
Rice, T.R., and R.L. Ferguson. 1975. Response of estuarine phytoplankton to of estuarine
       phytoplankton to environmental conditions. In Physiological ecology of estuarine
       organisms. Edited by F.J. Vernberg. University of South Carolina Press, Columbia, South
       Carolina, pp. 1-43.

Richey, I.E., M.A. Perkins, and C.R. Goldman. 1975. Effects of Kokanee salmon (Oncorhynchus
       nerka) decomposition on the ecology of a subalpine stream. Journal of the Fisheries
       Research Board of Canada 32: 8 17-820.

Rogers, D.E. 1987a. Pacific Salmon. In: The Gulf of Alaska. D.W. Hood and S.T. Zimmerman
       (eds) Washington DC: NOAA Dept. Commerce, pp. 461-475.

Schindler, D. A., M. D. Scheuerell, J. W. Moore, S. M.  Gende, 6. B. Francis, and W. J. Palen.
       2003. Pacific salmon and the ecology of coastal ecosystems. Frontiers in Ecology and
       the Environment 1:31-37.

Seeb, L.W., I.E. Seeb,  C. Habicht, E.V. Farley Jr., andF.M. Utter. 2011. Single-nucleotide
       polymorphism genotypes reveal patterns of early juvenile migration of sockeye salmon in
       the eastern Bering Sea. Transactions of the American Fisheries Society 140:734-748.

Shuntov, V.P., V.I. Radchenko, V.V. Lapko, and Yu.N. Poltev. 1993. Distribution of salmon in
       the western Bering Sea and neighboring Pacific  waters. J. Ichthyol. 33(7): 48-62.

Simenstad, C.A., K.L. Fresh, and E.O. Salo. 1982. The role of Puget Sound and Washington
       coastal estuaries in the life history of Pacific Salmon: an unappreciated function.  Pages
       343-364 in V. S. Kennedy, editor. Estuarine Comparisons. Academic Press, New York.

Simenstad, C. A. 1983. The ecology of estuarine channels of the Pacific Northwest coast: A
       community profile. FWS/OBS-83/05. U.S. Fish and Wildlife Service, Olympia,
       Washington. 181pp.

Sugai, S.F., and D.C. Burrell. 1984. Transport of dissolved organic-carbon, nutrients, and trace
       metals from the Wilson and Blossom Rivers to Smeaton Bay, Southeast Alaska. Can. J.
       Fish. Aquat. Sci. 41(1): 180-190.

Thorn, R. M. 1987. The biological importance of Pacific Northwest estuaries. Northwest
       Environmental  Journal 3(l):21-42.

Wilson, M.F., S.M. Gende, and P.A. Bisson. 2004. Anadromous fishes as ecological links
       between ocean, fresh water, and land. In: Food Webs at the Landscape Level (eds Polis,
       G.A., Power, M.E. & Huxel, G.R.). The University of Chicago Press, Chicago, pp. 284
       300.
                                          24

-------
Bristol Bay Marine Mammals

Alaska Department of Fish and Game, 2011, Bristol Bay Critical Habitat Areas Management
      Plan.  Divisions of Habitat and Wildlife Conservation. ADF&G, 333 Raspberry Road,
      Anchorage, Alaska 99518-1599

Allen, B. M., and R. P. Angliss. 2011. Alaska marine mammal stock assessments, 2010. U.S.
      Dep. Commer., NOAA Tech.  Memo. NMFSAFSC-223, 292 p.

Andrew, B. 2011. Personal Communication. Discussion regarding Tradition Knowledge (TK)
      of known marine mammal range and distribution in the Nushagak, Kvichak and Wood
      river systems.

Andrew, G. 2011. Personal Communication. Discussion regarding Tradition Knowledge (TK)
      of known marine mammal range and distribution in the Nushagak, Kvichak and Wood
      river systems.

Andrew, P. 2011. Personal Communication. Discussion regarding Tradition Knowledge (TK)
      of known marine mammal range and distribution in the Nushagak, Kvichak and Wood
      river systems. Representative of the Bristol Bay Native Association?

Baker, C.S., L. Herman, A. Perry, W. Lawton, J.  Straley, A. Wolman, H. Winn, J. Hall, G.
      Kaufman, J. Reinke and J. Ostman. 1986. The migratory movement and population
      structure of humpback whales (Megaptera novaeangliae) in the central and eastern North
      Pacific. Marine Ecology Progress Series 31:105-119.

Baker, C.S., A. Perry, and L.M. Herman. 1987. Reproductive histories of female humpback
      whales Megaptera novaeangliae in the North Pacific. Marine Ecology Progress Series
      41:103-114.

Bigg, M.A., G.M. Ellis, J.K.B. Ford, andK.C.  Balcomb. 1987. Killer whales: a study of their
      identification, genealogy and natural history in British Columbia and Washington State.
      Phantom Press and Publishers, Nanaimo,  British Columbia, Canada.

Bristol Bay Environmental Sensitivity Index (BBESI),  Subarea Contingency Plan, Alaska
      Regional Response Team, Unified Plan Vol II: 2001.

Bristol Bay Coastal Resource Service Area (BB-CRSA), Coastal Management Plan. 2009.
      Prepared by Glenn Gray and Sandy Harbanuk and Associates. Preparation funded by
      National  Oceanic and Atmospheric Administration, and administered by the Alaska
      Department of Natural Resources.
                                         25

-------
Brooks, J.V. 1955. Beluga. Pages 98-106 in: Annual Rep. for 1955. Alaska Dep. Fisheries,
       Juneau, AK.

Burkanov, V.N. 1989. The spotted seal (Phoca larghd) in the waters of Kamchatka and its
       impact on Pacific salmon. Ph.D. thesis, Institute of Evolution, Morphology, and Biology
       of Animals, Moscow.

Calambokidis, I, G.H . Steiger, J.M. Straley, L. M. Herman, S. Cerchio, D. R. Salden, J. Urban
       R., J. K. Jacobson, 0. Von Ziegesar, K. C. Balcomb, C. M. Garbrielle, M. E. Dahlehim, S.
       Uchida, G. Ellis, Y. Miyamura, P. Ladron De Guevara, P., M. Yamaguchi, F. Sato,  S. A.
       Mizroch, L. Schlender, K. Rasmussen,  J. Barlow, and T. J. Quinn. 2001. Movements and
       population structure of humpback whales in the North Pacific. Marine Mammal Science
       17:769 794.

Chythlook, M., P. Coiley. 1994. Subsistence use of Beluga Whale in Bristol Bay by Alaska
       Natives. Technical Paper No. 231. Prepared for National Marine Fisheries  Service by
       Alaska Department of Fish and Game, Division of Subsistence, Juneau Alaska, July
       1994.

Chythlook, D. 2011. Personal Communication.  Discussion regarding Tradition Knowledge
       (TK) of known marine mammal range and distribution in the Nushagak, Kvichak and
       Wood river systems. Tribal IGAP Environmental Program Coordinator, Aleknagik
       Traditional Council, Tribal IGAP Environmental Program  Office

Clapham, P. J., S. Leatherwood, I. Szczepaniak, and R. L. Brownell. 1997. Catches of
       humpback and other whales from shore stations at Moss Landing and Trinidad,
       California, 1919-1926. Marine Mammal Science 13:368-394.

Ford, J.K.B., E.M. Graeme, L.G. Barrett-Lennard, A.B. Morton, R.S. Palm, and K.C. Balcomb
       III, 1998. Dietary specialization in two sympatric populations of killer whales
       (Orcinus Orca) in coastal British Columbia and adjacent waters. Can. J. Zool. 76, 1456
       1471.

Ford, K.B., G.M. Ellis, L.G. Barrett-Lennard, A.B. Morton, R.S. Palm, and K.C. Balcomb.  1998.
       Dietary specialization  in two sympatric populations  of killer whales (Orcinus orca) in
       coastal British Columbia and adjacent waters Canadian Journal of Zoology, 1998,
       76:1456-1471, 10.1139/z98-089

Fried, S.M., J.J. Laner, and S.C. Weston. 1979. Investigation of white whale (Delphinapterus
       leucas) predation upon sockeye salmon (Oncorhynchus nerka) smolts in Nushagak Bay
       and associated rivers:  1979 aeriral reconnaissance surveys. Unpubl. Rep. Project 11-41-6
       340, AK. Dep. of Fish and Game, Dillingham, AK.  15 p.
                                          26

-------
Frost, K. J. and L.F. Lowry. 1981. Foods and trophic relationships of cetaceans in the Bering
       Sea. In The eastern Bering Sea shelf: oceanography and resources, Vol. 2, pp. 825-836.
       Ed. by D. W. Wood and J. A. Calder. University of Washington Press, Seattle.

Frost, KJ. R.B. Russell and L.F. Lowry.  1992. Killer whales, Orcinus orca , in the southeastern
       Bering Sea: Recent sightings and  predation on other marine mammals.  Marine Mammal
       Science. Vol. 8, no. 2, pp. 110-119. 1992.

Gudmundson, C.J., T.K. Zepplin and R.R. Ream. 2006. Appplication of two methods for
       determining diet of northern fur seals (callorhinus ursinus). Fish Bull. 104:445-455.

Hauser, D.D.W.,  C.S. Allen, H.B. Rich and T.P. Quinn. 2008. Resident harbor seals (Phoca
       vitulind) in Iliamna Lake, Alaska: summer diet and partial consumption of adult sockeye
       salmon (Oncorhynchus nerkd). Aquatic Mammals 34: 303-309.

Jemison, L.A., G.W. Pendleton, C.A. Wilson, and RJ. Small. 2006. Long-term trends in harbor
       seal numbers at Tugidak Island and Nanvak Bay, AK. Marine Mammal Science
       22:339-360.

Jemison, L.A. 2011. Personal Communication. Discussion regarding marine mammal range
       distribution and feeding habitats in Bristol Bay and associated watersheds. Alaska
       Department of Fish and Game. Anchorage Alaska.

Kawakami, T. 1980. A review of sperm whale food. Scientific Report of the Whales Research
       Institute 32:199-218.

Kawamura, A. 1980. A review of food of balaenopterid whales. Scientific Report of the Whales
       Research  Institute 32:155-197.

Klinkhart, E.G. 1966. The Beluga Whale in Alaska. Report by the State of Alaska Department
       of Fish and Game. Juneau Alaska.
Lensink, CJ.  1961. Status report: beluga  studies. Alaska Dep. Fish and Game,  Juneau.

Lowry, L.F., V.N. Burkanov,  K.J. Frost, M.A. Simpkins, R. Davis, D.P. DeMaster, R.
       Suydam, and A. Springer. 2000. Habitat use and habitat selection by spotted seals (Phoca
       largha) in the Bering Sea. Canadian Journal of Zoology 78:  1959-1971.

Lowry, L.F., K. J. Frost, K.J., Zerbini, A., DeMaster, D. and R.R. Reeves. 2008. Trend in aerial
       counts of beluga or white whales (Delphinapterus leucas) in Bristol Bay,  Alaska, 1993
       2005. Journal of Cetacean Research and Management 10:201-207.

Mathisen, O.A., and T.C. Kline. 1992. Harbor seals in  Iliamna Lake, Bristol Bay, Alaska (Final
       Report on aerial census in 1991, JCDOS 9203). Fairbanks: Juneau Center for Fisheries
       and Ocean Sciences, University of Alaska-Fairbanks.

                                          27

-------
Merrick, R.L., M.K. Chumbley, and G.V. Byrd. 1997. Diet diversity of Steller sea lions
       (Eumetopias jubatus) and their population decline in Alaska: a potential relationship.
       Can. J. Fish. Aquat. Sci. 54: 1342-1348.

Merrick, R.L. 1995. The relationship of the foraging ecology of Steller sea lions (Eumetopias
      jubatus) to their population decline in Alaska. Ph. D. diss., Univ. Wash., Seattle, 175 p.

National Marine Fisheries Service. 1992. Recovery plan for the Steller sea lion (Eumetopias
      jubatus). Report prepared by the Steller Sea lion Recovery Team for the National Marine
       Fisheries Service, Silver Springs, Md.

Nemoto, T. 1957. Foods of baleen whales in the northern Pacific. Scientific Report of the Whales
       Research Institute 12:33-89.

Nichol, L.M. and Shackleton, D.M. 1996. Seasonal movements and foraging behavior of
       northern resident killer whales (Orcinus orca) in relation to the inshore distribution of
       salmon (Oncorhynchus spp.) in British Columbia. Canadian Journal of Zoology 74:983
       91. [aLR]

Pauly, D., A.W. Trites, E.Capuli, and V.Christensen. 1998a. Diet composition and trophic
       levels of marine mammals. ICES (International Council for the Exploration of the Sea)
       Journal of Marine Science 55:467-481.

Perez, M.A. and M.A. Bigg.  1986. Diet of northern fur seals, Callorhinus ursinus off western
       North America. Fishery Bulletin. Vol. 84, no. 4, pp. 957-971.

Quakenbush, L. 2011. Personal Communication. Discussion regarding marine mammal range
       distribution and feeding habitats in Bristol Bay and associated watersheds. Arctic Marine
       Mammal Program.  Alaska Department of Fish and Game.  Fairbanks Alaska.

Saulitis, E., C. Matkin, L. Barrett-Lennard, K. Heise, and G. Ellis. 2000. Foraging strategies of
       Sympatric Killer Whale (Orcinus Orca) populations in Prince Willaim Sound, Alaska.
       Marine Mammal Science, 16: 94-109.

Sinclair, E.H., and T.K. Zeppelin. 2002. Seasonal And Spatial Differences In Diet In The
       Western Stock Of Steller Sea lions (Eumetopias jubatus). Journal of Mammalogy. Vol.
       83, no. 4, pp. 973-990.

Sinclair, E.H., L.S. Vlietstra, D.S. Johnson, T.K. Zeppelin, G.V. Byrd, A.M. Springer, R.R.
       Ream, G.L. Hunt. 2008. Patterns in prey use among fur seals and seabirds in the Pribilof
       Islands . Deep Sea Research II, Vol 55 16-17, pi897-1918.

Small, R.J.  2001. Aerial  Survey of Harbor Seals in Southern Bristol Bay, Alaska, 1998-1999.
       In Harbor Seal Investigations in Alaska,  Alaska Department of Fish and Game,
       Anchorage.

                                           28

-------
Small, R.J., G.W. Pendleton, and K.W. Pitcher. 2003. Trends in Abundance of Alaska Harbor
       Seals, 1983-2001. Marine Mammal Science 19(2):344-362.

Smith, R. J., K.S. Hobson, H.N. Koopman, and D.M. Lavigne. 1996. Distinguishing between
       populations of freshwater and saltwater harbor seals (Phoca vitulind) using stable-isotope
       ratios and fatty acid profiles. Canadian Journal of Fisheries and Aquatic Sciences, 53,
       272-279.

Straley, J., E. Chenoweth, E. McCauley, T. Sheridan, L. Garrison, J. Moran, H. Riley,    F.
       Thrower, and B. Contag. 2010. Preliminary investigations of humpback whale
       predation at salmon enhancement facilities on eastern Baranof Island, southeastern
       Alaska, April to June 2010. University of Alaska Southeast, 1332 Seward Ave, Sitka,
       AK 99835

Straley, J. 2011. Personal Communication. Discussion regarding humpback whale food
       habitats. University of Alaska, Southeast.

Tinker, T. 2011. Personal Communication. Discussion regarding Tradition Knowledge (TK)
       of known marine mammal range and distribution in the Nushagak, Kvichak and Wood
       river systems. Tribal IGAP Environmental Program, Aleknagik Traditional Council
       Tribal IGAP Environmental Program Office.

Tomilin, A.G. 1967. Mammals of the USSR and adjacent countries. Vol. 9, Cetacea. Israel
       Program Scientific Translation No. 124, NTIS TT 65-50086. 717 pp.

Trites, A.W. and C.P. Donnelly. 2003. The decline of Steller sea lions Eumetopias jubatus in
       Alaska: a review of the nutritional stress hypothesis. Mammal Review, 33, 3-28.

Waite, J.M., M.E. Dahlheim, R.C. Hobbs, S.A. Mizroch, O. von Ziegesar-Matkin, L.M.
       Herman and J. Jacobsen. 1999. Evidence of a feeding aggregation of humpback whales
       (Megaptera novaeangliae) around Kodiak Island, Alaska. Marine Mammal Science
       15:210-220.

Urban R., J., A. Jarmill, L. Aguayo, P. Ladron de Guevara, M. Salinas, C. Alvarez, L. Medrano,
       J.K. Jacobsen, K.C. Balcomb, D.E. Claridge, J. Calambokidis, G.H. Steiger, J. M.
       Straley, O. von Ziegesar, J. M. Waite, S. Mizroch, M. E. Dahlheim, J. D. Darling and C.
       S. Baker. 2000. Migratory destinations of humpback whales wintering in the Mexican
       Pacific. Journal of Cetacean Research and Management 2:101-110.

Discussion

Auburn, M.E., and S.E. Ignell. 2000. Food habits of juvenile salmon in the Gulf of Alaska July
       August 1996. N. Pac. Anadr. Fish Comm. Bull.  2: 89-97.
                                          29

-------
Aydin, K.Y. 2010. Analysis of fall, winter, and spring predation of key Bering Sea and Gulf of
       Alaska groundfish through food habits and stable isotope analysis. North Pacific
       Research Board Final Report 622, 202 p.

Beamish, R. J., and C. Mahnken. 2001. A critical size and period hypothesis to explain natural
       regulation of salmon abundance and the linkage to climate and climate change. Prog.
       Oceanogr.  49:423-437.

Beamish, R. J., C. Mahnken, and C. M. Neville. 2004. Evidence that reduced early marine
       growth is associated with lower marine survival of coho salmon. Trans. Am. Fish. Soc.
       133:26-33.

Ben-David, M.,  R. W. Flynn, and D. M. Schell. 1997. Annual and seasonal changes in the diet of
       martens: evidence from stable isotope analysis. Oecologia 111:280-291.

Ben-David, M.,  Hanley, T.  A. and Schell, D. M.  1998. Fertilization of terrestrial vegetation by
       spawning Pacific salmon: the role of flooding and predator activity. !/ Oikos 83: 471/55.

Bilby RE, Fransen BR, Bisson PA (1996) Incorporation of nitrogen and carbon from spawning
       coho salmon into the trophic system of small streams: evidence from stable isotopes. Can
       J Fish Aquat Sci 53:164-173

Bilby, R. A., B.  R. Fransen, P. A. Bisson, and J. K. Walter. 1998. Response of juvenile coho
       salmon (Oncorhynchus kisutch) and steelhead (Oncorhynchus mykiss) to the addition of
       salmon carcasses to two streams in southwestern Washington, USA. Canadian Journal of
       Fisheries and Aquatic Sciences 55:1909-1918.

Bottom, D.L., C.A. Simenstad, J. Burke, A.M. Baptista, D.A. Jay, K.K. Jones, E. Casillas, and
       M.H. Schiewe. 2005.  Salmon at river's end: the role of the estuary in the decline and
       recovery of Columbia River salmon. U.S. Dept. Commer., NOAA Tech. Memo. NMFS
       NWFSC-68, 246 p.

Brickell, D. C., and J. J. Goering. 1970. Chemical effects of salmon decomposition on aquatic
       ecosystems. Pages 125-138 in R. S. Murphy, ed. First International Symposium on Water
       Pollution in Cold Climates. U.S. Government Printing Office,Washington, DC.

Brodeur, R. D.,  and W. G. Pearcy. 1990. Trophic relations of juvenile Pacific salmon off the
       Oregon and Washington coast. U.S. National Marine Fisheries Service Bulletin 88:617
       636.

Cak A.D., Chaloner D.T. & Lamberti G. A. (2008) Effects of spawning salmon on dissolved
       nutrients and epilithon in coupled stream-estuary systems of southeastern Alaska.
       Aquatic  Sciences, 70, 169-178.
                                          30

-------
Cederholm, C.J., Houston, D.B., Cole, D.L., and Scarlett, WJ. 1989. Fate of coho salmon
       (Oncorhynchus-kisutch) carcasses in spawning rivers. Can. J. Fish. Aquat. Sci. 46(8):
       1347-1355.

Cederholm, C. J., M. D. Kunze, T. Murota, and A. Sibatani.  1999. Pacific salmon carcasses:
       essential contributions of nutrients and energy for aquatic and terrestrial ecosystems.
       Fisheries 24( 10):6-15.

Chaloner D.T. & Wipfli M.S. (2002) Influence of decomposing Pacific salmon carcasses on
       macroinvertebrate growth and standing stock in southeastern Alaska streams. Journal of
       the North American Benthological Society, 21, 430-442.

Chaloner, D.T., Martin, K.M., Wipfli, M.S., Ostrom, P.H., and Lamberti, G.A. (2002) Marine
       carbon and nitrogen in southeastern Alaska river food webs: Evidence from artificial and
       natural rivers. Can. J. Fish. Aquat. Sci. 59(8): 1257-1265.

Chow, J. K. 2007. Nutrient linkages between freshwater and marine ecosystems: uptake of
       salmon-derived nutrients in estuaries. Masters Thesis, University of Victoria, Victoria,
       Canada.

Christie, K. S. and Reimchen, T. E. 2008. Presence of salmon increases passerine density on
       Pacific north-west streams. Auk 125:  5159.

Christie, K. S. 2008. Tracking salmon nutrients in riparian food webs: isotopic evidence in
       a ground-foraging passerine. Can. J. Zool. 86: 13171323.

Bade, W. B. 2012. Transport of fluvial sediment supply to the sea.  Water Resources Research,
       48(11).

Darimont, C.T. & Reimchen, T.E. (2002) Intra-hair stable isotope analysis implies seasonal shift
       to salmon in gray wolf diet. Canadian Journal of Zoology, 80, 1638-1642.

Darimont, C.T., Reimchen, T.E. & Paquet, P.C. (2003) Foraging  behaviour by gray wolves on
       salmon streams in coastal British Columbia. Canadian Journal of Zoology, 81, 349-353.

Farley, E. V. Jr., J. H. Moss, and R. J. Beamish. 2007. A review of the critical size, critical
       period hypothesis for juvenile Pacific salmon. North Pacific Anadromous Fish
       Commission Bulletin 4:311-317.

Farley, E.V., A. Starovoytov, S. Naydenko, R. Heintz, C. Guthrie, L. Eisner, and J.R. Guyon.
       2011.  Implications of a warming eastern Bering Sea for Bristol Bay sockeye salmon.
       ICES J. Mar. Sci. (2011) first published online April  13, 2011.
                                           31

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Fujiwara, M. and R.C. Highsmith. 1997. Harpacticoid copepods: potential link between inbound
       adult salmon and outbound juvenile salmon. Marine Ecology Progress Series 158: 205-2
       16.

Gaichas, S., and K. Aydin. 2010. The importance of Bristol Bay salmon in North Pacific Ocean
       ecosystems. Unpublished Report.  Resource Ecology and Ecosystem Modeling Program,
       NOAA NMFS Alaska Fisheries Science Center, Seattle, WA 98115. March 1, 2010.

Gende SM and Willson ME 2001. Passerine densities in riparian forests of southeast Alaska:
       potential role of anadromous spawning salmon. Condor 103: 624-29.

Gende, S., T. Quinn, and M. Willson. 2001. Consumption choice by bears feeding on salmon.
       Oecologia 127:372-382.

Gende, S.M., Edwards, E.D., Willson, M.F., and Wipfli, M.S. 2002. Pacific salmon in aquatic
       and terrestrial ecosystems. Bioscience, 52(10): 917-928.

Gende, S. M., T. P Quinn, M. E Willson, R. Heintz, and T. M. Scott 2004. Magnitude and fate of
       salmon-derived nutrients and energy in a coastal stream ecosystem. J. Freshw. Ecol. 19:
       149-160.

Groot, C. and L. Margolis. 1991. Pacific Salmon Life Histories. University of British Columbia
       Press.

Halupka, K. C., M. F. Willson, M. D. Bryant, F. H. Everest, and A. J. Gharrett. 2003.
       Conservation of population diversity of Pacific salmon in southeast Alaska. North
       American Journal of Fisheries Management 23:1057-1086.

Harding, R. D. 1993. Abundance, size, habitat utilization,  and intrastream movement of juvenile
       coho salmon in a small southeast Alaska stream. Thesis. University of Alaska Fairbanks,
       Fairbanks, Alaska, USA.

Healey, M.C. 1982. Juvenile Pacific salmon in estuaries: the life support system. In Estuarine
       comparisons. Edited by V.S. Kennedy. Academic Press, New York. pp. 315-341.

Healey, M. C. 1983. Coastwide distribution and ocean migration patterns of stream and ocean
       type Chinook Salmon, Oncorhynchus tshawytscha. Canadian Field-Naturalist 97:427
       433.

Heifetz, J., S. W. Johnson, K V. Koski, and M. L. Murphy. 1989. Migration timing, size, and
       salinity tolerance of sea-type sockeye salmon (Oncorhynchus nerka) in an Alaska estuary.
       Canadian Journal of Fisheries and Aquatic Sciences 46:633-637.

Helfield, J.M. and R.J. Naiman. 2001. Effects of salmon-derived nitrogen on riparian forest
       growth and implications for stream productivity. Ecology 82: 2403-2409.
                                          32

-------
Houghton, J. P. 1987. Forage fish use of inshore habitats north of the Alaska Peninsula. In:
       Proceedings, forage fishes of the southeastern Bering Sea. Anchorage, AK: U.S.
       Department of the Interior, Minerals Management Service.

Hyatt, K. D., D. J. McQueen, K. S.  Shortreed, and D. P. Rankin. 2004. Sockeye salmon
       (Oncorhynchus nerka) nursery lake fertilization: review and summary of results.
       Environmental Reviews 12:133-162.

Kline, T. C., Jr., J. J. Goering, O. A. Mathisen, P. H. Poe, and P. L. Parker. 1990. Recycling of
       elements transported upstream by runs of Pacific salmon: 1.15N and n C evidence in
       Sashin Creek, southeastern Alaska. Canadian Journal of Fisheries and Aquatic Sciences
       47:136-144.

Kline, T. C., J. J. Goering, O. A. Mathisen, P. H. Poe, P. L. Parker, and R. S. Scalan. 1993.
       Recycling of elements transported upstream by runs of Pacific salmon: II. al5I and 613C
       evidence in the Kvichak River watershed, Bristol Bay, southwestern Alaska. Canadian
       Journal of Fisheries and Aquatic Sciences 50:2350-2365.

Koski, K, and M. Lorenz. 1999. Duck Creek watershed management plan. National Oceanic and
       Atmospheric Administration's National  Marine Fisheries Service (NOAA), Auke Bay
       Laboratory, Juneau, Alaska, USA.

Koski, K.V. 2009. The fate of coho salmon nomads: the story of an estuarine-rearing strategy
       promoting resilience. Ecol. Soc. 14(1): 4. Available from
       http://www.ecologvandsocietv.org/voll4/issl/art4/.

Janetski, D. J., D. T. Chaloner, S. D. Tiegsl, AND G. A. Lamberti. 2009. Pacific salmon effects
       on stream ecosystems: a quantitative synthesis. Oecologia (Berlin)  159:583-595.

Jauquet, J., N. Pittman, J. A. Heinis, S. Thompson, N. Tatyama and J. Cederholm, 2003.
       Observations of chum salmon consumption by wildlife and changes in water chemistry at
       Kennedy Creek during 1997 - 2000. In:  J. G. Stockner (ed.), Nutrients in Salmonid
       Ecosystems: Sustaining Production and  Biodiversity. American Fisheries Society,
       Bethesda, MD, pp. 71 - 88.

Johnson, S. W., J. F. Thedinga,  and K V. Koski. 1992. Life history of juvenile ocean-type
       Chinook salmon (Oncorhynchus tshawytscha) in the Situk River, Alaska. Canadian
       Journal of Fisheries and Aquatic Sciences 49:2621-2629.

Johnston, N. T., E. A. Macisaac, P. J. Tschaplinski, and K. J. Hall. 2004. Effects of the
       abundance of spawning sockeye salmon (Oncorhynchus nerka) on nutrients and algal
       biomass in forested streams.  Can. J. Fish. Aquat. Sci. 61: 384-403.
                                          33

-------
Jonsson, B. and N. Jonsson, 2003. Migratory Atlantic salmon as vectors for the transfer of
       energy and nutrients between freshwater and marine environments. Freshwater Biology
       48:21-27.

Landingham, J.H., M.V. Sturdevant, and R.D.  Brodeur. 1998. Feeding habits of Pacific salmon
       in marine waters of southeastern Alaska and northern British Columbia. Fish. Bull. 96:
       285-302.

Lessard, J. L. and Merritt, R. W. 2006. Influence of marine-derived nutrients from spawning
       salmon on aquatic insect communities in southeast Alaskan streams. Oikos 113: 334-343.
Levings, C.D., Colin, K., Raymond, B. 1991. Intertidal habitats used by juvenile Chinook
       salmon (Oncorhynchus tsawytscha) rearing in the North Arm of the Fraser River Estuary.
       Mar. Poll. Bull. 22(1): 20-26.

Levy D, A. Andt. G. Northcote, 1982. Juvenile salmon residency in a marsh area of the Fraser
       River estuary. Canadian Journal of Fisheries and Aquatic Sciences 39:270-276.

Mahnken, C., E. Prentice, W. Waknitz, G. Monan, C. Sims, and J. Williams.  1982. The
       application of recent smoltification research to public hatchery releases: an assessment of
       size/time requirements for Columbia River hatchery coho salmon (Oncorhynchus
       kisutch). Aquaculture 28:251-268.

Mathewson, D. D., M. D. Hocking, and T. E. Reimchen. 2003. Nitrogen uptake in riparian plant
       communities across a sharp ecological  boundary of salmon density. BMC Ecology 3:4
       15.

Miller, B. A., and S. Sadro. 2003.  Residence time and seasonal movements of juvenile coho
       salmon in the ecotone and  lower estuary of Winchester Creek,  South Slough, Oregon.
       Transactions of the American Fisheries Society 132:546-559.

Milliman, J.D., Farnsworth, K.L.,  2010. River Discharge to the Coastal Ocean:  A Global
       Synthesis. Cambridge Univ. Press, Cambridge.

Mitchell, N. L. and G. A. Lamberti, 2005. Responses in dissolved nutrients and epilithon
       abundance to spawning salmon in Southeast Alaska streams. Limnology and
       Oceanography 50: 217 - 227.

Moore, J.W., and D.E. Schindler.2004. Nutrient export from freshwater ecosystems by
       anadromous sockeye salmon (Oncorhynchus nerka). Can. J. Fish. Aquat. Sci. 61(9):
       1582-1589.

Moss, J. H., D. A. Beauchamp, A. D. Cross, K. W. Myers, E. V. Farley, J. M. Murphy, and J. H.
       Helle. 2005. Evidence for size-selective mortality after the first summer of ocean growth
       by pink salmon. Transactions of the American Fisheries Society 134:1313-1322.

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Moulton, L.L. 1997. Early marine residence, growth, and feeding by juvenile salmon in northern
       Cook Inlet. Alaska Fisheries Research Bulletin 4(2): 154-177.

Murphy, M. L.,  1984. Primary production and grazing in freshwater and intertidal reaches of a
       coastal stream, Southeast Alaska. Limnology and Oceanography 29: 805 - 815.


Murphy, M. L.,  J. Heifetz, J. F. Thedinga, S. W. Johnson, and K V. Koski. 1989. Habitat
       utilization by juvenile Pacific salmon (Oncorhynchus) in the glacial Taku River,
       southeast Alaska. Canadian Ecology and Society 14(1):  4
       http://www.ecologvandsocietv.org/voll4/issl/art4/ Journal of Fisheries and Aquatic
       Sciences 46:1677-1685.

Murphy, M. L.,  K V. Koski, J. M. Lorenz, and J. F. Thedinga. 1997. Downstream migrations of
       juvenile  Pacific salmon (Oncorhynchus spp.) in a glacial transboundary river. Canadian
       Journal of Fisheries and Aquatic Sciences 54:2837-2846.

Naiman, R.J., Bilby, R.E., Schindler, D.E., and Helfield, J.M. 2002. Pacific salmon, nutrients,
       and the dynamics of freshwater and riparian ecosystems. Ecosystems. 5(4): 399-417.

O'Keefe, T.C., and Edwards, R.T. 2002. Evidence for hyporheic transfer and removal of marine
       derived nutrients in a sockeye stream in Southwest Alaska. Am. Fish. Soc. Symp. 33: 99
       107.

Orsi, J. A., M. V. Sturdevant, J. M. Murphy, D. G. Mortensen, and B. L. Wing. 2000. Seasonal
       habitat use and early marine ecology of juvenile Pacific  salmon in southeastern Alaska.
       N.  Pac. Anad. Fish Comm. Bull. 2:111-122.

Parker, R. R. 1968. Marine mortality schedules of pink salmon  of the Bella Coola River, Central
       British Columbia. Journal of the Fisheries Research Board of Canada 25:757-794.

Powers, S.P., M.A. Bishop, and G.H. Reeves. 2006. Estuaries as essential fish habitat for
       salmonids: Assessing residence time and habitat use of coho and sockeye salmon in
       Alaska estuaries. North Pacific Research Board Project Final Report 310. 65pp.

Quinn, T.P. 2005. Behavior and Ecology of Pacific Salmon and Trout. University of
       Washington Press and the American Fisheries Society.

Reimchen, T.E.  1992. Mammal and bird utilization of adult salmon in  stream and estuarine
       habitats  at Bag Harbour, Moresby Island. Canadian Parks Service.

Reimchen, T. E. 1994. Further studies of predator and scavenger use of chum salmon in stream
       and estuarine habitats at Bag Harbour, Gwaii Haanas. Technical report prepared for
       Canadian Parks Service. Queen Charlotte City, British Columbia, Canada.
                                          35

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Reimchen, T.E., Mathewson, D., Hocking, M.D., and Moran, J. 2002. Isotopic evidence for
       enrichment of salmon-derived nutrients in vegetation, soil, and insects in riparian zones
       in coastal British Columbia. American Fisheries Society Symposium. XX: 1-12.

Reimchen TE, Mathewson DD, Hocking MD, Moran J, Harris D (2003) Isotopic evidence for
       enrichment of salmon-derived nutrients in vegetation, soil, and insects in riparian zones
       in coastal British Columbia. In: Nutrients in Salmonid Ecosystems: Sustaining
       Production and Biodiversity (ed. Stockner J), pp. 59-69. American Fisheries Society
       Symposium 34, Bethesda.

Reimers, P. E. 1971. The length of residence of juvenile fall Chinook salmon in Sixes River,
       Oregon. Dissertation. Oregon State University, Corvallis, Oregon, USA.

Rich, W.H. 1920. Early history  and seaward migration of Chinook salmon in the Columbia and
       Sacramento rivers. Fish.  Bull. 37:1-74.
Richey, I.E., M.A. Perkins, and C.R. Goldman.  1975. Effects of Kokanee salmon (Oncorhynchus
       nerka) decomposition on  the ecology of a subalpine stream. Journal of the Fisheries
       Research Board of Canada 32: 8 17-820.

Stockner JG, Maclsaac EA (1996) British Columbia lake enrichment programme: two decades of
       habitat enhancement for sockeye salmon. Regul Rivers Res Manag 12:547-561

Stockner, J. G. 1987. Lake fertilization: The enrichment cycle and lake sockeye salmon
       (Oncorhynchus nerka) production. Pages 198-215 in H. D.  Smith, L. Margolis, and C. C
       Wood, editors. Sockeye salmon (Oncorhynchus nerka) population biology and future
       management. Canadian Special Publications Fisheries and Aquatic Sciences.

Stockner, J.G., E. Rydin & P. Hyenstrand. 2000b. Cultural oligotrophication: causes and
       consequences for fisheries resources. Fisheries, 25: 7-14.

Thedinga, J. F., S. W. Johnson, K V. Koski, J. M. Lorenz, and M. L. Murphy. 1993. Potential
       effects of flooding from Russell Fiord on salmonids and habitat in the Situk River,
       Alaska. National Marine Fisheries Service, Alaska Fisheries Science Center Processed
       Report 93-01, Auke Bay Laboratory, Juneau, Alaska, USA.

Thedinga, J. F., S. W. Johnson, and K V. Koski. 1998. Age and marine survival of ocean-type
       Chinook salmon (Oncorhynchus tshawytscha) from the Situk River, Alaska. Alaska
       Fishery Bulletin 5 (2): 143-148.

Thorpe, J.E. 1994. Salmonid fishes and the estuarine environment.  Estuaries, 17: 73-93.

U.S. Fish and Wildlife Service. Conservation Planning Assistance.  2009.  Studies of
       Anadromous Fish in  Knik Arm. A Literature Review.  Prepared by, Prevel-Ramos, A.,
       Brady, J.A., Houghton, J., Dec. 2009.
                                          36

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Weitkamp, L. A., and M. V. Sturdevant. 2008. Food habits and marine survival of juvenile
       Chinook and coho salmon from marine waters of Southeast Alaska. Fisheries
       Oceanography 17:380-395

Wiedmer, M, 2013, Personal Communication. Discussion regarding the movement of coho
       salmon from freshwater tributaries to marine estuaries and retaining to overwinter rearing
       in fresh water in the Bristol Bay region.

Willette, T. M., R. T. Cooney, and K. Hyer. 1999.  Predator foraging mode shifts affecting
       mortality of juvenile fishes during the subartic spring bloom. Can. J. Fish. Aquat. Sci.
       56:364-376.

Willson, M. F., and K. C. Halupka. 1995. Anadromous fish  as keystone species in vertebrate
       communities. Conservation Biology 9:489-497.

Willson, M. F., S. M. Gende, and A. H. Marston. 1998. Fishes and the forest. Bioscience 48:455
       462.

Wipfli, M. S., J. Hudson, and J. Caouette. 1998. Influence of salmon carcasses on stream
       productivity: response of biofilm and benthic macroinvertebrates in southeastern Alaska,
       U.S.A. Canadian Journal of Fisheries and Aquatic Sciences 55:1503-1511.
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                                           Tables
Table 1:  Fish and Invertebrate Species List
Species listed have been identified in the NOAA-AFSC Bering Sea Trawl Surveys between
1982-2010 (Lauth 2010). Caveats: All species found, 1) east of the 162 line, 2) deeper than 15-
20m, 3) seasonality of surveys and species presence do not represent complete species diversity,
4) standardized trawl gear mesh is size selective, juvenile and larval specimens of a species may
not be well represented, 5) salmon species at any life stage may not be well represented due to
seasonality of surveys and migration.
             FISH SPECIES
             Common Name
Scientific Name
             Chinook salmon
             Chum salmon
             Steelhead
Salmonidae
Oncorhynchus tshcnvytscha
Oncorhynchus keta
Oncorhynchus mykiss
             Pacific cod
             Walleye pollock
             Arctic cod
             Saffron cod
Gadidae
Gadus macrocephalus
Theragra chalcogramma
Boreogadus saida
Eleginus gracilis
             Sablefish
Anoplopomatidae
Anoplopoma fimbria
             Eulachon
             Capelin
             Rainbow smelt
             Smelt unident
Osmeridae
Thaleichthys pacificus
Mallotus villosus
Osmerus mordax
Osmeridae
             Pacific herring
Clupeidae
Clupea pallasi
             Pacific sand lance
Ammodytidae
Ammodytes hexapterus
                                             38

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Pacific sandfish
Trick odontidae
Trichodon trichodon
Pacific halibut
Yellowfm sole
Northern rock sole
Rock sole unident.
Flathead sole
Dover sole
Rex sole
Butter sole
Sand sole
Starry flounder
Alaska plaice
Arrowtooth flounder
Kamchatka flounder
Longhead dab
Sanddab unident.
Pleuronectidae
Hippoglossus stenolepis
Limanda aspera
Lepidopsetta polyxystra
Lepidopsetta sp.
Hippoglossoides elassodon
Microstomus pacificus
Glyptocephalus zachims
Isopsetta isolepis
Psettichthys melanostictus
Platichthys stellatus
Pleuronectes quadrituberculatus
Atheresthes stomias
Atheresthes evermanni
Limanda proboscidea
Citharichthys sp.
Northern rockfish
Scorpaenidae
Sebastes polyspinis
Big skate
Bering skate
Starry skate
Alaska skate
Aleutian skate
Rajidae
Raja binoculata
Bathyraja intermpta
Raja stellulata
Bathyraja parmifera
Bathyraja aleutica
Whitespotted greenling
Rock greenling
Kelp greenling
Smooth lumpsucker
Greenling unident.
Hexagrammos
Hexagrammos stelleri
Hexagrammos lagocephalus
Hexagrammos decagrammus
Aptocyclus ventricosus
Hexagrammidae
                                      Psychrolutidae
                                     39

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Sawback poacher
Gray starsnout
Sturgeon poacher
Aleutian alligatorfish
Arctic alligatorfish
Warty poacher
Bering poacher
 Leptagonus frenatus
 Bathyagonus alascanus
 Podothecus accipenserinus
 Aspidophoroides bartoni
 Ulcina olrikii
 Chesnonia vermcosa
 Occella dodecaedron
Wolf-eel
Bering wolffish
 Anarhichadidae
 Anarrhichthys ocellatus
 Anarhichas orientalis
Threaded sculpin
Arctic staghorn sculpin
Armorhead sculpin
Northern sculpin
Sculpin unident.
 Gymnocanthus sp.
 Gymnocanthus pistilliger
 Gymnocanthus tricuspis
 Gymnocanthus galeatus
 Icelinus borealis
 Cottidae
Hookhorn sculpin
Irish lord
Red Irish lord
Yellow Irish lord
 Artediellus sp.
 Artediellus pacificus
 Hemilepidotus sp.
 Hemilepidotus hemilepidotus
 Hemilepidotus jordani
Ribbed sculpin
Brightbelly sculpin
Warty sculpin
Great sculpin
Plain sculpin
 Triglops sp.
 Triglops pingeli
 Microcottus sellaris
 Myoxocephalus verrucosus
 Myoxocephalus polyacanthocephalus
 Myoxocephalus jaok
Pacific staghorn sculpin
Antlered sculpin
Spiny head sculpin
Crested sculpin
Eyeshade sculpin
Sailfin sculpin
 Myoxocephalus sp.
 Leptocottus armatus
 Enophrys diceraus
 Dasycottus setiger
 Blepsias bilobus
 Nautichthys pribilovius
 Nautichthys oculofasciatus
40

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Bigmouth sculpin
Thorny sculpin
Spatulate sculpin
 Hemitriptems bolini
 Icelus spiniger
 Icelus spatula
Variegated snailfish
Snailfish unident.
 Liparis sp.
 Liparis gibbus
 Liparidinae
Daubed shanny
Snake prickleback
Decorated warbonnet
Bearded warbonnet
Polar eelpout
 Stichaeidae
 Lumpenus maculatus
 Lumpenus sagitta
 Chirolophis decoratus
 Chirolophis snyderi
 Lycodes turneri
Giant wrymouth
 Cryptacanth odidae
 Cryptacanthodes giganteus
INVERTEBRATE SPECIES
Common Name
 Scientific Name
Octopus

Common Octopus
Eastern Pacific bobtail
 Octopodidae sp.
 Octopoda
 Rossia pacifica
Crab

Oregon rock crab
Graceful decorator crab
Tanner crab
Circumboreal toad crab
Pacific lyre crab
Snow crab
Hybrid tanner crab
Helmet crab
Hermit crab unident.

Sponge hermit
 Cancer sp.
 Cancer oregonensis
 Oregonia gracilis
 Chionoecetes bairdi
 Hyas coarctatus
 Hyas lyratus
 Chionoecetes opilio
 Chionoecetes hybrid
 Telmessus cheiragonus
 Paguridae
 Pagurus sp.
 Pagums brandti
41

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Aleutian hermit
Splendid hermit
Knobbyhand hermit
Fuzzy hermit crab
Bering hermit
Alaskan hermit
Longfmger hermit
Wideband hermit crab
Hairy hermit crab
Purple hermit
Wrinkled crab

Fuzzy crab
Red king crab
Horsehair crab
 Pagurus aleuticus
 Labidochims splendescens
 Pagurus confragosus
 Pagurus trigonocheirus
 Pagurus beringanus
 Pagurus ochotensis
 Pagurus rathbuni
 Elassochirus tenuimanus
 Pagurus capillatus
 Elassochirus cavimanus
 Dermaturus mandtii
 Hapalogaster sp.
 Hapalogaster grebnitzkii
 Paralithodes camtschaticus
 Erimacrus isenbeckii
Shrimp

Ocean shrimp
Alaskan pink shrimp
Humpy shrimp
Shrimp unident.

Spiny lebbeid

Abyssal crangon
Twospine crangon
Ridged crangon
Sevenspine bay shrimp
Crangonid shrimp unident.

Arctic argid

Sculptured shrimp
Kuro argid
 Pandalus sp.
 Pandalus jordani
 Pandalus eous
 Pandalus goniurus
 Hippolytidae
 Lebbeus sp.
 Lebbeus groenlandicus
 Crangon sp.
 Crangon abyssorum
 Crangon communis
 Crangon dalli
 Crangon septemspinosa
 Crangonidae
 Argis sp.
 Argis dentata
 Sclerocrangon sp.
 Sclerocrangon boreas
 Argis lar
Clams, Mussels, Scallop, Cockles
Northern horse mussel
 Mytilidae sp.
 Modiolus modiolus
42

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Blue mussel
Weathervane scallop
Arctic hiatella
Arctic roughmya

Crisscrossed yoldia
Northern yoldia
Discordant mussel
Boreal astarte
Many-rib cyclocardia

Arctic surfclam

Alaska great-tellin

Bent-nose macoma

Pacific razor
Alaska razor

Softshell clam
Alaska falsej ingle (soft oyster)
Soft shell unident.

Hairy cockle
California cockle

Greenland cockle
Broad cockle
Coral, Soft coral

Sea raspberry

Sea pen (sea whip)
Mytilus sp.
Mytilus edulis
Patinopecten caurinus
Hiatella arctica
Panomya norvegica
Yoldia sp.
Yoldia seminuda
Yoldia hyperborea
Musculus discors
Astarte borealis
Cyclocardia crebricostata
Mactromeris sp.
Mactromeris polynyma
Tellina sp.
Tellina lutea
Macoma sp.
Macoma nasuta
Siliqua sp.
Siliqua patula
Siliqua alta
My asp.
Mya arenaria
Pododesmus macrochisma
Anomiidae
Ciliatum sp.
Clinocardium ciliatum
Clinocardium californiense
Serripes sp.
Serripes groenlandicus
Serripes laperousii
Cyclocardia sp.
Clinocardium sp.
Gersemia sp.
Gersemia rubiformis
Gorgonacea sp.
Pennatulacea
                                     43

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Snail, snails, welk

Aleutian moonsnail
Rusty moonsnail
Pale moonsnail
Great slippersnail
Moonsnail eggs unident

Warped whelk
Pribilof whelk

Lyre whelk
Fat whelk

Helmet whelk


Oregon triton

Rosy tritonia

Angular whelk
Sinuous whelk
Ladder whelk
Polar whelk
Smooth lamellaria

Snail eggs
Snail eggs unident.
 Natica clausa sp.
 Cryptonatica aleutica
 Cryptonatica russa
 Euspira pallida
 Crepidula grandis
 Naticidae eggs
 Voliitopsius sp.
 Pyrulofusus deformis
 Beringius sp.
 Beringius kennicottii
 Beringius beringii
 Neptunea sp.
 Neptunea pribiloffensis
 Neptunea borealis
 Neptunea lyrata
 Neptunea ventricosa
 Neptunea heros
 Clinopegma magnum
 Plicifusus kroyeri
 Neptunea sp.
 Fusitriton oregonensis
 Tritonia sp.
 Tritonia diomedea
 Buccinum sp.
 Buccinum angulosum
 Buccinum plectrum
 Buccinum scalariforme
 Buccinum polare
 Velutina velutina
 Hyas sp.
 Gastropod eggs
 Neptunea sp. eggs
Barnacles

Giant barnacle
Beaked barnacle
Barnacle unident.
 Balanus sp.
 Balanus evermanni
 Balanus rostratus
 Thoracica
44

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Anemone

Sea anemone unident.

Clonal plumose anemone
Gigantic anemone
Mottled anemone
Chevron-tentacled anemone
Tentacle-shedding anemone
Stony coral unident.
Halipteris sp.
Actiniaria
Metridium sp.
Metridium senile
Metridium farcimen (=Metridium
giganteum)
Stomp hia sp.
Urticina sp.
Urticina crassicornis
Cribrinopsis fernaldi
Liponema brevicornis
Scleractinia
Star fish, sea star

Mottled sea star
Giant sea star

Blackspined sea star

Blood sea star
Tumid sea star
Grooved sea star
Rose sea star

Purple-orange sea star
Brittlestarfish unident.
Basketstar
Notched brittlestar
Evasterias sp.
Evasterias troschelii
Evasterias echinosoma
Leptasterias groenlandica
Lethasterias nanimensis
Henricia sp.
Henricia leviuscula
Henricia tumida
Leptasterias polaris
Leptasterias katharinae
Leptasterias arctica
Leptasterias sp.
Crossaster sp.
Crossaster borealis
Crossaster papposus
Asterias sp.
Asterias amurensis
Ophiuroidea
Gorgonocephalus eucnemis
Ophiura sarsi
Sea urchin
                                      Echinacea sp.

                                     45

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Green sea urchin
Sand dollar
 Strongylocentrotus droebachiensis
 Strongylocentrotus sp.
 Strongylocentrotus poly acanthus
 Echinarachnius parma
Sponges

Stone sponge
Clay pipe sponge
Barrel sponge

Sponge
 Stelletta sp.
 Suberitesficus
 Aphrocallistes vastus
 Halichondria panicea
 Suberites sp.
 Porifera
Jelly fish

Jelly Fish
Lion's mane
Chrysaora jellyfish
Jellyfish unident.
Comb jelly unident.
 Amphilaphis sp.
 Chrysaora melanaster
 Cyanea capillata
 Chrysaora sp.
 Scyphozoa
 Ctenophora
Miscellaneous Invertabrate Species
Worm

Giant scale worm
Depressed scale worm
Striped sea leech
Echiuroid worm unident.
Cat worm unident.
Scale worm unident.
Peanut worm unident.
Tube worm unident.
 Polychaeta
 Eunoe nodosa
 Eunoe depressa
 Notostomobdella cyclostoma
 Echiura
 Nephtyidae
 Polynoidae
 Sipuncula
Hydroids

Bryozoans
Feathery bryozoan
 Abietinaria sp.

 Eucratea loricata

46

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Leafy bryozoan

Ribbed bryozoan
Bryozoan unident.
Flustra sermlata
Alcyonidium pedunculatum
Rhamphostomella costata
Bryozoa
Sea Cucumbers

Sea football
Sea cucumber

Foraminiferan unident.
Ascidians
Orange sea glob
Sea pork

Sea grape
Sea clod
Cucumaria sp.
Cucumaria fallax
Holothuroidea
Cucumaria frondosa
Psolus sp.
Foraminifera
Aplidium sp.
Aplidium californicum
Molgula sp.
Molgula grifithsii
Molgula retortiformis
                                    47

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Table 2: Marine Mammals Species List
Marine mammal species listed have been identified from several sources (Allen 2010, ADFG 2010, BBESI
2001, BB-CRSA 2009).
              MARINE MAMMALS
              Common Name
Scientific Name
              Toothed Whales
              Beluga whale
              Killer whale
              Pacific white-sided dolphin
              Harbor porpoise
              Ball's porpoise
              Baird's beaked whale
Cetaceans - Ondontocetes
Delphinapterus leucas
Orcinus orca
Lagenorhynchus obliquidens
Phocoena phocoena
Phocoenoides dalli
Berardius bairdii
              Baleen Whales
Cetaceans - Balenotropha
              Gray whale
              Humpback whale
              Fin whale
              Minke whale
              Bowhead whale

              Sealion
Eschrichtius robustus
Megaptera novaeangliae
Balaenoptera physalus
Balaenoptera acutorostrata
Balaena mysticetus

Pinnipeds - Otariidae
              Steller sea lion (Eastern)
              Northern fur seal (Eastern)
Eumetopias jubatus
Callorhinus ufsinus
              Seals
Pinnipeds - Phocidae
              Harbor seal
              Spotted seal
              Bearded seal
              Ringed seal
              Ribbon seal
Phoca vitulina
Phoca largha
Erignathus barbatus
Pusa hispida
Histriophoca fasciata
                                             Pinnipeds - Odobenidae
              Walrus
Odobenus rosmarus
                                             Mustelidae - Lutrinae
              Northern Sea Otter
Enhydra lutris kenyoni
                                                 48

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DRAFT                                               EPA910-R-12-004Bc
DO NOT CITE OR QUOTE                                 April 2013
                                                    Second External Review Draft
                                                    www.epa.gov/bristolbay
      An Assessment of Potential Mining Impacts on Salmon
                 Ecosystems of Bristol Bay, Alaska


                  Volume 3 of 3 -Appendices E-J


   Appendix G: Foreseeable Environmental Impact of Potential
      Road and Pipeline Development on Water Quality and
       Freshwater Fishery Resources of Bristol Bay, Alaska
                                NOTICE
   THIS DOCUMENT IS AN EXTERNAL REVIEW DRAFT. It has not been formally released by
   the U.S. Environmental Protection Agency and should not be construed to represent Agency
   policy. It is being circulated for comment on its technical accuracy and policy implications.
                      U.S. Environmental Protection Agency
                               Seattle, WA

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                       Appendix G.

       Foreseeable Environmental Impact of
   Potential Road and Pipeline Development on
Water Quality and Freshwater Fishery Resources
                of Bristol Bay, Alaska
                            By
                  Christopher A. Frissell, Ph.D.
                     Pacific Rivers Council
               PMB 219, 48901 Highway 93, Suite A
                      Poison, MT 59860
                     chris@pacificrivers.org
                      phone 406-471-3167

                  Maps and Spatial Analysis by
                       Rebecca Shaftel
                 Alaska Natural Heritage Program
                 University of Alaska Anchorage
                Beatrice McDonald Hall, Suite 106
                    rsshaftel@uaa.alaska.edu
                      Report prepared for
                 University of Alaska Anchorage
             Environment and Natural Resources Institute
               And Alaska Natural Heritage Program
                  Daniel Rinella, Project Leader
                     rinella@uaa.alaska.edu

                         April 2013

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                                  ABSTRACT
While Pacific salmon fishery resources have diminished around the Pacific Rim for more
   than a century, the Bristol Bay region of Alaska supports a globally unique, robust,
productive, and sustainable salmon fishery associated with extremely high quality waters
  and high integrity freshwater ecosystems. The Bristol Bay watershed has seen a bare
   minimum of road development to date. However, State of Alaska long range plans
  envision a future of extensive inter-community transportation routes, including both
 highways and pipelines. Other developments being considered for the area would also
 require an infrastructure of roads and pipelines that would traverse previously roadless
   areas of the Kvichak and Nushagak river drainages. As a plausible example of such
 potential infrastructure, this report uses the 138-km-long access road and four pipelines
 likely to be part of Northern Dynasty Minerals' Pebble Mine, should the company elect
  to pursue development of that prospect. It reviews the known physical and biological
  effects of road and pipeline development on streams, rivers, lakes,  and wetlands. The
    report identifies two key conditions in the Bristol Bay ecosystem that particularly
 contribute to its water quality and biological productivity and resilience: 1) a geologic
  and geomorphic template that provides abundant shallow groundwater resources and
 strong vertical linkage between surface waters and groundwater, across all stream sizes
    and wetland types; and 2) the lack of past industrial disturbance, including road
    development across most of the Bristol Bay watershed. The example Pebble Mine
    transportation corridor would bisect this landscape with the potential to shape the
hydrology, water quality and fish habitat integrity of many of the Kvichak and Nushagak
 river drainages. Drawing from the literature that conceptualizes how to spatially project
  risk-impact footprints from road designs and landscape and stream network data, the
 report maps the spatial  extent of potential harm from construction, operation,  accidents
and accidents response on the Pebble transportation corridor. At least twelve percent  and
    possibly upwards of twenty percent of the road corridor would intersect or closely
   approach known wetlands. More than 30 large streams and rivers known to  support
 spawning salmon would intersect with the proposed transportation corridor, potentially
 affecting between twenty and thirty percent of known spawning populations of sockeye
salmon in the Hiamna Lake system. The eastern half of Iliamna Lake supports the highest
 concentrations of rearing sockeye salmon and would also be very close to the road and
   pipeline corridor. The corridor would also bisect or closely approach more than 70
   streams known to support resident fishes such as Dolly Varden, arctic grayling, and
others.  The report also assesses potential mitigation measures and identifies practices  that
    could potentially reduce the risk of impact to water quality, freshwater ecosystem
     function, and Bristol Bay fishery resources should the corridor be developed.

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I.  INTRODUCTION AND SCOPE OF THIS REPORT

While Pacific salmon fishery resources have diminished around the Pacific Rim to the
point that many populations are managed as endangered or threatened species, the Bristol
Bay region of Alaska supports a globally unique, robust and productive salmon fishery
(Burgner 1991, Schindler et al. 2010). Commercial fishers harvest five Pacific salmon
species in Bristol Bay, including a sockeye salmon landing of over 29 million fish in
2010 (ADFG 2010). Bristol Bay's wild rivers support sport fisheries likely exceeding
90,000 angler days and millions of dollars in related expenditures (Duffield et al. 2007).

Hilborn et al. (2003)  identified key factors sustaining the productivity and resilience of
Bristol Bay, specifically, 1) a highly accountable system of fishery regulation, 2)
favorable ocean conditions in recent years, and 3) a stock complex sustained by variable
production from an abundance and high diversity of freshwater and estuarine habitats.,
Salmon production in different Bristol Bay rivers and lakes, in their current, largely
natural and undeveloped condition, varies independently over time spans of decades.
Despite the local variability, the system  sustains a high  overall fishery production
because at any given  time, a collection of extremely high-quality habitats contributes
extraordinarily high abundance and production of fishes. These same factors (i.e.,
diversity and high quality of interconnected habitats) likely confer to Bristol Bay a degree
of resilience in the face of future climate and environmental change (Hilborn et al. 2003,
Woody  and O'Neal 2010, Schindler et al. 2010).

Although some planners have projected extensive highways and industrial development
in the Bristol Bay region (BBAP 2005), the Pebble Mine is the most likely large-scale
development to be proposed in the near future. Development of the Pebble project would
include  a major 138-km-long access road, pipeline, and electric utility corridor between
the mine site, north of Lake Diamna, and a deepwater port on Cook Inlet, to the east
(Ghaffari et al. 2011) (Figure 1).  This corridor would cross many tributaries of the of the
Kvichak and Nushagak Rivers, including tributaries of Diamna lake, as well as bisecting
numerous wetlands and groundwater-rich areas that connect to and sustain the water
quantity and quality in those fish habitats.

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                           Togiak .Twin Hills
                                   Manokotak  ""U>iUingham
             Koliganek

            NewStuyahok
   Aleknagik    ig^Bk
               Levelock
                                                                          Port Alsworth

                                                                      Nondalton
                                                                      *
                                                                 NeJhale^mna fedroBay ^


                                                                      Kokhanok
                                           Clark's Point
                                                      Naknek
                                    L.
                                                   Egegik
    • ADOT major roads

 	ADNR secondary roads

     Proposed infrastructure corridor

    i Pebble deposit

 0   25  50     100 Kilometers
 i   i   I   i    I
Port Heiden
3"*
Figure 1. Existing roads in the Bristol Bay region, and the proposed routed of the Pebble
   Mine transportation corridor. Mapped by Rebecca Shaftel (Alaska Natural Heritage
   Program, Anchorage) based on data from Alaska Department of Transportation and
                 Alaska Department of Natural Resources (Anchorage).
Through its contractor for this report, NatureServe, U.S. Environmental Protection
Agency charged the author with providing a review of:  1) relevant literature and expert
input on the risks, threats, and stressors to Bristol Bay area water quality and salmon
resources associated with the construction, operation, and maintenance of reasonably
foreseeable roads in the region; and 2) mitigation practices used to abate such impacts,
including both commonly used and available, but uncommonly used practices.

Accordingly, after a brief review of known consequences of road and pipeline
development on streams,  rivers, and lakes, this report will  assess the scope of likely and
possible environmental impacts on the water quality and fishery resources of the Bristol
Bay region from  development of the potential Pebble Mine Transportation Corridor

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II. THE BRISTOL BAY ECOSYSTEM

Bristol Bay is one of the world's few remaining, large virtually roadless near-coastal
regions. There are but a few short segments of state highway and road, and no railroads,
pipelines, or other major industrial transportation infrastructure. Roadways presently link
Iliamna Lake (Pile Bay) to Cook Inlet (tidewater at Williamsport); the Iliamna area
(including Iliamna airport) north to a proposed bridge over the Nondalton River and then
to the village of Nondalton; and two other short road segments from Dillingham to
Aleknagik and Naknek to King (Figure 1). A short road system also connects the village
of Pedro Bay with its nearby airstrip.  Improvements have been proposed by the state of
Alaska for the road between Iliamna and Nondalton, in part to alleviate erosion and
sedimentation.

Glacial landforms dominate much of Bristol Bay's surface geology and geomorphology
and include extensive glacial outwash glacial till mantles on hillslopes, expansive,
interbedded glacial lake deposits, and glacial and periglacial stream deposits (Hamilton
2007). These landforms, and more specifically, the extensive, interconnected surface and
near-surface groundwater systems resulting from them, are one of the two factors that
principally account for Bristol Bay's  high productivity for salmon. (The other key factor
is the dearth of industrial and commercial development in the basin.)

Most available information on fish distribution and abundance in the Bristol Bay region
focuses on large rivers (in part because they can be surveyed from the air, at least for
sockeye salmon).  However, a myriad of smaller streams and wetlands also provide high-
quality habitat for coho salmon, Dolly Varden, rainbow trout, and arctic grayling, as well
as other species including round whitefish, pond smelt, lamprey, slimy sculpin, northern
pike, sticklebacks and burbot (Rinella 2011, personal communication, and  Shaftel 2011,
personal communication).  In the most comprehensive published field inventory, Woody
and O'Neal (2010) reported detection of one or more of these species from 96 percent of
the  108 small waters they sampled in the vicinity of the projected site of Pebble prospect
in the Nushagak and Kvichak River drainages. They summarize:

       Small headwater streams are often assumed not to be important
       salmon producing habitats in Alaska, although collectively they
       produce millions of salmon and determine water flow and
       chemistry of larger rivers. As illustrated by this and numerous
       other studies, headwaters comprise a significant proportion of
       essential spawning  and rearing habitat for salmon and non-salmon
       species all of which are important to subsistence users in the
       region.

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III. ROADS AND PIPELINES PROPOSED OR FORESEEABLE IN BRISTOL BAY

In evaluating the environmental impact of any road, it is important to recognize that the
development of a new road is often only the first step toward industrial or commercial
development of the landscape in general, including the proliferation of additional roads
(Trombulak and Frissell 2000, Angermeier et al. 2004). Additional large-scale landscape
development, facilitated by the initial road, is a reasonably foreseeable impact of road
construction in a roadless area.  Essentially, finance and construction of the initial road
subsidizes future developments that rely on that road to route traffic, particularly when
that initial road  connects to a possible trade hub, such  as a deepwater port. The
environmental impact of the ensuing development can dwarf by orders of magnitude the
direct, local effects of constructing the initial road segment (Angermeier at al. 2004).

That there is some interest in industrialization of Bristol Bay beyond the Pebble Mine is
evident in various State of Alaska sources. The ADNR's Bristol Bay Area Plan from the
(BBAP 2005, citing the ADOT's Southwest Alaska Transportation Plan, November
2002), lays out an ambitious long-range vision for future development of a network of
roads and highways in the Bristol Bay region.  The roads, highways, and related
infrastructure envisioned by the BBAP include "regional transportation corridors" that
would connect Cook Inlet to the area of the Pebble prospect, as well as Aleknagik
(already connected by road to Dillingham), King Salmon, Naknek, Egegik, and Port
Heiden, and finally, to Chignik and Perryville, on the southern Alaska Peninsula. The
State also foresees other "community transportation projects" that involve extensions,
improvements, or new roads within or adjacent to Bristol Bay watershed (Chignik Road
Intertie, King Cove-Cold Bay Connection, Newhalen River Bridge, Iliamna-Nondalton
Road Intertie, and Naknek-South Naknek Bridge and Intertie). The plans also identify
three potential "Trans-Peninsula transportation corridors" (Wide Bay/Ugashik Bay,
Kuiulik Bay/Port Heiden, and Balboa Bay/Herendeen Bay,) routes that could serve for
roads, oil and gas pipelines or other utilities as needed (BBAP 2005, Figure 2.5).

Several other large ore bodies and at least seven different complexes of mineral claims lie
within a roughly concentric 24-km radius around the existing Pebble Prospect,
encompassing a vast swath of the Bristol Bay watershed north of Iliamna Lake (Ghaffari
et al. 2011, The Nature Conservancy 2010). The area spans the headwaters of the
Koktuli, Stuyahok, and Newhalen Rivers, as well as Kaskanak, and both Lower and
Upper Talarik Creeks. There are other large mineral leases farther afield within Bristol
Bay, including tracts north  and west of the Nushagak and Mulchatna Rivers. Although
they are at various stages of exploration, these prospects could yield future mine
proposals, particularly if road and other transportation improvements completed for
Pebble Mine provided a transportation stepping stone to them.
IV. EFFECTS OF ROADS AND PIPELINES ON WATER AND FISH HABITAT

Roads have persistent multifaceted impacts on ecosystems and can strongly affect water
quality and fish habitat.  Several authors have reviewed the suite and scope of

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environmental impacts from roads (e.g., Forman and Alexander 1998, Trombulak and
Frissell 2000, Gucinski et al. 2001) with particular focus on water quality and fish habitat
impacts found in sources such as Furniss et al. (1991), Jones et al. (2000), and
Angermeier et al. (2004). The increasing presence of roads in the developed and
developing world has been identified as a threat to native freshwater species and water
quality alike. Czech et al. (2000), for example, identified roads as a likely contributing
factor in the local extinction and endangerment of 94 taxa across the U.S.

Road construction causes mortality and injury of stationary and slow-moving organisms
both within and adjacent to the construction footprint and alters the physical conditions in
the area, as well (Trombulak and Frissell 2000), often including direct conversion of
habitat to non-habitat within and adjacent to the footprint (Forman 2004).  Behavior
modification depends on species and road size/type. Voluntary modification ranges from
use of the road corridor to avoidance; involuntary modification may result when a road
completely blocks the movement of organisms, resulting in fragmentation or isolation of
populations, often with negative demographic and genetic effects and with potential
consequences as grave as local population or  species extinction and loss of biodiversity
(Forman 2004, Gucinski et al. 2001, Trombulak and Frissell 2000). Truncation offish
migrations  due to passage barriers created by  roads is one example of involuntary
behavioral alterations that compromise survival and productivity. Other behavior
modifications include changes in home range, reproductive success, escape response,
and/or physiological state (Forman and Alexander 1998, Trombulak and Frissell 2000).

Roads can create long-term, local changes in  soil density, temperature, and water content,
light, dust,  and/or surface water levels, and flow, runoff, erosion,  and/or sedimentation
patterns, as well as adding heavy metals, deicing salts, organic molecules, ozone, and
nutrients to roadside environments (Forman 2004, Gucinski et al. 2001, Trombulak and
Frissell 2000, Forman and Deblinger 2000). When delivered to streams, road-derived
pollutants directly and indirectly impact water quality.  The extension of natural stream
networks to integrate eroding road surfaces can cause sustained delivery of fine
sediments that alter bed texture and reduce the permeability of streambed gravels (Furniss
et al. 1995, Wemple et al. 1996, Jones et al. 2000, Angermier et al. 2004).  Increased
loading of fine sediments has been linked to adverse impacts on fish though several, often
co-occurring biological mechanisms, including decreased fry emergence, decreased
juvenile densities, loss of winter carrying capacity, increased predation on fish, and
reduced benthic organism populations and algal production (Newcombe and MacDonald
1991, Newcombe and Jensen 1996, Gucinski  et al. 2001, Angermier et al. 2004, Suttle et
al. 2004, and many others).  In  steeper terrain, roads greatly increase the frequency of
slope failure and debris flow, with the resulting episodic sediment delivery to streams and
rivers (Montgomery  1994, Jones et al. 2000, Gucinski et al. 2001). Roads often promote
the dispersal of exotic species and pathogens  by altering habitats, stressing native species,
and providing  corridors and vehicle transport for seed/organism dispersal (Forman 2004,
Trombulak and Frissell 2000, Gucinski et al.  2001).  So long as they remain accessible
and passable enough to facilitate human use, roads also lead to increased hunting, fishing,
poaching, fish and wildlife harassment, use conflicts, lost soil  productivity, fires,
landscape modifications, and decreased opportunities for solitude (Forman 2004,

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Gucinski et al. 2001, Trombulak and Frissell 2000, Angermeier et al. 2004).  Although
impacts to water and fish are the primary focus of this report, the direct and indirect
impacts of roads on other resources and their use should also be recognized.

While the only certainly effective mitigation to avoid the impacts of roads and pipelines
is to find alternatives that do not require building and using them, it does not appear
geographically or operationally feasible to develop the Pebble mine without a road and
pipeline corridor.
Immediate Effects of Construction versus Long-term Impact of Use and Maintenance

Following Angermeier et al. (2004), the effects of roads are distributed across scales of
space and time in three discernible quanta. The first is the immediate and site-specific
effect from the construction of a new road. Many of these impacts are either transient or
are acute only during and shortly after initial construction. An example is the delivery of
large pulses of sediment to streams during runoff events after placement of fill or maj or
ground disturbance by heavy equipment.  The second quantum is the suite  of effects
caused by sustained operation, maintenance, and/or mere existence of the roadway.
Examples include seasonal runoff of pollutants such as deicing salts into nearby streams,
transport of wind-eroded dust from road surfaces to adjacent areas, chronic delivery of
sediment from erosion of road surfaces, ditches, and cut slopes, and the alteration or
sustained displacement of natural vegetation in the footprint and influence  zone of the
road.  Finally, often the greatest impact of road development is the ancillary
development of the landscape, or change in the pattern of human habitation, resource
extraction, and land and  water use of a region, that the road in some way facilitates.   The
remainder of this report focuses on the first two quanta, while acknowledging that the
third class of impacts is likely the most significant for Bristol Bay.

The hydrologic and biological effects of roads are generally similar in nature for
wetlands, streams, rivers, and lakes. Darnell et al. (1976, see especially pp. 129-136)
identified basic construction activities typically associated with industrial projects,
including roads and pipelines:

       1) Clearing and grubbing;
       2) Disposition of materials;
       3) Excavation;
       4) Sub-grade and slope/cut stabilization, including riprap;
       5) Placement of fill;
       6) Aggregate production;
       7) Paving;
       8) Equipment staging;
       9) Borrow pits;
       10) Landfills (disposal sites of excess excavated material).

The authors summarized the categories of possible or likely impact from such projects
                                         8

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and activities on adjoining aquatic areas as follows:

       1) Loss of natural vegetation;
       2) Loss of topsoil;
       3) Change of water table elevation;
       4) Increased erosion;
       5) Leaching of soil minerals from exposed and eroding soil surfaces;
       6) Fluctuations in streamflow;
       7) Fluctuations in surface water levels;
       8) Increased downstream and upstream flooding;
       9) Increased sediment load;
       10) Increased sedimentation;
       11) Increased turbidity;
       12) Changes in water temperature;
       13) Changes in pH;
       14) Changes in chemical composition of soils and waters;
       15) Leaching of pollutants  from pavement;
       16) Introduction of hydrocarbons to soils and waters;
       17) Addition of heavy metals;
       18) Addition of asbestos fibers (dispersed from industrial or natural sources); and
       19) Increased oxygen demand (caused by organic matter export to and
          accumulation in waterways).

These various alterations interact in complex cause-and-effect chains. Although
recognizing that long-term consequences of these alterations are to a significant degree
dependent on local circumstances, Darnell et al. (1976) nevertheless identified common,
general long-term outcomes that include 1) permanent loss of natural habitat; 2) increased
surface runoff and reduced groundwater flow; 3) channelization or structural
simplification of streams and hydrologic connectivity; and 4) persistent changes in the
chemical composition of water and soil.

Three other categories of impact common to roads have been identified in more recent
literature (Trombulak and Frissell 2000, Forman 2004): 1) disruption of movements of
animals, including fishes and other freshwater species; 2) aerial transport of pollutants via
road dust; and 3) disruption of near-surface groundwater processes, including
interception or re-routing of hyporheic flows, and conversion of subsurface slope
groundwater to surface flows. Because of their potential importance in the Bristol Bay
region, are further described in the following section.
Connectivity and Barriers to Fish Movement

Because roads alter surface drainage, and their stream crossing structures can either by
design or by subsequent alteration by erosion or plugging with debris, roads can form
barriers to the movement of freshwater organisms (Roeloffs et al. 1991, Trombulak and
Frissell 2000, Gucinski et al. 2001.) Barriers to upstream passage into headwater streams

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are most common. Pipelines may or may not have similar effects, depending on their
crossing design and association with access and maintenance roads.

Small headwater streams are the lifeblood of rivers and lakes; they sustain processes and
natural communities that are critically and inextricably linked to water quality, habitat
and ecosystem processes that sustain downstream resources (Lowe and Likens 2005).
The direct dependence of some fish on headwater streams for habitat is just one example
of these linkages. When road crossings block fish passage—as they often do (Harper and
Quigley 2000, Gucinski  et al. 2001, FSSSWP 2008), the isolated population(s)
immediately lose migratory (anadromous or freshwater migrant) species and life history
types. Resident species that remain are also at risk of permanent extirpation because
barriers can hinder their  dispersal and natural recolonization after floods, drought, or
other disturbances.

Bryant et al. (2009) found in southeast Alaska that Dolly Varden char moved upstream
into very small streams primarily in fall, and coastal cutthroat trout primarily in spring.
Both species moved upstream just prior to their spawning season, but during low water
intervals, not during high-runoff events. Wigington et al. (2006) developed clear
quantitative evidence that free access to spawning and early rearing habitat in small
headwater streams is critical for sustaining coho salmon in an Oregon river.  Culverts
and other road crossing structures not designed, constructed, and maintained to provide
free passage of such species can curtail migration, isolate these species from their
spawning and nursery habitats, and fragment populations into small demographic isolates
that are vulnerable to extinction (Hilderbrand and Kirshner 2000, Young et al. 2004).
Drawing inference from  natural long-term isolates of coastal cutthroat trout and Dolly
Varden in Southeast Alaska, Hastings (2005) found that About 5.5 km length of perennial
flow headwater stream habitat supporting a census population size of greater than 2000
adults is required for a high likelihood of long-term population persistence.  Beyond
diminishing potential survival and reproduction, barriers to movement can truncate life
history and genetic diversity of populations, reducing resilience and increasing their
vulnerability to environmental variability and change (Hilborn et al. 2003, Bottom et al.
2009).

The loss of some fish species due to road blockages and other barriers can bring
cascading ecological effects by altering key biological interactions.  For example, the
blockage of anadromous salmon from headwater streams could trigger declines in food
web productivity caused by loss of marine-derived nutrients that originate from carcasses
and gametes of spawning salmon (Bilby et al. 1996, Wipfli and Baxter 2010).
Dust and Its Impact

Previous syntheses of the impacts of roads have not sufficiently addressed the effects of
road dust. Dust results from traffic operating on unpaved roads in dry weather, grinding
and breaking down road materials into fine particles (Reid and Dunne 1984).  The
resulting fines either transport aerially in the dry season or are mobilized by water in the
                                        10

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wet season.  The dust particles may also include trace contaminants including deicing
salts, hydrocarbons, and a variety of industrial substances used in construction or
maintenance, or that are dispersed intentionally or unintentionally by vehicles on the road
(e.g., heavy metals or cyanide from transported mining waste, or asbestos fibers in some
mine and treatment projects).  Especially after initial suspension by vehicle traffic, aerial
transport by wind spreads dust over varying terrain and long distances, meaning that it
can reach surface waters that are otherwise buffered from sediment delivery via aqueous
overland flow. Walker and Everett (1987) evaluated the impacts of road dust generated
in particular from traffic on the Dalton Highway  and Prudhoe Bay Spine Road in
northern Alaska. Dust deposition altered the albedo of snow cover, causing earlier (and
presumably more rapid) snowmelt up to 100 meters from the road margin, as well as
increased depth of thaw in roadside soils. The authors also associated dust with loss of
lichens, sphagnum and other mosses, and a reduction of plant cover (Walker and Everett
1987). Loss of near-roadway vegetation has important implications for water quality, as
that vegetation is a major contributor to filtration of sediment from road runoff.  Hence,
dust deposition not only contributes to stored sediment that will mobilize to surface
waters in wet weather, but can also reduce the capacity of roadside landscapes to filter
that sediment.
Near-Surface Groundwater and Hyporheic Flows

The potential Pebble Mine transportation corridor would have a high frequency of
crossings of streams, wetlands, and areas of shallow groundwater.  These groundwater
systems include extensive hyporheic flow networks that connect surface waters through
shallow, subsurface flow paths.  In the Bristol Bay watershed, they appear to be
especially associated with alluvial, glado-fluvial and glacio-lacustrine deposits, but also
locally with slope-mantling till and other locally porous deposits. Existing research sheds
relatively little light on the crucial subject of the impacts of road development on shallow
groundwater and the connectivity to surface water habitats important to fish. Due to the
apparent large extent and hydrologic importance of sub surface-to-surf ace hydrologic
connectivity to streams, lakes and wetlands in Bristol Bay (e.g., Woody and Higman
2011, Woody and O'Neal 2010), and to the recognized importance of groundwater-fed
habitats for northern latitude fishes  (e.g.,  Cunjak 1996, Power et al.  1999, Malcom et al.
2004), this review pays particular attention to those linkages and how they can be
impacted by roads.

Rudimentary groundwater studies at roads traversing moderate slopes of conifer forest
and muskeg in southeast Alaska (Kahklen and Moll 1999) revealed there could be either
a bulge or a drawdown in groundwater level near the upslope ditch, while immediately
downslope of the road the water table was most often depressed. These effects appeared
for distances between 5 and 10 meters on each side of the road prism. The effect of
observed water table deformation on the downslope flux of groundwater remains
unknown.

The distance to which a road influences subsurface flow paths may be considerably
                                        11

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greater in gently sloping alluvial and glaciolacustrine terrain, typically characterized by
shallower, porous zones of subsurface hyporheic or channeled subsurface flow that roads
can unearth or compact (Jones et al. 2000).  It is well-recognized that management of
roads in such terrain types can be unpredictable and challenging, in part because it is very
difficult to anticipate the extent and nature of disruption to subsurface flow paths, large
volumes of water may be involved, and with low gradients, the effects of water table
deformation can project hundreds of meters from the road itself (Darnell et al. 1976).

The field observations reported by Hamilton (2007} and Woody and O'Neal (2010}
in the Pebble mine area are descriptive of terrain with an abundance of near-surface
groundwater and a high incidence of seeps and springs associated with complex
glaciolacustrine, alluvial, and slope till deposits. The abundance of mapped
wetlands (see main report} further testifies to the pervasiveness of shallow
subsurface flow processes and high connectivity between groundwater and surface
water systems in the areas traversed by the transportation corridor. The
construction and operation of roadways and pipelines can fundamentally alter the
intricate connections between shallow aquifers and surface channels and ponds, leading
to further impacts on surface water hydrology, water quality, and fish habitat (Darnell et
al. 1976, Stanford and Ward 1993, Forman and Alexander 1998, Hancock 2002).  In
wetlands, for example, hydrologic disruptions from roads, by altering hydrology,
mobilizing minerals and stored organic carbon, and exposing soils to new wetting and
drying and leaching regimes, can lead to changes in vegetation,  nutrient and salt
concentrations,  and reduced water quality (e.g., Ehrenfeld and Schneider 1991).
Hyporheic exchange processes may be further altered by changes in sediment supply,
both positive and negative, which alter infiltration, porosity, and exfiltration of
subsurface flow paths, as well as affecting mixing of upwelled and surface water
(Hancock 2002, Kondolf et al. 2002).  Roads can either reduce sediment supply by
blocking downslope or downstream sediment transport or increase sediment supply by
creating a new source of eroded material (e.g., road fills, cuts, landslides), often
exacerbated by  stream diversions that result in more erosive flows (Montgomery 1994).

Ground disturbance and catchment alteration by roads and other land use practices
generally increases erosion and sediment delivery to streams.  In the Bristol Bay region,
many streams and rivers connect, directly or indirectly, to lakes. Of particular regard to
Pebble project is Lake Iliamna, which supports abundant and diverse sockeye salmon and
other species (Schindler et al. 2010). Accelerated sedimentation and accompanying
phosphorus deposition in lakes, as well as mobilization of dissolved and particulate
carbon and nitrogen result from shoreline and catchment disturbance (Birch et al.  1980,
Stendera and Johnson 2006), and these inputs can, in turn, trigger profound changes in
lake trophic status and food webs that could result in harmful effects on production of
sockeye salmon and other lake-dwelling species (Schindler and  Scheurell 2002).
Nutrient delivery from road runoff and other road-related hydrologic alterations differs in
seasonal timing, quantity, and chemical makeup from nutrients delivered to streams and
lakes by anadromous fishes that die after spawning, hence it may have different
ecosystem-level effects. For example, road-associated runoff commonly combines
inputs of carbon, phosphorus, and nitrogen with suspended sediments, and the physical
                                       12

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and light-reducing properties of the sediments can profoundly impact the processing of
those nutrients by microbial films, plants, and filter feeders (Newcombe and Jensen 1996,
Donohue and Molinos 2009).  While the most profound and detectable physical and
biological effects occur in littoral zones and deltas, where sediments and nutrients are
directly delivered (and where sockeye spawning is often concentrated,  [Woody 2007]),
suspended sediment and accelerated nutrient delivery can produce lake-wide effects
(Schindler and Scheurell 2002, Stendera and Johnson 2006, Donohue and Molinos 2009,
Ask et al.  2009). Ultraoligotrophic lakes (nutrient concentrations in both the water
column and lake sediments are extremely low) such as Iliamna can be among the most
vulnerable to major changes in lake status and function in response to increases in
nutrient or sediment inputs (e.g., Ramstack et al. 2004, Bradshaw et al. 2005).
Relationship of Road Density and Roadless Condition to Salmon

Across many studies in North America, higher abundances and more robust populations
of native salmonids typically correlate to areas of relatively low road density or large
roadless blocks (e.g., Baxter et al. 1999, Trombulak and Frissell 2000, Gucinski et al.
2001). One study from Alberta documented that bull trout occur at substantially reduced
abundance when even limited road development (road density of less than one mile per
square mile) occurs in the local catchment, compared to their typical abundance in
roadless areas (Ripley et al. 2005). In Montana, Hitt et al. (2003) found the incidence of
hybridization that threatens the westslope cutthroat trout within its native range increased
with increasing catchment road density. However consistent the correlations, the specific
causal links between roads and harm to fish are complex and manifold, and seldom laid
clear in existing research.

Nevertheless, in light of the already dramatic and widespread influence of roads in North
America (Forman 2000), protection of remaining roadless areas has been identified as a
potentially crucial and fiscally sound  step for effective regional conservation offish and
wildlife (Trombulak and Frissell 2000, Gucinski et al. 2001).
Pipeline Spills

Pipelines have similar environmental effects as roads, with the primary difference being
that pipelines constantly or semi-continuously transport potentially toxic or harmful
materials that are only intermittently transported on roadways. In contrast to vehicle
transport, pipeline transport is often remote from direct oversight by human operators,
putting heavy reliance on remote leak detection.  As a consequence,  accidents with
pipelines can lead to dramatically larger spills than roadway accidents. Beyond pipeline
design, effective leak detection systems and inspection  protocols are crucial for reducing
risk of leaks and spills, particularly in a relatively active seismic zone such as the Pebble
Mine area.  However, in a review of recent pipeline spills in North America, Levy (2009)
finds that existing technology and contemporary practice does not provide firm assurance
against catastrophic spills.
                                        13

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Pipeline crossings of streams are an obvious source of direct channel disturbance and
sediment entry, and as a result they have received considerable study (e.g., Lawrence and
Campbell 1980, Levesque and Dube 2007, Levy 2009).  Pipeline installation can avoid or
reduce direct disturbance to channels by building full-span pipeline bridges over
waterways (at less expense than road bridges), or by boring underneath the streambed.

In addition to the access road, Ghaffari et al. (2011) describes a transportation corridor
(Figure 3) with four pipelines:

    1)  An 8-inch diameter steel pipeline to transport a slurry of copper-molybdenum
       concentrate from the mine site to the port site, with one pump station at the mine
       end of the line and a choke station at the port terminal;
    2)  A 7-inch diameter steel line returning reclaimed filtrate water (remaining after
       extraction of the concentrate) to the mine site, fed from a pump station at the port
       site;
    3)  A 5-inch diameter steel pipeline for pumping diesel fuel from the port site to the
       mine site;
    4)  An 8-inch diameter pipeline for delivering natural gas from the port site to the
       mine site (specifics of design not yet released).

All four lines would be contained in close proximity, for an unspecific portion of the
distance buried about five feet below the ground surface in a common  trench, either
adjacent to or—in steeper terrain—beneath the road surface. The combined lines would
cross streams via either subsurface borings or suspended bridges, apparently with all
pipes encased in a secondary containment pipe, although the specific circumstances that
would  receive  secondary containment and what the containment design would be are not
available.  In the design presented in Ghaffari et al. (2011, p. 336), there would be no
secondary encasement of the pipelines away from stream crossings

Available documents do not discuss the composition or potential toxicity of the mineral
slurry concentrate.  However, it is likely that such a slurry would be toxic to some
organisms and that, due to its concentrated, aqueous form, it would readily transport
downstream or downslope of a spill site, and deposited materials on terrestrial surfaces
could generate leachate that enters groundwater systems.  Projected chemical
composition of the returned slurry filtrate is also not available, but it is likely that this
water would have toxic levels of acidity and/or metals. As for the third line, diesel fuel
has known toxicity, with both acute and chronic effects on fish and other organisms
(Levy 2009 and elsewhere).

Liquefied natural gas, the product that the fourth line would carry, consists primarily of
methane, which dissipates rapidly when released into water or the air, and is considered
non-toxic in those circumstances (Levy 2009).  Large-scale explosions of natural gas
pipelines have occurred as a result of the accumulation of gas from slow leaks. Such an
explosion could pose a major risk of damaging or destroying the other pipelines in the
                                        14

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Pebble Mine corridor, disabling electronic leak detection and severing road access
necessary for emergency shut-offs or repairs. Containing all four pipelines, the primary
access road, and the utility lines in a single narrow corridor, while reducing spatial
footprint impacts like erosion and sedimentation, would also bring the consequence,
albeit a low-probability one, of compounding the risk and potential scope of
environmental impact from a catastrophic event such as a methane explosion.
                                                                   Proposed infrastructure cornd
                                                                   Pebble deposit
 Figure 2. Anticipated location of the road, pipeline, and utility transmission corridor for
  Pebble Mine (Ghaffari et al. 2011, p. 326).  The new road and pipeline corridor would
 connect the Pebble Mine operations with a new seaport on Cook Inlet. Not shown is an
  existing north-south connecting tie road from near Nondalton to the Iliamna area (see
  Figure 1).  The Pebble segment from Cook Inlet west to near Lake Iliamna would be
                reconstructed over an existing lower-standard roadway.
                                        15

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V. IMPACT FOOTPRINT OF THE PROPOSED PEBBLE MINE TRANSPORTATION
CORRIDOR ON WATER AND FISH

The Preliminary Assessment of the Pebble Project produced for Northern Dynasty
Minerals, Ltd. (Ghaffari et al. 2011) included a map and moderately detailed description
of the route of the potential Pebble Mine transportation corridor (see Fig. 2). The
following summary relies on that source for road location, while noting the caveat cited
in the document that the project ultimately proposed may be different.

According to Ghaffari et al. (2011), the proposed access road and pipelines would
provide for the basic infrastructural and transportation needs of the mine and its products
and have a fifty-year design life, consistent with the anticipated operating life of the
mine. The 86-mile corridor would contain an all-weather road with a two-lane, 30-foot
wide gravel driving surface. The road would link with the Iliamna airfield, as well as a
new deepwater port on Cook Inlet, from which ships would transport ore elsewhere for
processing. Northern Dynasty anticipates that the route would require twenty bridges,
ranging from 40 to 600 feet in total span, as well as 1,880 feet of causeway passing over
the upper end of Iliamna Bay and five miles of fill embankment along the shorelines of
Iliamna and Iniskin Bays.

The route of the transportation corridor stays south of the Lake Clark National Park
boundary.  About eighty percent of the potential alignment is on private land held by
Alaska Native Village Corporations and other corporate landowners, with the rest owned
by the State of Alaska (Ghaffari et al.  2011). The route was reportedly selected with
regard to transportation and environmental concern in mind, but also with regard to
avoiding parcels of private land held by individuals (Ghaffari et al.  2011).

The Preliminary Assessment (Pp. 326-328) characterizes the proposed route as amenable
to road and pipeline construction with

   . ...terrain favourable for road development. In general, soils are good to
   excellent; where rock  is encountered, it is fairly competent, useable for
   construction material and amenable to reasonable slope development. The
   numerous stream  crossings appear to  have favourable conditions  for
   abutment foundations.  There are no significant occurrences of permafrost
   or areas of extensive wetlands. Where the  terrain is  challenging, the rock
   or soil conditions are generally favourable. In intertidal areas, subsurface
   conditions appear favourable for placement of rock to create the required
   road embankment

A comparison of the route to National Wetlands Inventory (NWI) data available for the
middle portions indicates that while the proposed route might avoid areas of particularly
extensive wetlands, nevertheless the route intersects or closely approaches a large number
of mapped wetlands (see main report). The route also crosses a great number of mapped
(and likely many more unmapped) tributary streams to Iliamna Lake on its 86-mile
traverse. The Preliminary Assessment does not identify alternative routes that would
                                       16

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avoid or reduce impacts to wetlands, streams or shorelines.  Identifying alternative routes
to accomplish this would be very difficult given the high density of such hydrologic
features.

Summarizing the account of Ghaffari et al. (2011, pp. 327-329), traveling eastward from
the Pebble Mine site, north of Iliamna Lake, the proposed transportation corridor passes
through diverse terrain and climatic zones.  From the mine site, at an elevation of 1,100
feet above mean sea level, the road traverses variably sloping upland terrain over glacial
drift before descending to the Newhalen River valley, 11 kilometers north of Hiamna
Lake. From there, the route crosses variable terrain of dry, open tundra until approaching
Roadhouse Mountain, about 8 kilometers east of the river.  The terrain and climatic
conditions of this western portion of the route are typical of western interior Alaska, with
relatively light precipitation, mild summers and winters with windblown snow.  East of
Roadhouse Mountain, the route parallels the shoreline of Iliamna Lake apparently at a
distance of about five to eight kilometers from the shoreline, spanning a transitional
landscape of increasing snowpack and extensive spruce-hardwood forest cover. Roughly
20 kilometers west of Pedro Bay, the route approaches and occupies the shoreline of
Iliamna Lake, traversing the steep escarpment of Knutson Mountain, an area vulnerable
to avalanches, debris flows, and other high-energy montane processes. After skirting the
face of Knutson Mountain above the lakeshore, the route traverses an extensive outwash
plain northeast of Iliamna Lake, then ascends rugged terrain to cross Iliamna Pass and
wends its way some 32 kilometers through rugged terrain and increasingly warmer and
wetter Maritime climatic conditions until descending to the Iniskin Bay port site on Cook
Inlet.

This report, together with material referenced on wetlands, provides a quantitative
conceptualization of the potential impact footprint of the Pebble Mine transportation
corridor on the following known resources:

       1)  Wetlands  (see main report);
       2)  Anadromous fish-bearing streams (Figures 3a and 3b);
       3)   Sockeye salmon spawning (Figure 4) and rearing (Figure 5) areas in the
          Iliamna Lake system; and
       4)  Resident fish (Dolly Varden, arctic grayling, rainbow trout, three-spine
           stickleback, nine-spine stickleback, northern pike, and slimy sculpin; Figures
          6a, 6b, and 6c).
                                        17

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                     •
   Figure 3a. Anadromous fish-bearing streams (documented to support at least one
species of salmon) crossed by the eastern half of the potential Pebble Mine transportation
     corridor (Chekok Creek east to Y Valley Creek).l Map compiled from Alaska
Department of Fish and Game catalog sources (ADFG 2012, Johnson and Blanche 201 la,
  201 lb)2, supplemented with additional spawner count data (Morstad 2003). Compiled
  data on species present and available estimates of sockeye spawning population size in
                     each stream are provided in Attachment A.
1 Median alignment of the corridor was defined by scanning and geo-referencing the Pebble
transportation corridor route map from Ghaffari etal. (2011. Figure 1.9.2, p.57).

2 Field surveys indicate that ADFG Catalog (Johnson and Blanche 2011a, 2011b) under-
represents the actual extent of salmon spawning (Woody and O'Neal 2010, and Daniel
Rinella, University of Alaska, Anchorage, AK, unpublished data), although these figures do
reflect updates based on recent surveys.
                                       18

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                                                    Anadromous Waters Catalog streams

                                                    National Hydrography Dataset streams
   Figure 3b. Anadromous fish-bearing streams (documented to support at least one
       species of salmon) crossed by the western half of the potential Pebble Mine
  transportation  corridor (Upper Talarik Creek east to Canyon Creek).3  Map compiled
 from Alaska Department of Fish and Game catalog sources (ADFG 2012, Johnson and
  Blanche 201 la, 201 lb)4, supplemented with additional spawner count data (Morstad
 2003).  Compiled data on species present and available estimates of sockeye spawning
                    population size in each stream are provided in
                                  Attachment A.
3 Median alignment of the corridor was defined by scanning and geo-referencing the Pebble
transportation corridor route map from Ghaffari etal. (2011. Figure 1.9.2, p.57).

4 Field surveys indicate that ADFG Catalog (Johnson and Blanche 2011a, 2011b) under-
represents the actual extent of salmon spawning (Woody and O'Neal 2010, and Daniel
Rinella, University of Alaska, Anchorage, AK, unpublished data), although these figures do
reflect updates based on recent surveys.
                                        19

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                                                               Sockeye spawning densities. 1955^2011
                                                                   60-4200
                                                                   4,200 -12200

                                                                 I  12,200-26,000

                                                                 >  26.000-72,800

                                                                 )  72.800-128.312

                                                                   Proposed infrastructure corridor
                                                                 M Pebble deposit
    Figure 4. Pattern in abundance of spawning sockeye salmon in Iliamna Lake and
tributary streams relative to the potential Pebble Mine transportation corridor. A general
 concentration of sockeye spawning is apparent in the northeast portion of Iliamna Lake.
  Spawner density data compiled from Johnson and Blanche (201 la, 201 Ib, as average
             counts collected with varying regularity between 1955-2011).5
5 Morstad (2003) with additional information on sampling locations from Harry Rich
(2011, and University of Washington, Seattle, WA, unpublished data)
                                          20

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                                                             Average fry catch 19b1-i976
                                                               «  0-33

                                                               0  34-128

                                                                 129-330

                                                                 331 - 564
   Figure 5.  Uiamna Lake juvenile sockeye catches in tow-net sampling, 1961-1976,
 relative to the potential Pebble Mine transportation corridor.  High-density rearing sites
 are concentrated in the eastern half of the lake, where the transportation corridor comes
 closest to the lakeshore and intersects with numerous tributaries. Compiled from data
provided by Harry Rich (2011, and University of Washington, Seattle, WA, unpublished
                                      data).6
 Sampling methods for these data are described in Rich (2006).
                                        21

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                                 Freshwater Fish Inventory data points

                                 Anadromous Waters Catalog streams

                                 National Hydrography Dataset streams
   Proposed infrastructure corridor

62  Streams crossed by corridor
 Figure 6a. Resident or nonanadromous fish streams crossed or potentially affected by7
  the eastern one-third of the potential Pebble Mine transportation corridor.  Compiled
 from the Alaska Freshwater Fish Inventory (AFFI) Database (ADFG 2012, Johnson and
 Blanche 201 la and 201 Ib, additional information provided by Joe Buckwalter, ADFG,
 Anchorage, AK, Unpublished data).  Stream names and fish species known present are
                            summarized in Attachment A.
7 Secondary tributaries entering trunk streams downstream of the transportation corridor
are indicated because they could be isolated and freshwater migrant life histories harmed
by spills affecting the trunk stream.

8 Median alignment of the corridor was defined by scanning and geo-referencing the
Pebble transportation corridor route map from Ghaffari et al. (2011).
                                         22

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                                 Freshwater Fish Inventory data points     Proposed infrastructure corridor

                                 Anadromous Waters Catalog streams   62 Streams crossed by corridor

                                 National Hydrography Dataset streams
 Figure 6b. Resident or non-anadromous fish streams crossed or potentially affected by
  the central one-third of the potential Pebble Mine transportation corridor.10 Compiled
 from the Alaska Freshwater Fish Inventory (AFFI) Database (ADFG 2012,  Johnson and
  Blanche 201 la and 201 Ib, additional information provided by Joe Buckwalter, ADFG,
  Anchorage, AK, Unpublished data).  Stream names and fish species known present are
                            summarized in Attachment A.
9 Secondary tributaries entering trunk streams downstream of the transportation corridor
are indicated because they could be isolated and freshwater migrant life histories harmed
by spills affecting the trunk stream.

10 Median alignment of the corridor was defined by scanning and geo-referencing the
Pebble transportation corridor route map from Ghaffari et al. (2011).
                                         23

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                                  Freshwater Fish Inventory data points     Proposed infrastructure corridor

                                 • Anadrornous Waters Catalog streams fc//^] Pebble deposit

                                  National Hydrography Dataset streams 62 Streams crossed by corridor
                                                                               11
 Figure 6c. Resident or non-anadromous streams crossed or potentially affected by   the
                                                         '19°
western one-third of the potential Pebble Mine transportation corridor.   Compiled from
   the Alaska Freshwater Fish Inventory (AFFI) Database (ADFG 2012, Johnson and
 Blanche 201 la and 201 Ib, additional information provided by Joe Buckwalter, ADFG,
 Anchorage, AK, Unpublished data).  Stream names and fish species known present are
                            summarized in Attachment A.
11 Secondary tributaries entering trunks downstream of the transportation corridor are
indicated because they could be isolated and freshwater migrant life histories harmed by
spills affecting the trunk stream.

12 Median alignment of the corridor was defined by scanning and geo-referencing the
Pebble transportation corridor route map from Ghaffari et al. (2011).
                                         24

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Drawing on published conceptualizations that plot the extent of environmental and
ecological influences of roads as a spatial footprint (Forman 2000, Forman and Deblinger
2000, Trombulak and Frissell 2000, Jones et al. 2000), Figures 3a through 6c illustrate
that the potential Pebble transportation corridor could have widespread regional effect on
the aquatic ecosystems that feed Iliamna Lake. Figures 6a, 6b, and 6c identify both
upstream and downstream habitat that is susceptible to loss  or degradation due to
structural failures, spills, sedimentation, or other impacts originating in the transportation
corridor.   Through hydrological dispersion of sediment or toxicants, the maps illustrate
that a large proportion of Iliamna Lake salmon habitat would be vulnerable to indirect
impact, or direct impact at a point removed from the origin of a spill, either through
potential exposure to pollutants downstream of the transportation corridor or blockage of
migration to spawning and nursery habitats upstream.

A significant fraction of Iliamna Lake's sockeye salmon resource would be vulnerable to
impacts from the Pebble transportation corridor. Migration and spawning in these streams
could be  compromised below the corridor crossing by sedimentation or contamination
from spills, and habitat upstream from the crossings could be cut off from access by spills
or structural failures. To roughly estimate the proportion at risk, we adjusted the stream
length potentially affected by the transportation corridor in each system by the average
surveyed spawner density for that system (Figure 4).  This analysis suggests that about
twenty percent of known stream spawning populations of Iliamna system sockeye
reproduces in streams and rivers intersected by the Pebble corridor. Moreover, many
principal sockeye fluvial spawning areas lie in close proximity to road and pipeline
crossing sites. In addition, a major sockeye salmon beach spawning site is located at the
mouth of Knutsen Creek (Rich 2006,  and unpublished data), a stream that the Pebble
transportation corridor would cross, making its delta vulnerable to impacts from
upstream. If the Knutsen Creek delta spawning population is included in the tally of
potentially affected waters, roughly thirty percent of known Iliamna Lake sockeye
spawners could be at risk.  A similar analysis from the University of Washington
Fisheries Research Institute came to a similar conclusion (Rich 2011, and unpublished
data).

Available data show that rearing sockeye salmon are most concentrated in the eastern
half of the lake (Figure 5), where the Pebble transportation corridor would intersect with
numerous direct tributaries to the lake and for some distance would occupy the lakeshore
itself, posing a high  risk, if not a certainty of affecting Iliamna Lake habitats.
                                        25

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VI. MITIGATION MEASURES AND THEIR LIKELY EFFICACY

It is commonly recognized that the environmental impact of a major construction project
like a road or major pipeline corridor can never be fully mitigated (Trombulak and
Frissell 2000). Indeed, inherent to the underlying purpose of road projects (i.e., to alter
natural conditions so that vehicle transportation is possible where it was physically
impossible before) are changes to landscape structure that not only irretrievably alter
ecosystem and biological conditions within the construction footprint, but also interrupt
or modify the natural flux of water, sediment, nutrients, and biota across the ecosystem,
usually permanently (Darnell et al. 1976, Rhodes et al.  1994, Forman and Alexander
1998, Forman 2000, Forman and Deblinger 2000, Trombulak and Frissell 2000).
Moreover, engineering or implementation failures, unanticipated field conditions, and/or
unforeseen environmental events inevitably test and compromise the effectiveness of
mitigation measures applied in large projects (e.g., Espinosa et al. 1997, Levy 2009). The
only sure way to avoid impacts to a freshwater ecosystem from a large road or pipeline
project is to refrain from building such a project in that ecosystem (Frissell and Bean
2009).

Unfortunately the scientific and professional literature on the subject of the effectiveness
of environmental mitigation measures for water and fish is sparse and poorly synthesized.
There are  lists of standard practices and there are a scattering of short-term, site-specific
studies of efficacy of mitigation measures for roads  and pipelines (e.g., assessment of
mitigation of the delivery of sediment and its local impact on biota). Some report
showing adverse impact, or ineffectiveness of mitigation measures, and others report not
detecting adverse effects, which is often taken as circumstantial evidence that mitigation
measures were effective. Exceedingly few of these  studies extend to medium- or long-
term evaluation of mitigation effectiveness, and fewer still have been published in
accessible peer-reviewed forums.  Therefore, evaluating the effectiveness of proposed
mitigation measures remains a process of best professional judgment and logical
evaluation of premises, specific environmental context, and likely operational
circumstances.  The release of the Preliminary Assessment for the Pebble project this
year (Ghaffari et al. 2011) allows some specific analysis of the potential transportation
corridor.

A few synthesis documents also provide some guidance (e.g., Rhodes et al. 1994), but the
over-arching theme is that implementation of site-specific mitigation measures is fraught
with uncertainty and risk and that, overall, mitigation has proven to be ineffective in fully
protecting water quality and conserving freshwater fishery resources (Esiponsa et al.
1997).
                                        26

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Mitigation Measures for Pebble Road and Pipelines

In the following section I cite mitigation measures identified in Ghaffari et al. (2011) for
the Bristol Bay transportation corridor and briefly assess 1) their likely effectiveness to
avoid or prevent harm to Bristol Bay water quality and fishery values, 2) possible adverse
side effects of applying the mitigation measure, and 3) alternative mitigation measures
that could be more effective, given the project is assumed to  proceed.

As far as practicable, minimize areas of disturbances (Ghaffari et al. 2011, p. 3 29).  This
means restricting the footprint of construction activities and the final footprint of the
project to the minimum practical surface area (for example, by stacking the road and
pipelines in a single corridor).  The effectiveness of this measure depends on the location
of disturbance relative to resources at risk.  Even a small footprint that involves
permanent alteration of soils, vegetation, and hydrology can  have significant adverse
effects that propagate across the landscape by hydrologic and other vectors. This
measure must be practiced in the context of measures to avoid sensitive locations to be
effective.   Secondly, the effectiveness of this measure depends on how other project
parameters, including capital cost, delimit what is "practicable."  Limiting the area
disturbed  can often involve expensive practices such as long-distance hauling of waste
material in preference to onsite storage.  Finally, it is important to reiterate there are
potential risks associated with minimizing the footprint of the transportation corridor by
"stacking" the road and pipelines closely together. A pipeline failure or gas explosion
could sever the sole available route for ground transportation of equipment and personnel
to take emergency remedial measures.

As far as practicable, minimize stream crossings and avoid anadromous streams
(Ghaffari  et al.  2011, p.329).  This mitigation measure can be effective if three conditions
are met: 1) the landscape structure supports a route that avoids and is buffered from
strong interaction with streams, wetlands, and areas of near-surface groundwater; 2)
implementation does not result in a route so long and tortuous that it encumbers
additional environmental risk (e.g., to upland vegetation and wildlife), 3) resources are
sufficient to ensure that costly but environmentally sounder locations and possibly longer
routes are "practicable." Ghaffari et al. (2011, pp. 329-330) lists several other criteria that
constrain choice of road location, such as:

        1) Avoiding certain "unfavorable" land ownerships;
       2) Avoiding potential  (albeit unspecified) geologic hazards;
       3) Keeping road gradients under 8 percent;
       4) Maintaining minimum curvature and design speeds;
       5) Facilitating high axle loads for transporting assembled mine equipment;
       6)  Optimizing crossings of soils suitable to  maintaining roadway structure and
           stability;
       7)  Optimizing access to  sources of construction and  surfacing rock;
       8) Incorporating minimum 2.5-foot (76 centimeter)  ditches (possibly necessary
          for maintaining subgrade stability in many  wet or seasonally wet areas); and
       9) Minimizing area of disturbance.
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These competing objectives for the roadway, coupled with the large number of streams in
the landscape between the Pebble Mine site and Cook Inlet serve to limit the
effectiveness of this measure. To be most effective, minimizing stream crossings must
take primacy above other objectives of economic or operational convenience in project
siting and route location.  However, even in then, one potential side effect of basing
route selection on minimization of stream crossings in a stream-rich landscape would
likely be a route that is tortuous, countervailing the preceding mitigation measure of
minimizing area of disturbance. Hence the two most potentially effective mitigation
measures can stand in opposition to each other, especially in landscapes of relatively high
stream density.

Appropriate Best Management Practices (BMPs) will be utilized for the maintenance of
the road during operations and construction. Ghaffari et al. (2011, p.  370). The
Preliminary Assessment does not identify the appropriate practices for road maintenance
and construction, so it is not possible to specifically address their likely effectiveness at
reducing water quality and fisheries impacts. Specifically with regard to maintenance,
BMPs should include a strict prohibition on the disposal of material generated from
grading and  snow removal into surface waters, and should specify grading practices that
retain a local road contour necessary to disperse road surface drainage away from
streams, rivers,  Iliamna Lake and areas that drain to those waterways (Weaver and
Hagans 1994, Wemple et al.  1999, Furniss et al.  1991, Moll 1999). Construction
specifications should also designate sites for waste rock disposal and temporary materials
storage  and stipulate that they be in locations with minimum risk of subsequent transport
of material to streams, rivers, or Iliamna Lake, whether by water, wind, or mass failure
(Weaver and Hagans 1994).  These practices pose minimal risk of environmental side
effects,  though they may increases annual operational costs.  However, because these
practices are also effective at reducing roadway harm from erosion, over years they may
reduce maintenance and repair costs of the roadway.

Road dust abatement measures. Ghaffari et al. (2011, p. 458) mentions dust suppression
as a generic need, but the only allusion to specific mitigation regards procurement of a
water spreading truck (Ghaffari et al. 2011, p. 313). The Preliminary Assessment
mentions developing a dust dispersion model as part of the permitting process for air
emissions (Ghaffari et al.  2011, p. 458), but it does not address dust impacts to surface
waters.  Depending on mineralogy, water application can be effective at reducing dust
transport, if application is frequent and of appropriately limited volume (USDA Forest
Service 1999).  There are, however, offsetting factors: moderate or heavy application of
water that exceeds the very low infiltration capacity of the road surface mobilizes dust in
fluid runoff instead of aerial deposition. Wherever a road is in close proximity to surface
waters,  such runoff can deliver suspended sediments, perhaps quite frequently, to
locations where, or at seasons when, they are otherwise virtually nonexistent.  Loss of
fines from the road rock matrix can contribute to breakdown and accelerated erosion of
the road surface (USDA Forest Service 1999). On the other hand under-application of
water fails to fully abate dust generation.
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Dust abatement measures can bring unintended side effects.  Even when dust abatement
is effective in retaining fines within the road rock matrix during the dry season, these
fines are simply mobilized by water and transported to the surrounding landscape in wet
season runoff (Reid and Dunne 1984).  The fine sediments are not eliminated—merely
reallocated. Other dust controls, including chloride salts, clays, lignosulfanate or other
organic compounds, and petroleum distillates (Hoover 1981) bring risk of toxic effects
when they run off and enter surface waters, though little research is available to assess
their environmental risks or safe conditions of application (USDA Forest Service 1999).
In the case of chloride salts, one recommendation is to avoid application within 8 meters
of surface waters  or anywhere groundwater is near the surface (USDA Forest Service
1999). Adverse biological effects are likely to be particularly discernible in naturally
low-conductivity  waters like those of Bristol Bay,  although research is needed to
substantiate this speculation.  The best practice to minimize  dust pollution is to avoid
road construction; the next most effective mitigation is surfacing all roadways with high-
grade asphalt pavement, with diligent maintenance of the paved road surfaces.

Paving can measurably reduce (though  not eliminate) the chronic generation and delivery
of both wet-weather surface-erosion and dust (Furniss et al.  1991, Weaver and Hagans
1994). However, asphalt production, deposition, and weathering generates hydrocarbons
that may, in some circumstances, be harmful to aquatic life (Spellerberg 1998,
Trombulak and Frissell 2000). In addition, off-site transfer of heavy metals and other
contaminants from road treatments such as deicing salts could be more rapid and direct
from paved road surfaces.  Moreover, in the case of the potential Pebble transportation
corridor, pavement could complicate excavation needed to access pipelines buried under
the road for visual inspection or repairs of leaks.
River and stream crossing structures have been designed to minimize the impact of the
project on areas of sensitive habitat (Ghaffari et al. 2011, p. 370). The Preliminary
Assessment further specifies that structural elements, including foundation elements, will
be designed to comply with a Memorandum of Agreement between ADOT and ADFG
regarding the design of culverts for fish passage and habitat protection. Wherever
culverts are not "suitable," Ghaffari et al. state the road would incorporate single- or
multiple-span bridges, with specifications based on "hydrological considerations, local
topography and fish passage requirements." Although criteria for determining crossing
structure type are not provided, the Preliminary Assessment identifies thirteen possible
multi-span bridge crossings, at "major" rivers, including 600-foot spans both at the
Newhalen River and across tidal flats at Iliamna Bay (Ghaffarri et al. 2011, p. 332).

Road crossing designs are much improved over historic practice, but where rivers are
wide and river or stream channels shift location frequently, any crossing structure short of
fully spanning the channel migration or flood-prone valley width can prove problematic.
Because of the nature of design structures and geomorphic setting, crossings of small
streams (under about 3 meters in width) pose greater risk of causing barriers to animal
migration and movement of sediment and natural debris, whereas crossings of larger
streams pose risk of erosion, sedimentation, channel and floodplain alteration, and
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delivery of pollutants from spills. The importance of small streams in Bristol Bay for
Dolly Varden and other fish species (Woody and O'Neal 2010) underscores the need for
culverts to provide fish passage and maintain fish habitat, even where salmon are absent.
Numerous studies also document that connectivity between small headwater streams
(including streams with intermittent or seasonal flow) and downstream habitats is
important and, in some cases, critical for productivity and survival of salmonids (e.g.,
Hilderbrand and Kirshner 2000, Young et al. 2004, Fausch et al. 2002, Hastings 2005,
Wigington et al. 2006, Bryant et al. 2009).

In general, culvert crossings of small streams remain problematic, even under
contemporary standards and practices as applied by state highway departments and land
management agencies.  Gibson et al. (2005) surveyed a 210-kilometer segment of the
Trans-Labrador highway, newly constructed under prevailing Canadian government and
provincial regulations for fish protection, and found that more than half of the culverts
posed fish passage problems  due to inadequate design or poor installation. Chestnut
(2002), in a survey of stream crossings in Kamloops, British Columbia, found that out of
31 culverts assessed, all but one failed to meet Department of Fisheries and Oceans
objectives for juvenile fish passage and maintenance offish habitat. In an audit of two
other Provincial Forest Districts in British Columbia, Harper and Quigley (2000)
concluded about a third of road culverts blocked fish passage to upstream habitat.

In small streams without significant near-surface groundwater associations, the
effectiveness of different stream crossing structures depends on the geomorphic setting,
including stream gradient and channel stability, road slope and angle of interception,
flashiness of water and sediment flows, potential for ice rafting and plugging, and
abundance and size range of wood and other waterborne debris.  In small prairie streams,
for example, Bouska et al. (2010) found that large box culverts were less disruptive of
stream morphology and hydrodynamics than were low water crossings and corrugated
metal culverts.  Large-width, bottomless arch or "squashed design" culverts that preserve
or restore a natural channel bed material train through the length of the culvert are the
current standard norm for stream crossings to maintain both  physical and biological
connectivity (Weaver and Hagans 1994, FSSSWG 2008). In recent years, the US Forest
Service has worked to reduce risk of failure and improve passage offish and other biota
at road at road crossings using a new so-called "Stream  Simulation" design protocol for
culvert crossings of small streams that emphasizes dramatically wider, open-bottom arch
stream crossing designs that strive to maintain both geomorphic and biological continuity
through the crossing (FSSSWG 2008).   Greater expense of initial design and installation
may be compensated by longer life spans (round corrugated  steel culverts commonly
have a functional life span of 20 years,  if properly functioning) and fewer emergency
maintenance and repair costs (Weaver and Hagans 1994).

Effective mitigation of adverse roadway impacts to streams must account explicitly not
just for the passage offish and surface waters; in ecosystems like Bristol Bay that are rich
in shallow groundwater, roadways must also avoid disrupting  or obstructing hyporheic
flow paths and shallow aquifers.  Short of not building new roads altogether, the most
effective practice to avoid alteration of hydrology and hydrologic connectivity is to locate
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the route well away from streams, wetlands, springs, seeps, areas of near-surface
groundwater, pond and lake shorelines, and alluvial fans and glacio-alluvial valley trains
where frequently shifting stream courses are present. Due to the number and density of
streams, zones of near-surf ace groundwater, and associated wetlands in the area of the
potential transportation corridor (Hamilton 2007), complete avoidance of "sensitive
habitat" would be exceedingly difficult.  If avoidance of these sensitive hydrologic
features is impossible, the next best mitigation is bridge the roadway across them,
completely spanning the area of both surface water and near-surface groundwater,
thereby reducing direct physical intersection of the roadway and water features. At
streams, crossings should occur only where channels are stable, not migrating and not
branching. Where long suspensions are necessary to bridge multiple or coextensive
hydrologic features, special engineering is required to manage stormwater drainage that
accrues on the extensive suspended roadway and route and disperse this discharge to
areas well away from surface waters.

Where spanning extensive areas of shallow groundwater is impracticable (e.g., due to
expense), the next most effective mitigation would be to "lift" the road surface over them
by use of porous fills. Porous fills (commonly large, angular open-framework rock
capped by a surface of mixed material) can provide  a stable road prism and support heavy
vehicle loads, while passing overland or  sheet flow with limited concentration and
maximum dispersion of water, thereby reducing erosive forces and impacts to local
hydrology (Moll 1999). Nevertheless, porous fills do partly obstruct surface drainage,
blocking the movement of sediment, debris, and aquatic organisms and despite some
filtering capacity, they do not fully control  delivery  of sediment and other pollutants from
the road surface into surface waters.  Under heavy tire loads, porous fill road beds may,
over time, subside into subsurface soils and alluvial deposits, allowing native fines to
enter and clog the porous matrix, eventually making it a barrier to subsurface flow.
Burial in a common trench. (Ghaffari et al. 2011, p. 336).  Burial aids in insulation of the
pipeline. It also can reduce pipeline impact on wildlife movements, and in steep,
mountainous terrain, it can partially protect pipelines from damage and potential spills
caused by surface processes like avalanches, landslides and debris flows (Levy 2010).
Equally important, clustering of pipelines reduces the direct spatial footprint of
disturbance to habitat by concentrating construction and maintenance activity.  The
smaller footprint, in turn, minimizes the area destabilized by excavation and backfill, thus
reducing impacts to water quality from construction site runoff. The downsides of
pipeline burial are that: 1) it prevents visual inspection of the lines for leakage and visual
monitoring of spilled materials; 2) it typically  does not incorporate secondary
containment measures for spills and leaks; and 3) it can disrupt subsurface hydrology by
severing, damming, or capturing buried flow paths.  Visual inspection is a vital backup to
electronic leak detection systems and may be the only sure way to detect some chronic,
slow leaks.  Finally, buried pipelines are still vulnerable to stress and rupture from
subsurface processes, such as earthflows,  slumps, and seismic shocks.

Secondary containment of buried lines, using an impermeable lining for the trench, could
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help limit the discharge of material in the event of leaks or spills, but would have the
opposing effect of causing greater distortion of natural subsurface flow paths. By acting
as a subsurface dam, a lined trench could not only disrupt natural hydrology patterns, but
by obstructing subsurface water flow, belowground containment structures could
complicate the management of drainage that is necessary to maintain the road surface and
the trench itself.  From the standpoint of the protection of water quality and fish
resources, ideal mitigation measures could include:  1) keeping the pipelines above
ground and visible (except where landslide and avalanche risks are moderate to high); 2)
incorporating some means of secondary containment for spills and leaks; 3) installing
manual shutoff valves at either side of all surface water crossings and all locations
vulnerable to damaging landslides or avalanches; and 4) implementing robust plans for
both very frequent or full-time visual inspection for leaks, and rapid  response for
containment, shutdown, repair, and disposal of contaminated material when leaks do
occur. Note that these measures may have adverse side effects;  for example, elevated
pipelines may be more disruptive of wildlife movements, such as caribou migrations.

There is another drawback of clustering that the above mitigation measures would not
resolve. With common proximity of the lines, there might be some risk that natural gas
leakage and subsequent explosion could both damage the other lines and hinder rapid
response to repair damage and contain spills (due to damage to the road).  This risk bears
close examination by appropriate experts.

Boring pipelines under stream (Ghaffari et al. 2011, p.337). Horizontal boring of a
pipeline under stream crossings can reduce much of the channel disruption, erosion and
sedimentation associated with trenching and exposed line surface crossings. However,
the method suffers from the same drawbacks identified above under Burial in a common
trench. In particular, leakage of the lines under the stream course could result in
undetected  contamination of hyporheic, thence surface waters.  To reduce impacts to fish
and water quality, the most effective mitigation measure likely would include suspending
pipelines (along with road crossings) on full-span bridges that minimize disturbance to
surface water, as well as containing the pipelines in a secondary pipe designed for and
operated under a plan that includes frequent visual inspection and robust spill response
procedures.  Burial—with secondary containment—could be appropriate for unavoidable
crossings of areas with unstable slopes prone to landslides and avalanches. Note that
these measures may have adverse side effects; for example, elevated pipelines may be
more disruptive of wildlife movements.

Secondary containment pipe ("encased in a protective layer") for overhead stream
crossings on bridges (Ghaffari et al.  2011, p. 337). Secondary containment is a
particularly important measure for isolating and managing leaks or spills wherever the
pipeline is directly above surface water. Ideally, some form of secondary containment
should extend to other locations where leaks or spills could reach and contaminate
surface or subsurface waters.  There also should be specific procedures and requirements
for response and materials handling in the event of leaks or spills into the containment
system, to prevent  secondary pollution from leaching or spill of contaminated materials.
Advance designation and preparation of an array of well-distributed  storage pads for
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contaminated soils at dry, stable sites far removed from surface waters or shallow
groundwater would be among the needs to implement this measure effectively. These
precautionary structural measures are likely to be costly.
Manual isolation valves on either side of major river crossings (Ghaffari et al. 2011, p.
376). The Preliminary Assessment does not define "major" river crossings, but they
would presumably include multi-span crossings such as that of the Newhalen River.  The
effectiveness of manual  closure correlates directly to the effectiveness of leak detection
and rapid response. Coupled with full-time, fully redundant electronic and visual leak
detection systems and valve locations as suggested above, manual valves could
considerably improve the odds of successful stream protection from leaks and spills.
Again, the surveillance and logistical measures needed to support  a rapid response to
accidents can be costly.

Electronic Leak Detection Systems (Ghaffari et al. 2011, p. 376). The Preliminary
Assessment discusses implementing an electronic leak detection system for the pipelines,
using pressure transmitters located along the length of the lines. It also specifies a
SCADA (Supervisory Control and Data Acquisition) system for monitoring and control
of the pumping stations, with fiber optic communications between the concentrator and
the port site tying the detection systems together.  The most effective approach to leak
detection includes redundant systems for each separate pipeline. However, the proposed
approach appears to tie leak detection for all four systems to a single fiber optic line.
Coupled with the close proximity of the four pipelines, a single communications line
increases the chance that leak detection could be disrupted by the same event that
triggered a leak (e.g., a seismic dislocation, lake seiche wave, or large landslide).  As
suggested above, providing for rigorous visual inspection would further increase the
effectiveness of electronic leak detection and reduce the risk of undetected spills.
Likely Effectiveness of Mitigation Measures

Special circumstances prevail in Bristol Bay and specifically in the area proposed for
the Pebble Mine road and pipeline corridor that render the effectiveness of standard
or even "state of the art" mitigation measures highly uncertain. These include:

    1)  Subarctic extreme temperatures and frozen soil conditions could complicate
       planning for remediation, with outcomes uncertain as a result of variable
       conditions and spill material characteristics;
    2)  Subarctic climatic conditions limit the lushness and rapidity of vegetation growth
       or re-growth following ground disturbance, reducing the effectiveness of
       vegetated areas as sediment and nutrient filtration buffers;
    3)  Widespread and extensive areas of near-surface groundwater and seasonally or
       permanently saturated soils limit potential for absorption or trapping of road
       runoff, and increase likelihood of its delivery to surface waters.
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4) Likelihood of ice flows and drives during thaws that can make water crossing
   structures problematic locations for jams and plugging.
5) Seismically active geology; even a small increment of ground deformation can
   easily disturb engineered structures and alter patterns of surface and subsurface
   drainage in ways that render engineered mitigations inoperative or harmful.
6) Remote locations that are not frequented by human users, hence mitigation
   failures and accidents may not be detected until substantial harm to waters has
   occurred.

While many possible mitigation measures can be identified and listed in a plan, they
cannot all be ideally applied in every instance.  Mitigation measures are commonly
mutually limiting or offsetting in field application, as is common knowledge to
practicing engineers. As a salient example for the potential Pebble Mine corridor,
choosing a road location that minimizes crossings of streams, wetlands, and areas of
shallow groundwater in a landscape that is rich in those hydrologic features can result
in a tortuous alignment, or one that is substantially lengthened, and might involve
substantially more vertical curvature to accommodate upland terrain. A tortuous
alignment greatly increases the total ground area disturbed, and increased road
curvature in either horizontal and vertical dimensions may increase  risk of traffic
accidents and consequent spills.  Moreover in this case it would increase the length
and structural complexity of the road-parallel pipelines. Avoidance of sensitive
features therefore elevates other environmental risks. This underscores the fact that
there is no "free lunch" when it comes to mitigating the environmental impacts of a
new road in a previously roadless landscape.
VII.    CONCLUSIONS

•  Bristol Bay's robust and resilient salmon fishery is in part associated with the
   watershed's extremely high quality waters and high integrity freshwater
   ecosystems, minimally impacted by roads and industrial development.

•  A second major contributor to the Bristol Bay watershed's productivity for
   salmon is its abundant and extensive near-surface groundwater and strong vertical
   linkage between surface waters and groundwaters, across a wide range of stream
   sizes and landscape conditions.

•  Any environmental analysis and planning of a road project such as the Pebble
   Mine road must consider the significance of initial road development as an
   economic and social stepping stone to future roads and developments.

•  Roads, in particular can foster the incremental decline of salmon and other native
   fishes by their own direct environmental impact, but equally important is that
   roads facilitate a variety of human activities that bring their own suite of impacts
   including increased access to primitive lands, increasing legal and illegal hunting
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   and fishing, use of off-highway vehicles, increased mineral prospecting, and
   others.

•  For the Pebble road corridor, each stream or wetland crossing has the potential for
   impacts to not just to salmon populations in the stream itself, but also downstream
   in Iliamna Lake, which is in close proximity.

•  The Pebble transportation corridor poses risks of direct and acute impacts to
   salmonids, including possible loss of populations due to blocking of migration
   pathways from spills or from stream crossing dysfunctions.  Like any such
   development, it will  certainly cause chronic, pervasive "press disturbances"
   (Yount and Niemi 1990) all along its length and for its entire existence,
   contributing to deterioration of quality of spawning habitats,  reduced habitat
   diversity, disrupted groundwater hydrology, alteration of roadside vegetation, and
   related impacts that stem from construction, operation and maintenance.

•  Many environmental mitigation measures identified for the Pebble Project suffer
   from  being mutually exclusive or offsetting, from being potentially superseded or
   limited by engineering, operational, maintenance, or fiscal concerns, or are likely
   to be  ineffective given the hydrogeomorphology, subarctic climate and
   hydrogeologic conditions, seismicity,  and pristine condition and inherent
   sensitivity of the environment in Bristol Bay watershed.
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                            ACKNOWLEDGMENTS

   Rebecca Shaftel of the Alaska Natural Heritage Program, Anchorage contributed
immensely to the analytic and graphical content of this report; she prepared all the maps.
We thank Harry Rich and Dr. Thomas Quinn of the University of Washington School of
Fisheries and Aquatic Sciences for critical data and analytic leadership in the assessment
                of risk to sockeye salmon and other fishery resources.
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LITERATURE CITED
 ADFG. 2010. Alaska Department of Fish and Game, Commercial Fisheries Division.
   News Release. 2010 Bristol Bay salmon season summary.
   http://www.cf.adfg.state.ak.us/region2/fmfish/salmon/bbay/brbposlO.pdf

ADFG.  2012.  Alaska Freshwater Fish Inventory Database.
   http://www.adfg.alaska.gov/index.cfm?adfg=ffmventory.liability

Angermeier, P., A. Wheeler, and A. Rosenberger. 2004. A conceptual framework for
   assessing impacts of roads on aquatic biota. Fisheries 29(2): 19-29.

Ask, J., J. Karlsson, L. Persson, P. Ask, P. Bystrom, and MJansson. 2009. Whole-lake
   estimates of carbon flux through algae and bacteria in benthic and pelagic habitats of
   clear-water lakes.  Ecology 90:1923 -1932. [doi:http://dx.doi.org/10.1890/07-1855.1]

Baxter, C.V., C.A. Frissell, and F.R. Hauer. 1999. Geomorphology, logging roads and the
    distribution of bull trout (Salvelinus confluentus) spawning in a forested river basin:
    implications for management and conservation. Transactions of the American Fisheries
    Society, 128:854-867.

Bilby, R. E., B. R. Fransen, and P. A. Bisson. 1996. Incorporation of nitrogen and carbon
   from spawning coho salmon into the trophic system of small streams:  evidence from
   stable isotopes. Canadian Journal  of Fisheries and Aquatic Sciences 53:164-173.

Birch, P.B., R.A. Barnes, and D.E. Spyridakkis.  1980. Recent sedimentation and its
   relationship with primary production in four western Washington lakes.  Limnology and
   Oceanography 25(2):240-247.

Bottom, D. L., K. K. Jones, C. A. Simenstad, and C. L. Smith. 2009. Reconnecting social and
   ecological resilience in salmon ecosystems. Ecology and Society 14(1): 5. [online] URL:
   http://www.ecologvandsocietv.org/voll4/issl/art5/

BBAP. 2005. Bristol Bay Area Plan.  Alaska Department of Natural Resources, Anchorage.
   Chapter 2: Transportation. 5pp.
   http://dnr.alaska.gov/mlw/planning/areaplans/bristol/index.htm

Bouskaa, W. W., T. Keaneb, and C. P. Paukertc. 2010. The Effects of Road Crossings on
   Prairie Stream Habitat and Function. Journal of Freshwater Ecology 25(4): 499-506.

Bradshaw, E.G., P. Rasmussen, and B. Vad Odgaard. 2005.  Mid-to late-Holocene land-use
   change and lake development at Dallund SO, Denmark: synthesis of multiproxy data,
   linking land and lake.  TheHolocene 15(8):152-1162. [doi: 10.1191/0959683605hl887rp]

Bryant, M., M. Lukey, J. McDonell, R. Gubernick, and R. Aho. 2009. Seasonal Movement of
                                          37

-------
   Dolly Varden and Cutthroat Trout with Respect to Stream Discharge in a Second-Order
   Stream in Southeast Alaska. North American Journal of Fisheries Management
   29(6): 1728-1742.

Burgner, R.L.  1991.  Life history of sockeye salmon (Oncorhynchusnerkd). In: Pacific
   Salmon Life Histories. C. Groot and L. Margolis (eds.). Published by UBC
   Press, Canada. Pp. 3-117.

Chestnut, TJ. 2002.  A review of closed bottom stream crossing structures (culverts) on fish
   bearing streams in the Kamloops Forest District, June 2001. Canadian Manuscript
   Report of Fisheries and Aquatic Sciences 2602.

Cunjack, R.A. 1996. Winter habitat of selected stream fishes and potential impacts from land
   use activity. Canadian Journal of Fisheries and Aquatic Sciences 53(Supplement 1): 267-
   282.

Czech, B., P.R. Krausman, and P.K. Devers. 2000. Economic associations among causes of
   species endangerment in the United  States. BioScience 50: 593-601.

Darnell, R. M. W. E. Pequegnat, F. J. Benson, and R. A. Defenbaugh.  1976. Impacts of
   Construction Activities in Wetlands of the United States. U.S. Environmental Protection
   Agency, Ecological Research Series EPA-600/3-76-045, 396pp. http://nepis.epa.gov/

Duffield, J., D. Patterson and C. Neher.  2007. Economics of wild salmon watersheds:
    Bristol Bay, Alaska. USDA Forest Service Proceedings RMRS-P-49, pp. 35-44.

Ehrenfeld, J. G., and J.P. Schneider. 1991. Chamaecyparis thyoides wetlands and
   suburbanization:  effects on hydrology, water quality and plant community composition.
   Journal of Applied Ecology 28:467-490.

Endicott D. 2008. National Level Assessment of Water Quality Impairments Related to
   Forest Roads and Their Prevention by Best Management Practices. Final report prepared
   for USEPA Office of Water, Office of Wastewater Management Permits Division, by
   Great Lakes Environmental Center, Traverse City, MI.  250 pp.
   http ://wildlandscpr. org/files/Forest%20Road%20BMP%20fmal%20report%2012%2004
   %2008%20revl%20(3).pdf

Espinosa, F.A., J.J. Rhodes, and D.A. McCullough.  1997.  The failure of existing plans to
   protect salmon habitat in the Clearwater National Forest in Idaho. Journal of
   Environmental Management 49:205-230.

Fausch, K. D., C. E. Torgersen, C. V. Baxter, and H. W. Li.  2002.  Landscapes to
   riverscapes: bridging the gap between research and conservation of stream fishes.
   BioScience 52:483-498.

Forman, R. 2000. Estimate of the area affected ecologically by the road system in the United
   States. Conservation Biology. 14(l):31-35.
                                          38

-------
Forman, R.T. and Alexander, L.E. (1998) Roads and their major ecological effects. Annual
   Review of Ecology and Systematics 29, 207-231.

Forman, R. T. T. 2004. Road ecology's promise: What's around the bend?
   Environment 46:8-21.

Forman, R. and R. Deblinger. 2000. The ecological road-effect zone of a Massachusetts
   (U.S.A.) suburban highway. Conservation Biology. 14(l):36-46.

Frissell, C.A. and C.W. Bean. 2009. Responding to environmental threats within the UK
   and North America.  In:  Assessing the Conservation Value of Fresh waters: An
   International Perspective. P. J. Boon and C.M. Pringle (eds.).  Published by Cambridge
   University Press, Cambridge, UK.  Pp. 91-116.

FSSSWG (Forest Service Stream-Simulation Working Group). 2008. Stream simulation: an
   ecological approach to road stream crossings. USDA Forest Service Technology and
   Development Program, San Dimas, CA.  29 pp.
   http://www.stream.fs.fed.us/fishxing/publications/PDFs/AOP PDFs/Cover TOC.pdf

Furniss, M. J.; Roelofs, T.  D.; Yee, C. S. 1991. Chapter 8, Road construction and
   maintenance. In: Meehan, W. R., ed. Influences of forest and rangeland management on
   salmonid fishes and their habitats. American Fisheries Society Special Publication
   19:297-323.

Ghaffari, H.P.,  R. S. Morrison, M. A. de Ruijter, Aleksandar Zivkovic, T.Hantelmann, D.
   Ramsey, and S. Cowie. 2011. Preliminary Assessment of the Pebble Project, Southwest
   Alaska. Report prepared by WARDROP, Vancouver, British Columbia, for Northern
   Dynasty Minerals, Ltd. Document No. 1056140100-REP-R0001-00. 579 pp. Available
   online at:
   http://www.northerndvnastyminerals.eom/i/pdf/ndm/Pebble Project Preliminary%20Ass
   essment%20Technical%20Report February%2017%202011 .pdf

Gibson, R.J., R.L. Haedrich, and C. M. Wenerheim. 2005. Loss offish habitat as a
   consequence of inappropriately constructed stream crossings.  Fisheries (Bethesda) 30(1):
   10-17.

Gracz, M., K. Noyes, P. North, and G. Tande. 1999. Wetland Mapping and Classification of
   the Kenai Lowland, Alaska.  Kenai Watershed Forum, Fritz Creek, AK. Published online
   at http://www.kenaiwetlands.net/.

Gucinski, H., M. J.  Furniss, R. R. Ziemer, and M. H. Brookes. 2001. Forest roads:
   a synthesis  of scientific information. Gen. Tech. Rep.  PNWGTR-509. U.S.
   Department of Agriculture, Forest Service, Pacific Northwest Research Station, Portland,
   OR.  103 pp.

Hamilton, T.D.  2007. Report C-l Surficial Geologic Map of the Pebble Project.  The Pebble
   Partnership Pre-Permitting Environmental/ Socio-Economic Data Report Series.
                                          39

-------
Hancock, P. J. 2002. Human Impacts on the Stream-Groundwater Exchange Zone.
   Environmental Management Vol. 29, No. 6, pp. 763-781.

Harper, D. and J. Quigley. 2000. No net loss offish habitat: an audit of forest road crossings
   offish-bearing streams in British Columbia, 1996-1999. Fisheries and Oceans Canada,
   Habitat and Enhancement Branch, Vancouver, British Columbia V6B 5G3 2319. 43 pp.
   http://www.dfo-mpo.gc.ca/Library/247265.pdf

Hastings, K. 2005.  Long-term persistence of isolated fish populations in the Alexander
   Archipelago. Doctoral Dissertation, The University of Montana, Missoula, MT.

Hilborn, R., T. P. Quinn, D. E. Schindler, and D. E. Rogers. 2003. Biocomplexity and
   fisheries sustainability. Proceedings of the National Academy of Sciences of the
   United States of America 100(11):6564-6568.

Hilderbrand, R.H., and Kershner, J.L. 2000. Conserving inland cutthroat trout in small
   streams: how much stream is enough? North American Journal of Fisheries Management
   20: 513-520.

Hitt, N.P., C.A. Frissell, C.C. Muhlfeld, and F.W. Allendorf. 2003.  Spread of hybridization
   between native westslope cutthroat trout, Oncorhynchus clarki lewisi, and non-native
   rainbow trout, O. mykiss.  Canadian Journal of Fisheries and Aquatic Sciences 60: 1440-
   1451.

Hoover, J. 1981. Mission oriented dust control and surface improvement processes for
   unpaved roads. Engineering Research Institute, Iowa State University Project 1308, Iowa
   DOT Project HR-194, Ames, Iowa.
   http://www.iowadot.gov/operati onsresearch/reports/reports_pdf/hr_and_tr/reports/hr 194.
   p_df

Johnson, J. and P. Blanche. 201 la. Catalog of waters important for spawning, rearing, or
   migration  of anadromous fishes - Southwestern region, Effective June 1, 2011. Alaska
   Department of Fish and Game, Special Publication No. 11-08, Anchorage.

Johnson, J. and P. Blanche. 201 Ib.  Catalog of waters important for spawning, rearing, or
   migration  of anadromous fishes - Southcentral region, Effective June  1, 2011. Alaska
   Department of Fish and Game, Special Publication No. 11-06, Anchorage.

Jones, Julia A., Swanson, Frederick J., Wemple, Beverley C., Snyder, Kai U. 2000
   Effects of roads on hydrology, geomorphology, and disturbance patches in stream
   networks Conservation Biology 14(1): 76-85.
   http://andrewsforest.oregonstate.edu/pubs/pdf/pub2634.pdf

Kahklen, and  K. J. Moll. 1999. Measuring Effects of Roads on Groundwater: Five Case
   Studies. USDA Forest Service Technology & Development Program report, San Dimas,
   CA. 12pp.
                                          40

-------
Kondolf, G.M., H. Pie'gay, and N. Landon. 2002. Channel response to increased and
   decreased bedload supply from land use change: contrasts between two catchments.
   Geomorphology 45: 35-51.

Lawrence, W.M., and LA. Campbell. 1980. Effects of a pipeline right-of-way on sediment
   yields in the Spring Creek watershed, Alberta, Canada. Canadian Geotechnical Journal
   17(3): 361-368.

Levesque.  L.M., and M. G. Dube. 2007. Review of the effects of in-stream pipeline crossing
   construction on aquatic ecosystems and examination of Canadian methodologies for
   impact assessment.  Environmental Monitoring and Assessment 132(l-3):395-409.

Levy, D.A. 2009. Pipelines and salmon in northern British Columbia.  Report prepared for
   The Pembina Institute, Drayton Valley, Alberta. 51 pp. Available online at:
   http://pubs.pembina.org/reports/pipelines-and-salmon-in-northern-bc-report.pdf

Lowe, W.H., and G.E. Likens. 2005. Moving headwater streams to the head of the class.
   BioScience 55(3): 196-197.

Malcolm, LA., C. Soulsby, A. Youngson, D. Hannah,  I. McLaren and A. Thorne. 2004.
   Hydrological influences on hyporheic water quality: implication for salmon egg survival.
   Hydrological Processes 18: 1543-1560.

Moll, I.E.  1999. Minimizing Low Volume Road Water Displacement. USDA Forest Service
   Technology & Development Program 7700—Transportation Management 2500—
   Watershed Management. San Dimas Technology & Development Center, San Dimas,
   CA. 18pp.

Montgomery, D. R. 1994. Road surface drainage, channel initiation, and slope stability.
   Water Resources Research 30: 1925-1932.

Morstad, S. 2003. Kvichak River sockeye salmon spawning ground surveys,  1955-2002.
   Alaska Department of Fish and Game, Regional Information Report No. 2A02-32,
   Anchorage.

Newcombe, C.P. and D.D. MacDonald. 1991. Effects  of Suspended Sediments on Aquatic
   Ecosystems. North American Journal of Fisheries Management 11: 72-82.

Newcombe, C. P. and J. O. T. Jensen.  1996. Channel suspended sediment and fisheries: a
   synthesis for quantitative assessment of risk and impact. North American Journal of
   Fisheries Management 16(4):693-719.

Ramstack, J.M., S. C Fritz, and D. R Engstrom. 2004. Twentieth century water quality trends
   in Minnesota lakes compared with presettlement variability. Canadian Journal of
   Fisheries and Aquatic Sciences 61(4):561-576. [10.1139/f04-015]
                                         41

-------
Rashin, E., C. Clishe, A. Loch, and J. Bell. 1999. Effectiveness of Forest Road and Timber
   Harvest Best Management Practices with Respect to Sediment-Related Water Quality
   Impacts. Publication No. 99-317. TFW-WQ6-99-001. report prepared for
   Timber/Fish/Wildlife Cooperative Management, Evaluation, and Research Committee by
   the Department of Ecology, Olympia, Washington.
   http://www.dnr.wa.gov/publications/fp tfwwq6 99  001 .pdf

Reid, L.M., and T. Dunne. 1984. Sediment Production From Forest Road Surfaces. Water
   Resources Research 20(11): 1753-1761.

Power, G., R.S. Brown, and J.G. Imhof. 1999. Groundwater and fish: Insights from northern
   North America. Hydrological Processes 13: 401-422.

Rhodes, J.J., D.A. McCullough, and F.A. Espinosa.  1994. A course screening process for
   potential application in ESA consultations. Submitted to NMFS, NMFS/BIA Inter-
   Agency Agreement 40 ABNF3.  126 pp. + appendices, www.critfc.org/tech/94-
   4report.pdf

Rich, Harry. 2006. Effects of climate and density on the distribution, growth, and
    life history of juvenile sockeye salmon (Oncorhynchus nerka) in Iliamna Lake, Alaska.
   M.S. Thesis, University of Washington, Seattle, WA.  69 pp.

Rich, Harry. 2011. Pebble Mine: Iliamna Lake activities.  Unpublished report, University of
   Washington, Fisheries Research Institute, Seattle, WA. 4 pp.

Ripley, T., G. Scrimgeour, and M. S. Boyce. 2005. Bull trout (Salvelinus confluentus)
   occurrence and  abundance influenced by cumulative industrial developments in a
   Canadian boreal forest watershed. Canadian Journal of Fisheries and Aquatic
   Sciences 62:2431-2442.

Schindler, D. E., R. Hilborn, B. Brandon Chasco, C. P.  Boatright, T. P. Quinn, L. A. Rogers,
   and M. S. Webster. 2010. Population diversity and the portfolio effect in an exploited
   species. Nature  465:609-612. [doi:10.1038/nature09060]

Schindler, D. E. and Scheuerell, M. D. 2002. Habitat coupling in lake ecosystems. Oikos
   98:177-189. [doi: 10.1034/j. 1600-0706.2002.980201.x]

Spellerberg, IF.  1998. Ecological effects of roads and traffic: a literature review. Global
   Ecology and Biogeography Letters 17(5):317-333.

Stanford, J. A. and J. V. Ward. 1993. An ecosystem  perspective of alluvial rivers:
   connectivity and the hyporheic corridor. Journal  of the North American Benthological
   Society 12(1):48-60.

Suttle, K., M. Power, J. Levine, and C. McNeely. 2004. How fine sediment in riverbeds
   impairs growth  and survival of juvenile salmonids. Ecological Applications 14:969-974.
                                          42

-------
The Nature Conservancy. 2010. Major Mining Claims Near Pebble (Map).  The Nature
   Conservancy, Anchorage, AK.
   http://www.groundtruthtrekking.org/Issues/MetalsMining/MiningClaimsNearPebble.html

Trombulak, S. and C. Frissell. 2000. Review of ecological effects of roads on terrestrial and
   aquatic communities. Conservation Biology. 14(1): 18-30.

USDA Forest Service.  1999. Dust Palliative Selection and Application Guide. Technology &
   Development Program 7700—Transportation Systems.
   http://www.fs.fed.us/eng/pubs/html/99771207/99771207.html

U.S. Fish and Wildlife Service.  2009. National Wetlands Inventory.
   http://www.fws.gov/wetlands/

Walker, D. A., and  K. R. Everett. 1987. Road Dust and Its Environmental Impact on
   Alaskan Taiga and Tundra. Arctic and Alpine Research, Vol. 19(4): 479-489.

Weaver, W.E., O.K. Hagans, and J.H, Popenoe. 1995. Magnitude and Causes of Gully
   Erosion in the Lower Redwood  Creek Basin, Northwestern California.  In Nolan, K.M.,
   H.M. Kelsey, and D.C. Marron  (eds.) Geomorphic Processes and Aquatic Habitat in the
   Redwood Creek Basin, Northwestern California.  USGS Professional Paper 1454. U.S.
   Department of Interior, Geological Survey, Washington, D.C.

Weaver, W.E., and  D.K. Hagans. 1994. Handbook for Forest and Ranch Roads - A Guide for
   Planning, Designing, Constructing, Reconstructing, Maintaining, and Closing Wildland
   Roads.  Prepared for the Mendocino County Resource Conservation District, Ukiah, CA.
   161 pp. Available online at:
   www.krisweb.com/biblio/gen_mcrcd_weaveretal_l 994_handbook.pdf

Wemple B.C., J.A. Jones, and G.R. Grant. 1996. Channel network extension by logging in
   two basins, western Cascades, Oregon. Water Resources Bulletin  32:  1195-1207

Wigington, P.J., Jr., J.L. Ebersole, M.E. Colvin, S.G.  Leibowitz, B. Miller,  B. Hansen, H.
   Lavigne, D. White, J.P. Baker, M.R. Church, J.R.  Brooks, M.A. Cairns, and J.E.
   Compton. 2006. Coho salmon dependence on intermittent streams. Frontiers in Ecology
   and Environment 4(10):513-518.

Wipfli, M.S., and C.V. Baxter. 2010. Linking ecosystems, food webs, and fish production:
   Subsidies in salmonid watersheds. Fisheries 35(8): 373-387.
   http://users.iab. uafedu/~mark_wipfli/pubs/2010_Wipfli&Baxter_Fisheries_Aug2010.pdf

Woody, C. A. Editor.  2007.  Sockeye salmon evolution, ecology and management.
   American Fisheries Society Symposium No. 53. Bethesda, MD. 129 pp.
                                          43

-------
Woody, C.A., and S. L. O'Neal. 2010. Fish surveys in headwater streams of the Nushagak
   and Kvichak River drainages, Bristol Bay, Alaska, 2008-2010. Report prepared for The
   Nature Conservancy, Anchorage, AK.  48 pp.
   http://www.fish4thefuture.com/pdfs/FishSurveysinNushagak Kvichakheadwaters.pdf

Woody, C. A. and B. Higman. 2011. Groundwater as Essential Salmon Habitat In Nushagak
   and Kvichak River Headwaters: Issues Relative to Mining. Fisheries Research Consulting
   and Ground Truth Trekking. 18 pp.
   http://www.fish4thefuture.com/pdfs/Groundwater_and_SalmonF IN AL27Augll.pdf

Young, M. K., P. M. Geunther-Gloss, and A. D. Ficke. 2004. Predicting cutthroat trout
   (Oncorhynchus clarki) abundance in high-elevation streams: revisiting a model of
   translocation success. Canadian Journal of Fisheries and Aquatic Sciences 62:2399-2408.

Yount, J. D., and G. J. Niemi. 1990. Recovery of lotic communities and ecosystems from
   disturbance-a narrative review of  case studies. Environmental Management 14:547-570.
                                          44

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                         Attachment A (pp. 46-51)

Resident fish streams potentially affected, crossed or closely approached by the potential
                      Pebble Mine transportation corridor.

 Compiled from the Alaska Freshwater Fish Inventory (AFFI) Database (ADFG 2012,
    Johnson and Blanche 201 la and 201 Ib, additional information provided by Joe
              Buckwalter, ADFG, Anchorage, AK, Unpublished data).

         Stream names from the Alaska Freshwater Fish Inventory Database.

 "Yes (spp?)" entry in the Anadromous Fish column means the AFFI database classifies
    the stream as "Anadromous," but anadromous species present are not identified.
                                     45

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Stream   Stream Name
No.      (if known)
(west to
NHD Reach Code   Stream  Resident     Anadromous
                Order   Fish         Fish
                (Map)
1




2



3










4

5








6



7

19030206007351 1




19030206007354 1



Upper TalarikCr. 19030206007015 4










19030206007159 1

19030206007175 1








19030205007587 2



19030205007593 2

Dolly
Varden,
rainbow
trout, slimy
sculpin
Dolly
Varden,
slimy
sculpin
Arctic
grayling,
Dolly
Varden,
ninespine
stickleback,
rainbow
trout, slimy
sculpin,
threespine
stickleback
[none
reported]
Dolly
Varden,
ninespine
stickleback,
rainbow
trout, slimy
sculpin,
threespine
stickleback
Ninespine
stickleback,
slimy
sculpin
Dolly
Varden
Co ho




Co ho



Chinook,
chum, coho,
sockeye








Coho
















                                  46

-------
Stream
No.
(west to
Stream Name
(if known)
NHD Reach Code  Stream   Resident    Anadromous
               Order    Fish        Fish
               (Map)
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
19030205007598
19030205007606
19030205007602
19030205007615
Newhalen River 19030205000002
19030205013069
19030205013055
19030205013057
19030205013041
19030205010623
19030205010628
19030205010629
Roadhouse Cr 19030206006712
NW Eagle Bay 19030206006678
Cr
19030206006677
19030206006644
2
2
2
2
5+
3
2
1
2
1
1
1
1
2
1
2
Dolly
Varden
Slimy
sculpin
Slimy
sculpin
Arctic
grayling,
longnose
sucker
Arctic
grayling,
jumpback
whitefish,
longnose
sucker,
rainbow
trout, round
whitefish,
sculpin
[no data]
[no data]
[no data]
[no data]
[no data]
[no data]
[no data]
Slimy
sculpin
Dolly
Varden
Ninespine
stickleback,
slimy
sculpin
Dolly

Yes(spp.?)
Yes(spp.?)

Arctic char,
chinook,
coho,
sockeye








Arctic char,
sockeye


                                  47

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                                                Varden
Stream
No.
(west to
Stream Name
(if known)
NHD Reach Code   Stream   Resident     Anadromous
                Order    Fish         Fish
                (Map)
24
25
26
27
28
29
30
31
32
33
19030206006671 2
19030206006663 2
NE Eagle Bay Cr 19030206006654 1
Young's Cr, 19030206006598 3
mainstem
Young's Cr, east 19030206006553 3
branch
Chekok Cr, west 19030206006533 2
branch
Chekok Cr, 19030206032854 3
mainstem
Canyon Cr 19030206006359 3
19030206006336 1
19030206006337 1
Dolly
Varden,
ninespine
stickleback
Dolly
Varden,
ninespine
stickleback
Ninespine
stickleback,
Rainbow
trout, slimy
sculpin
Dolly
Varden,
ninespine
stickleback,
rainbow
trout, slimy
sculpin
Dolly
Varden,
rainbow
trout, slimy
sculpin
[no data]
Rainbow
trout, slimy
sculpin
Dolly
Varden,
slimy
sculpin
[no data]
[no data]

Arctic char,
sockeye
Sockeye
Arctic char,
coho,
sockeye
Arctic char,
coho,
sockeye
Arctic char,
coho,
sockeye
Arctic char,
sockeye
Arctic char,
sockeye


                                  48

-------
34
19030206006236  1
[no data]
Stream   Stream Name   NHD Reach Code
No.      (if known)
(west to
                Stream  Resident
                Order   Fish
                (Map)
            Anadromous
            Fish
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
19030206006331
19030206006329
19030206006327
19030206006325
19030206006322
19030206006320
19030206006321
19030206006318
19030206006317
19030206006316
19030206006315
19030206006314
19030206006251
Knutson Cr 19030206006255
19030206006280
Pedro Cr 19030206006239
Russian Cr 19030206006248
19030206006231
19030206006230
19030206006228
19030206006227
19030206006222
Pile River 19030206000474
1
1
1
1
1
1
1
1
1
1
1
1
1
4
1
1
1
1
1
1
1
1
3
[no data]
[no data]
[no data]
[no data]
[no data]
[no data]
[no data]
[no data]
[no data]
[no data]
[no data]
[no data]
[no data]
Dolly
Varden,
slimy
sculpin
Dolly
Varden,
slimy
sculpin
[no data]
[no data]
[no data]
[no data]
[no data]
Dolly
Varden,
slimy
sculpin
[no data]
Slimy
sculpin,
threespine
stickleback













Arctic char,
sockeye








Arctic char,
sockeye
                                  49

-------
Stream   Stream Name  NHD Reach Code
No.      (if known)
(west to
Stream   Resident
Order    Fish
(Map)
Anadromous
Fish
58




58a
59




60
61



62
63
64

65
66
67
68
69




70


(Long L. 19030206010632
outlet)



19030206010632_2
Iliamna R 19030206000032




19030206005773
19030206005761



19030206005759
19030206005754
Chinkelyes Cr 19030206005737

19020602004863
19020602004864
19020602004865
19020602004866
Y-ValleyCr 19020602004967




19020602004882


1




1
4




1
2



1
2
2 (at
crossing)
1
1
1
1
1







Threespine
stickleback,
rainbow
trout, slimy
sculpin
[no data]
Dolly
Varden,
slimy
sculpin

[no data]
Dolly
Varden,
slimy
sculpin
[no data]
[no data]
Slimy
sculpin
[no data]
[no data]
[no data]
[no data]
Dolly
Varden



No fish
recorded or
observed
Yes (spp?)




Yes (spp?)
Chinook,
chum, coho,
pink,
sockeye,
Dolly Varden













Arctic char,
chinook,
chum, coho,
pink,
sockeye



                                  50

-------
51

-------
DRAFT                                                EPA910-R-12-004Bc
DO NOT CITE OR QUOTE                                  April 2013
                                                     Second External Review Draft
                                                     www.epa.gov/bristolbay
      An Assessment of Potential Mining Impacts on Salmon
                 Ecosystems of Bristol Bay, Alaska


                  Volume 3 of 3 -Appendices E-J


   Appendix H: Geologic and Environmental Characteristics of
      Porphyry Copper Deposits with Emphasis on Potential
    Future Development in the Bristol Bay Watershed, Alaska
                                NOTICE
   THIS DOCUMENT IS AN EXTERNAL REVIEW DRAFT. It has not been formally released by
   the U.S. Environmental Protection Agency and should not be construed to represent Agency
   policy. It is being circulated for comment on its technical accuracy and policy implications.
                      U.S. Environmental Protection Agency
                               Seattle, WA

-------
2 USGS
science for a changing world
Geologic and Environmental Characteristics of Porphyry

Copper Deposits with Emphasis on Potential Future

Development in the Bristol Bay Watershed, Alaska
By Robert R. Seal, II
U.S. Department of the Interior                            Approved: April 2012
U.S. Geological Survey                      Revised and Approved: December 2012

-------
                Geologic and Environmental Characteristics of Porphyry Copper Deposits
Contents
Introduction	1
Geologic Characteristics of Porphyry Copper Deposits	2
  Geologic Setting of the Bristol Bay Watershed	2
  Mineral Resource Potential of the Nushagak and Kvichak Watersheds	2
  General Characteristics of Porphyry Copper Deposits	4
      Geologic Features:	4
      Economic Characteristics:	5
      Geology of Bristol  Bay Porphyry Copper Deposits:	6
      Mining and Beneficiation Considerations:	9
Environmental Characteristics of Porphyry Copper Deposits	10
  Overview	10
  Acid-Generating Potential	10
  Waste Rock	13
  Tailings	17
  Copper Concentrate	22
Summary	24
References Cited	26
Figures
Figure 1.   Generalized geologic map of the central part of the Bristol Bay watershed showing the general locations
of the Pebble, Humble, and Big Chunk prospects	3
Figure 2.   Map showing location of Phanerozoic porphyry deposits with representative deposits labeled	5
                                                   11

-------
                Geologic and Environmental Characteristics of Porphyry Copper Deposits





Figure 3.   Idealized cross section through a porphyry copper deposit showing the relationship of the ore zone to



various alteration types	6



Figure 4.   Grade-tonnage characteristics of the Pebble deposit compared to other porphyry-type deposits	8



Figure 5.   Plot of neutralizing potential (NP) and acid-generating potential (AP) for mineralized rock types at the



Bingham Canyon porphyry copper deposit, Utah	11



Figure 6.   Plan view of the distribution of net-neutralization potential (NNP) values at the Bingham Canyon porphyry



copper deposit, Utah	12



Figure 7.   Dissolved copper concentrations and water hardness values for various potential end-member waters



around the Pebble site in the Bristol Bay watershed associated with waste-rock piles	16



Figure 8.   Dissolved copper concentrations and water hardness values for various potential end-member waters



around the Pebble site in the Bristol Bay watershed associated with a tailings impoundment	22








Tables




Table 1.    Deposit types with significant resource potential for large scale mining in the Nushagak and Kvichak



watersheds	4



Table 2.    Global grade and tonnage summary statistics for porphyry copper deposits (n = 256; Model 17, Singer



and others, 2008) compared to the Pebble deposit	7



Table 3.    Annual consumption of copper, molybdenum and gold compared to the Pebble deposit	7



Table 4.    Summary of geochemical results from humidity-cell tests on waste-rock samples conducted by the



Pebble Partnership (2011)	15



Tables.    Geochemical composition of porphyry copper tailing samples	18



Table 6.    Geochemical composition of test tailings samples from the Pebble deposit from metallurgical testing



conducted by the Pebble Partnership	19
                                                   in

-------
                Geologic and Environmental Characteristics of Porphyry Copper Deposits





Table 7.    Summary of geochemical results from humidity-cell tests on tailing samples and the supernatant solution



from metallurgical testing conducted by the Pebble Partnership	21



Table 8.    Geochemical analysis of the copper concentrate from the Aitik porphyry copper mine, Sweden	23



Table 9.    Geochemical analyses of dissolved constituents in leachates from tailings and copper concentrate from



the Aitik Mine, Sweden	25
                                                  IV

-------
              Geologic and Environmental Characteristics of Porphyry Copper Deposits
Geologic and Environmental Characteristics of Porphyry

Copper Deposits with Emphasis on  Potential  Future

Development in  the Bristol Bay Watershed, Alaska
By Robert R. Seal, II
   US Geological Survey
   954 National Center
   12201 Sunrise Valley Drive
   Reston,VA20192


Introduction

   This report is prepared in cooperation with the Bristol Bay Watershed Assessment being conducted by the U.S.
Environmental Protection Agency. The goal of the assessment is to help understand how future large-scale
development in this watershed may affect water quality and the salmon fishery. Mining has been identified as a
potential source of future large scale development in the region, especially because of the advanced stage of
activity at the Pebble prospect.  The goal of this report is to summarize the geologic and environmental
characteristics of porphyry copper deposits in general, largely on the basis of literature review.  Data reported in the
Pebble Project Environmental Baseline Document, released by the Pebble Limited Partnership in 2011, are used to
enhance the relevance of this report to the Bristol Bay watershed.
   The geologic characteristics of mineral deposits are paramount to determining their geochemical signatures in
the environment.  The geologic characteristics of mineral deposits are reflected in the mineralogy of the
mineralization and alteration assemblages; geochemical associations of elements, including the commodities being
sought; the grade and tonnage of the deposit; the likely mining and ore-processing methods used; the
environmental attributes of the deposit, such as acid-generating and acid-neutralizing potentials of geologic
materials;  and the susceptibility of the surrounding ecosystem to various stressors related to the deposit and  its
mining, among other features (Seal and Hammarstrom, 2003). Within the Bristol Bay watershed, or more
specifically the Nushagak and Kvichak watersheds, the geologic setting is permissive for the occurrence of several
mineral deposit types that are amenable for large-scale development.  Of these deposit types, porphyry copper
deposits (e.g., Pebble) and intrusion-related gold deposits (e.g., Shotgun) are the most important on the basis of
the current maturity of exploration activities by the mining industry. The Pebble deposit sits astride the drainage
divide between the Nushagak and Kvichak watersheds, whereas the Humble, Big Chunk, and Shotgun deposits
are within the Nushagak watershed. The Humble and Big Chunk prospects are geophysical anomalies that exhibit
some characteristics similar to those found at Pebble. Humble was drilled previously in 1958 and 1959 as an  iron
prospect on the basis of an airborne magnetic anomaly. Humble is approximately 85 miles  (137 km) west of

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               Geologic and Environmental Characteristics of Porphyry Copper Deposits


Pebble; Big Chunk is approximately 30 miles (48 km) north-northwest of Pebble; and Shotgun is approximately 110
miles (177 km) northwest of Pebble.  The H and D Block prospects, west of Pebble, represent additional porphyry
copper exploration targets in the watershed.
Geologic Characteristics of Porphyry Copper Deposits

Geologic Setting of the Bristol Bay Watershed
    The Nushagak and Kvichak watersheds are characterized by a complex geologic history. The history, going
back at least 100 million years, has been dominated by northward movement and subduction of the oceanic crust
beneath the Alaskan continental landmass, which continues today. The northward subduction of oceanic crust led
to the accretion of island land masses to the Alaskan mainland.  The divide between the Nushagak and Kvichak
watersheds is near the geologic boundary between the Peninsular Terrane to the southeast and the  Kahiltna
Terrane to the northwest (Decker and others,  1994; Nokleberg and others,  1994). The Peninsular Terrane consists
of Permian limestone, Triassic limestone, chert, and volcanic rocks, Jurassic volcanic and plutonic rocks, and
Jurassic to Cretaceous clastic sedimentary rocks.
    The Pebble porphyry copper deposit and the Humble and Big Chunk prospects are located within the southern
Kahiltna Terrane  (Fig. 1). The southern Kahiltna Terrane consists of a deformed sequence of Triassic to Jurassic
basalt, andesite, tuff, chert, and minor limestone of the Chilikadrotna Greenstone, which is overlain by the Jurassic
to Cretaceous Koksetna River sequence  comprising turbiditic sandstones, siltstone, and shales (Wallace and
others, 1989).  The area was intruded by Cretaceous to Tertiary plutons, which include those associated with the
Pebble deposit. The area also was partially covered by Tertiary to Quaternary volcanic rocks and varying
thicknesses of glacial deposits  (Detterman and Reed, 1980; Bouley and others,  1995).
    The underlying geology can exert a significant influence on water chemistry, and therefore the possible toxicity
of trace elements to aquatic organisms. The presence or absence of carbonate minerals and pyrite is the most
significant influences on water chemistry  in terms of pH, hardness, and alkalinity. Carbonate minerals such as
calcite - the main constituent of limestone - can raise the pH and  increase water hardness and alkalinity.
Limestone, dolomite, and siltstone with abundant calcareous concretions are the most common hosts of carbonate
minerals and are most abundant in Kvichak watershed in the vicinity of Lake Clark (Detterman and Reed, 1980;
Bouley and others, 1995). Pyrite, a potential source of acid, can be a minor constituent of turbiditic sediments such
those found in the Koksetna River sequence, northeast of Pebble. Hydrothermal activity associated  with the
formation of mineral deposits, discussed  below, also can introduce significant amounts of both pyrite and carbonate
minerals.
Mineral Resource Potential of the Nushagak and Kvichak Watersheds

    The geologic setting of the Nushagak and Kvichak watersheds has characteristics that indicate that the region
is favorable for several different mineral-deposit types (Schmidt and others, 2007).  These deposit types include
porphyry copper deposits, copper and iron skarn deposits, intrusion-related gold deposits, tin greisen deposits,
epithermal gold-silver vein deposits, hot spring mercury deposits, placer gold deposits, and sand and gravel
deposits (Table 1).  Of these deposit types, porphyry copper deposits and intrusion-related gold deposits are
represented by current prospects within the area that could prompt large-scale development. Copper skarn
deposits hold less potential, in the absence of infrastructure from other mine development in the region, because of
their typical smaller size (John and others, 2010).  Significant exploration activity associated  with porphyry copper

-------
                                                                                            m»iK       ••-••;-.iV",   ,    /..,£•
                           lJM4! KX&iHcnlirr niJut, culnuloi
                                                                V.it«jtjiic. ml


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                                                                                                    TTDC
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TIU&JL. _Lnl&: uxjkt


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                                                           Jl   Tilknfo FiumUkB ini lAcr nikMik nuia
                                                                                                          FJ , "jlni.-.ii. i:
Figure 1.  Generalized geologic map of the central part of the Bristol Bay watershed showing the general locations of the Pebble, Humble, and Big
Chunk prospects.  Adapted from Wilson and others (2006).  Map was made by Keith Labay (USGS).

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


deposits is currently being done at the Pebble prospect, and to a lesser extent the Humble and Big Chunk
prospects. Several other porphyry copper prospects are immediately adjacent to Pebble, including the H Block and
D Block prospects. Although the Humble (also known as Kemuk Mountain) prospect is currently being promoted
as a porphyry copper target (http://www.millrockresources.com/projects/humble/), the initial exploration (1957 -
1959) identified significant iron and titanium resources in a mafic intrusive complex (ALS Chemex, 2008).  Notable
exploration also is being done in the watershed at several gold properties including Shotgun, Kisa, and Bonanza
Hills.

    The Pebble deposit is the most advanced among the mining prospects in the Bristol Bay watershed in terms of
exploration and progress towards the submission of mine permit applications.  Therefore, the potential for large-
scale mining development within the watershed in the near future is greatest for porphyry copper deposits.
Accordingly, the remainder of the report will focus exclusively on this deposit type - porphyry copper deposits.
Table 1.  Deposit types with significant resource potential for large-scale mining in the Nushagak and Kvichak
watersheds.
Deposit type
Porphyry copper
Commodities
Cu, Mo, Au,
Ag
Examples
Pebble, Big Chunk,
Kijik River
References
Schmidt and others (2007); Bouley
and others (1995)
Intrusion-related gold           Au, Ag
Copper(-iron-gold) skarn        Cu, Au, Fe
Shotgun/Winchester,   Schmidt and others (2007);
Kisa, Bonanza Hills    Rombach and Newberry (2001)

Kasna Creek, Lake    Schmidt and others (2007),
Clark Cu, Iliamna      Newberry and others (1997)
Fe, Lake Clark
General Characteristics of Porphyry Copper Deposits

Geologic Features:
    The geologic characteristics of porphyry copper deposits recently have been reviewed by John and others
(2010), Sinclair (2007), and Seedorff and others (2005).  Therefore, only salient features are summarized here.
Porphyry copper deposits are found around the world, most commonly in areas with active or ancient volcanism
(Fig. 2). The economic viability of porphyry copper deposits is dictated by the economy of scale - they typically are
low grade (average 0.44 % copper in 2008), large tonnage (typically hundreds of millions to billions of metric tonnes
of ore) deposits that are exploited by bulk mining techniques (John and others, 2010).  Because of their large size,
their mine lives typically span decades.
    Primary (hypogene) ore minerals found in porphyry copper deposits  are structurally controlled and genetically
associated with felsic to intermediate composition, porphyritic intrusions that typically were emplaced at shallow
levels in the crust. Mineralization commonly occurs both within the associated intrusions and in the surrounding
wall rocks.  The primary minerals fill veins,  veinlets, stockworks and breccias.  Pyrite (FeS2) is generally the most
abundant sulfide mineral. The main copper-sulfide ore minerals are chalcopyrite (CuFeS2) and bornite (CusFeS^.
A number of other minor copper sulfide minerals are commonly found; most notable from an environmental
perspective is the arsenic-bearing mineral enargite (CusAsS^. Molybdenite (MoS2) is the main molybdenum
mineral.  Gold  in porphyry copper deposits can  be associated in appreciable amounts with bornite, chalcopyrite,

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          Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


and pyrite; the gold may occur as a trace element within these sulfide minerals or as micrometer-scale grains of
native gold (Kesler and others, 2002).
    Hydrothermal mineralization produces hydrothermal alteration haloes that are much larger than the actual ore
deposit. The classic alteration zonation includes a potassium feldspar-biotite rich core, surrounded by a
muscovite/illite sericitic (phyllic) alteration zone, which is surrounded by a clay-rich argillic alteration zone and finally
by a chlorite-epidote rich propylitic zone (Fig. 3; Lowell and Gilbert, 1970). The ore zones generally coincide with
the potassic and sericitic alteration zones.  From  an environmental perspective, the importance of these alteration
types is that the sericitic and argillic alteration tends to destroy the acid-neutralizing potential of the rock, while
enhancing the acid-generating potential through the addition of pyrite.  In contrast, the outer portion of the propylitic
zone tends to have enhanced acid-neutralizing potential due to the introduction of trace amounts of carbonate
minerals.
                                                                      & ^Qonyrat %
       MtPoltey
 —   Valley Copper
 Yerington/Ann-Mason "
         Resol u t io n - O"
           Morenci  -'
 _     ••-.   Cananea
• Sar Cheshmeh>    '/*•"*
                     Chuquicamala ^fc- Toquepala
                     La Escondida  - J&iS" Llallagua
                      El Salvador
                        Refugic
                                          Phanerozoic Igneous Provinces      „  n   , „
                                          Porphyry Deposit                  2'5UO  5^UOU

  Figure 2. Map showing location of Phanerozoic porphyry deposits with representative deposits labeled.
  Modified from Seedorff and others (2005) and John and others (2010).

    Supergene (weathering) processes, which occur long after the initial hydrothermal mineralizing events, can
lead to zones of supergene enrichment near the tops of these deposits (John and others, 2010).  The supergene
enrichment zones can be either oxide- or sulfide-dominated depending on the prevailing oxidation state at the site
of formation, the depth of the water table, and climate.  Mined material from the oxide enrichment zone is amenable
to a heap-leaching method of ore processing known as "solvent-extraction - electrowinning" (SX-EW; Jergensen,
1999). However, supergene ores are likely to be minor in Alaska due to recent glaciation.
    Porphyry copper deposits can be divided into three subtypes on the basis of Au (g/t)/Mo (%) ratios:  porphyry
Cu, porphyry Cu-Mo, and porphyry Cu-Au deposits, where Cu-Au deposits have Au/Mo ratios greater than or equal
to 30, Cu-Mo deposits have Au/Mo ratios less than or equal to 3, and Cu deposits are all other deposits not within
these bounds (Sinclair, 2007; Singer and others,  2008). On the basis of these criteria, the Pebble deposit would be
classified as a porphyry Cu deposit.

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


Economic Characteristics:
    Porphyry copper deposits are important sources of copper, molybdenum, gold, and silver; they also can supply
significant amounts of byproduct rhenium, tellurium, and platinum-group metals.  Porphyry copper deposits supply
over 60 percent of the copper for global copper production and together with porphyry molybdenum deposits,
account for over 95 percent of the molybdenum production (Sinclair, 2007; John and others, 2010).  In 2010, the
United States consumed 1,730,000 tonnes of copper,  of which 30 percent was imported, chiefly from Chile,
Canada, and Peru. In the same year, the United States consumed  48,000 tonnes of molybdenum, and was a net
exporter.  In  2010, the United States consumed 380 tonnes of gold  of which 33 percent was imported, primarily
from Canada, Mexico, Peru, and Chile. These commodities serve myriad uses (U.S.  Geological Survey, 2011).
Copper is used  primarily in building construction (wiring and pipes; 49 %), electric and electronic products (20 %),
vehicles (12  %), consumer products (10 %), and industrial machinery and equipment (9 %).  Molybdenum is
primarily used as a steel alloy (75 %). Gold is used mainly for jewelry (69 %), and electrical  and electronic products
(9 %).  Silver is  used for a variety of applications including industrial and medical uses, electronics, coins and
silverware, and  photography (albeit a declining application). Rhenium is principally used as  an alloy in turbine
engines (70  %)  and for petroleum refining (20 %).  Tellurium is primarily used as an alloy with steel, iron, and lead,
but increasingly is being used in photovoltaic cells.  Platinum-groups metals (platinum, palladium, rhodium,
ruthenium, iridium, and osmium) principally are  used in vehicle catalytic converters, as catalysts for chemical
manufacturing, in electronics and in emerging applications to fuel cells.
                         ADVANCED
                         ARGILLIC
                          Q-Kaol-Alun
 PERIPHERAL
cp-gal-sl-Au-Ag
PYRITE SHELL
py10%
\ cp.01-3%
X\
\
\
ORE
	 r- SHELL
py1%
cp 1-3%
mb .003%
1
i




EXPLANATION:
Chi - Chlorite
Epi - Epidote
Carb - Carbonate
Q - Quartz
Ser - Serieite
K-feld - Potassium
Feldspar
Bi - Biolile
Anil - Anhydrite
py - pyritc





Kaol - Kaolinite
Alun - Alunite
cp - Copper
gal - Galena
si - Sulfide
Au - Gold
Ag - Silver
mb - molybdenite


       Chl-Ser-Epi-mag
  Figure 3. Idealized cross section through a porphyry copper deposit showing the relationship of the ore zone to
  various alteration types. A. Distribution of alteration types; B. Distribution of ore mineral assemblages. The
  causative intrusion corresponds to the potassic alteration zone.  From John and others (2010) and modified from
  Lowell and Guilbert (1970).

    The grade and tonnage of porphyry copper deposits vary widely (Singer and others, 2008). Summary statistics
compiled for 256 porphyry copper deposits are presented in Table 2 and Figure 4.  For total tonnage of ore, Pebble
is in the upper 5th percentile, lower 50th percentile for copper grade, upper 10th percentile for molybdenum grade,
and upper 10th percentile for gold grade. The amount of metal contained in the Pebble deposit corresponds to a
21-year supply of copper for the  United States, a 53-year supply of molybdenum, and a 9-year supply of gold,
based on 2010 consumption statistics (Table 3). From the perspective of future discoveries in the watershed, it is

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


therefore highly unlikely that new deposits will approach the size of Pebble, but instead will be considerably
smaller.

Geology of Bristol Bay Porphyry Copper Deposits:
    Several porphyry copper prospects within the Bristol Bay watershed are being explored, and include Pebble,
Humble, and Big Chunk. The Pebble deposit is the only one with a significant published description of its geology
(Bouley and others, 1995; Kelley and others, 2010).  The deposit is controlled by the Pebble Limited Partnership -
a joint venture between Northern Dynasty Minerals, Ltd., and Anglo American. The Pebble deposit may be viewed
as consisting of two contiguous ore bodies: Pebble West and Pebble East, with the buried Pebble East having the
higher ore grades.  Pebble West was discovered in 1989 at the surface, and delineation drilling in 2005 resulted in
discovery of Pebble East beneath a 300 to 600 m thick cover of Tertiary volcanic rocks. The  deposit has been
explored  extensively with more than  1,150 drill holes that total greater than 949,000 feet (289,250 m) (Northern
Dynasty Minerals, 2011).

Table 2.  Global grade and tonnage summary statistics for porphyry copper deposits (n = 256; Model 17, Singer
and others, 2008) compared to the Pebble deposit.
Parameter
Tonnage (Mt)
Cu grade (%)
Mo grade (%)
Ag grade (g/t)
Au grade (g/t)
10th Percent! le
1,400
0.73
0.023
3.0
0.20
50th Percent! le
250
0.44
0.004
0.0
0.0
90th Percent! le
30
0.26
0.0
0.0
0.0
Pebble1
10,777
0.34
0.023
unknown
0.31
Sources: 1PLP (0.3 % Cu cut-off grade), includes measured, indicated, and inferred resources (http://www.pebblepartnership.com/)
Table 3. Annual consumption of copper, molybdenum and gold compared to the Pebble deposit.
Commodity
Copper (tonnes)
Molybdenum (tonnes)
Gold (tonnes)
US Annual Consumption (201 0)1
1,730,000
48,000
380
Pebble Resource2
36,636,364
2,531,818
3,337
Years of 2010
Consumption
21
53
9
Sources: 1U.S. Geological Survey (2011); 2PLP (0.3 % Cu cut-off grade), includes measured, indicated, and inferred resources
(http://www.pebblepartnership.com/)


    The oldest rocks in the vicinity of the deposit are Jurassic to Cretaceous (ca. 150 Ma) clastic sedimentary rocks
(i.e., mudstone, siltstone, and sandstone), which were intruded by dominantly granitic plutons from 100 to 90 Ma;
granodiorite stocks and sills,  spatially and  genetically related to the Cu-Au-Mo mineralization, were intruded about
90 Ma (Kelley and others, 2010). Intrusion of these granodiorite bodies resulted in hydrothermal activity that
produced the mineralization and associated alteration of the intrusions and surrounding rocks. The Pebble West
deposit extends from the surface to a depth of about 500 m and encompasses roughly 6 square kilometers on the
surface. Pebble East is covered by a wedge of post-mineralization Tertiary volcanic rocks that exceeds 600 m in
thickness towards the east.  The eastern end  of the deposit is truncated by a high-angle fault that offsets the
deposit 600 to 900 m down to the east (Kelley and  others, 2010). Early copper mineralization was dominated by

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


pyrite, chalcopyrite, and  gold, which was overprinted by pyrite, bornite, digenite, covellite, and minor enargite,
followed by quartz-molybdenite veinlets (Bouley and others, 1995; Kelley and others, 2010).
                          ZJ
                          O
                              10.0
                               1.0
                               0.1
                              0.01
                               1.0
                               0.1
                              0.01
                             0.001
                                    i Cu
                                    1 Cu-Mo
                                    i Cu-Au
                                                              Butte.
       • •>.       \M •/ B'r9nam
   . m,M^i*mf,  lll^l'ji ** *  EIT<
   iwsajgM-    -.
                K* "_1  . \
                 Chuquicamata

l"S*S^" ".1  .\  UPebbk
.' . / '',,   Highland \
               Island \
               Copper k.
                                          10       100     1,000    10.000   100,000
                                                  Tonnage (106t)
                            0.0001
                                    'Cu
                                    ' Cu-Mo
                                    i Cu-Au
                             \  (b
                                                         \
          i V       '•-,.      \      -
           . >v • i   • • *~
           • \ j', %   m Bingham  El lenient
                                              •V ^***J""L  •"     ^Pebb-
                                        \N •     ^ -f   Tm P*--     *  ''•• Chuquicamats
                                      \

               'Island
               Copper
            \
                                           V
                                  1        10       100     1.000    10,000   100,000
                                                  Tonnage (1Q6t)
                          S
                          D
                              10.0
                               1.0
                               0.1
                              0.01
                                    i Cu
                                    ' Cu-Mo
                                    i Cu-Au
                            \  ©
                               V
                                \
-.  . .    . .   ' . \ 7   Bingham  Pebble''-.?o
          \-f'{ N  '     \      ^
       .   '•--,  .r
                                                '•- "Huckleberry'-. ,
                                                 \*      '••»
                                          10       100     1.000    10.000   100,000
                                                  Tonnage (106t)
  Figure 4. Grade-tonnage characteristics of the Pebble deposit compared to other porphyry-type deposits. A.
  Copper; B. Molybdenum; C. Gold.  The Pebble deposit is shown as the yellow star. Selected, noteworthy
  deposits are labeled. Pebble is classified as a porphyry Cu deposit (red squares). The dashed diagonal lines
  represent the total contained metal. Modified from Sinclair (2007).

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


    Geologic information on the Humble prospect (also known as Kemuk) is limited to the details found on the
Millrock Resources, Inc. website (http://www.millrockresources.com/projects/huinble/).  The prospect is covered by
glacio-fluvial gravels and sands 30 to greater than 140 m thick. The site was identified on the basis of the presence
of an airborne geophysical (magnetic) anomaly and the presence of igneous rocks similar to those found at Pebble.
The Humble Oil Company drilled the property in 1958 and 1959 as an iron prospect.  No mention is made of Cu-
Au-Mo mineralization from the 1950s drilling, and there are no recent data available.  Information on the Big Chunk
Super project is limited to details on the Liberty Star Uranium and Metals Corporation website
(http://www.libertystaruranium.com/www/projects/big-chunk-super-project). Current exploration efforts are focused
on six to seven airborne electromagnetic geophysical anomalies from data collected in 2009 that are consistent
with porphyry-style mineralization.  Although exploratory drilling is mentioned on the web site, no results are
discussed.

Mining and Beneficiation Considerations:
    Mining  and ore-processing methods can vary based on whether or not parts of the ore are weathered, and on
the commodities being extracted. Due to their large size  and low grades, porphyry copper deposits are mined by
bulk mining methods such as open-pit mining  for deposits near the surface, and block caving for deposits at depth.
Because the copper ore grades are generally  less than 2 percent, greater than 98 percent of the material mined
ends up as waste.  The beneficiation of the ore is distinctly different between  hypogene (primary) sulfide ores and
supergene  (secondary) oxide ores.  Mining begins with the removal of waste  rock, which may or may not be acid-
generating.  Country rocks that host the mineralization are commonly acid-generating  due to the presence of
hydrothermal pyrite formed during the mineralizing event.  These rocks may be classified as subeconomic ore and
may be stockpiled separately from barren waste rock.  The processing of subeconomic ore commonly is prompted
by either an increase in metal prices making the material  economically viable, or if a high-grade zone is
encountered during mining, the subeconomic  ore may be mixed with high-grade ore to ensure that an optimal
grade of material is being fed to the mill. In  either case, subeconomic ore generally is handled  in a similar fashion
to that of waste rock during mine operations because of its acid-generating potential.
    The primary (hypogene) sulfide ore is crushed to sand or silt size prior to ore-concentrate separation using the
froth flotation method (Fuerstenau and others, 2007). For porphyry copper deposits, such  as Pebble, separate
concentrates for copper and molybdenum generally are produced.  The gold in porphyry copper deposits can be
partitioned variably among the copper-sulfide  minerals (chalcopyrite, bornite,  chalcocite, digenite, and covellite),
pyrite, and free gold (Kesler and others, 2002). Gold associated with the copper minerals remains with the copper
concentrate and is recovered at an off-site smelter. Gold associated with pyrite will end up in the tailings, unless a
separate pyrite concentrate is produced.  Pyrite concentrates can be produced during  froth flotation for the recovery
of gold or to more effectively manage the  high acid-generating potential of this material. Gold commonly is
recovered by cyanidation, but gold recovery from sulfide-rich material is poor (Marsden and House, 2006).  To
improve gold recovery, pyritic material typically is oxidized by various means  including high-temperature
(pyrometallurgical) roasting; low-temperature,  pressurized autoclaving; or bio-oxidation using bacteria. Following
oxidation, the material then is leached with cyanide, usually in a vat to recover gold (Marsden and House, 2006).
The resulting spent iron oxides generally are disposed with the tailings.  Autoclaving is probably the most likely
option in southwest Alaska because cyanide can be managed effectively in a vat-leaching operation.  High-
temperature roasting is energy intensive and presents additional challenges with respect to stack emissions.
Bioleaching may be more difficult because of the cold climate and slow biotic oxidation rates at lower temperatures.
    Tellurium generally is recovered from the  copper anode slimes at the refinery (John and others, 2010).
Rhenium is recovered as a byproduct of the roasting of the molybdenum concentrate at the refinery (U.S.
Geological  Survey, 2011). The platinum-group metals generally are associated with copper concentrates (Tarkian

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


and Stribrny, 1999) and thus, would not be recovered on site at Pebble. Therefore, the recovery of tellurium and
platinum-group metals from Pebble or other porphyry copper deposits in the watershed would likely be an activity
conducted off-site when ore concentrates are further processed.
    Supergene (secondary) oxide ores commonly are beneficiated using a heap-leach method known as solvent
extraction-electrowinning (SX-EW). This process involves placing coarsely crushed ore on a lined pad and
applying sulfuric acid to leach copper from the ore.  The pregnant leach solution is collected and the copper is
removed from the leachate electrolytically (Jergensen, 1999).  The supergene enrichment zone at Pebble is poorly
developed and dominated by the secondary copper sulfide minerals covellite (CuS), digenite (Cui-xS), and
chalcocite (Cu2S), in part due to recent glaciation (Bouley and others,  1995). Therefore, processing of oxide ore is
unlikely at Pebble or geologically similar deposits within the watershed.
Environmental Characteristics of Porphyry Copper Deposits

Overview
    Porphyry copper deposits can pose geochemical risks to aquatic and terrestrial ecosystems, and to human
health. The risks can range from nil to significant and depend upon a variety of factors.  Factors that influence the
environmental characteristics of mineral deposits range from geologic setting (both local and regional), hydrologic
setting, climatic settings, and mining methods, to ore beneficiation methods.  The sources of the risk can be
considered in the broad categories of acid-generating potential, trace element associations, mining and ore
beneficiation methods, and waste disposal practices. The significance of these sources of risk will vary from
deposit to deposit, but some generalizations can be made for porphyry copper deposits as a whole.


Acid-Generating Potential
    Acid generation can be considered a "master variable" for aqueous risks.  Metals and other cations are more
soluble at low pH than at neutral or high pH. Therefore, the acid-generating or acid-neutralizing potentials of the
waste rock, tailings, and mine walls are of prime importance in identifying the potential environmental risks
associated with mining and ore beneficiation.
    The acid-generating or acid-neutralizing character of a rock or mine waste material is evaluated  in terms of an
"acid-base account". Acid-base accounting uses static tests to assess maximum acid-generating potential. Static
tests are based on  a single analysis of waste material and therefore are independent of rates of reactions.  In
contrast to static tests, kinetic tests expose mine waste samples for weeks, months, or years. Most proposed
mining projects take a staged approach to evaluating acid-generating potential starting with acid-base accounting
data to screen  numerous samples, which are followed by  the more laborious kinetic testing process on fewer,
carefully selected samples.
    The acid-generating potential of rocks and mine waste samples can be evaluated using a variety of techniques
(Price, 2009; I NAP, 2011).  In North America, one of the most common techniques investigates the difference or
ratio of the acid-generating and acid-neutralizing potential of the sample.  Theoretically, a sample with an acid-
neutralizing potential (NP) equal to its acid-generating potential (AP) is "net neutral", meaning that its acid-
neutralizing potential (NP) should theoretically cancel (or neutralize) its acid-generating potential (AP).
Numerically,  this is expressed as a "net neutralizing potential" (NNP) of zero, where

                                            NNP = NP-AP
                                                  10

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


Values for AP, NP, and NNP are typically expressed in the units of kilograms of calcium carbonate per tonne of
waste material (kg CaCOs/t), such that the amount of calcium carbonate amendment that would be  needed to
achieve "net neutrality" is readily apparent.  The AP values are generally based on an analysis of the sulfide-sulfur
content of the sample, and the NP values are based on either an analysis of the carbonate content of the sample or
by leaching of the sample followed by a wet chemical titration of the resulting leachate.  NNP values that are
greater than zero have theoretical acid-neutralizing  potential present in excess of acid-generating potential and
those below zero have theoretical acid-generating potential present in excess of acid-neutralizing potential.
Alternatively, the acid-base account of a sample also can be expressed in terms of its neutralizing potential ratio
(NPR), which is simply the ratio of its NP to its AP:

                                              NPR= NP/AP

Thus, a sample with a NPR equal to one is  net neutral, greater than one has theoretical acid-neutralizing potential
exceeding acid-generating potential, and less than one has theoretical acid-generating  potential exceeding acid-
neutralizing potential.  Current industry standards generally divide rocks and mine waste samples into three distinct
categories based on the NPR values:  potentially acidic drainage generating (PAG) for NPR less than 1;  uncertain
(possibly) acidic drainage generating for NPR between 1 and 2; and non-potentially acidic drainage generating
(non-PAG) greater than 2 (INAP, 2011).  Note that the requirement that non-PAG material have a NPR value
greater than 2 represents twice the amount of alkalinity needed for net neutrality under  equilibrium conditions.  In
practice,  kinetic considerations are important, which is why a NPR greater than 2  is desirable. However, no
universal consensus exists on the NPR value required to ensure no acid generation; recommended values range
from 1  to 4 (White and others, 1999).  The NPR is typically used as a screening tool and mine-waste management
decisions will be based on  more extensive characterization using additional techniques (Price, 2009).
    The rocks associated with porphyry copper deposits, in general, tend to straddle the boundary between having
net acid-generating potential and not having net acid-generating potential. This aspect is illustrated well  by the
study of Borden (2003) on  the Bingham Canyon porphyry copper deposit in Utah  (Figures 5 and 6), which shares
many similar geologic features with the Pebble deposit.  The AP values for porphyry copper deposits approximately
reflect the distribution of pyrite.  The distribution of acid-generating and non-acid-generating material in plan view at
the Bingham mine matches well with the idealized cross section of porphyry copper deposits shown in Figure  3B.
The pyrite-poor, low-grade core corresponds to the  central part of the Bingham Canyon deposit where NNP values
are greater than 0. The progression out to the  ore shell and pyrite shell with their increasing abundance of pyrite in
these areas  is reflected in the progressively more negative NNP values.
    During mining of porphyry copper deposits, a variety of materials with differing NNP values may be
encountered. The low NNP,  largely barren  pyrite shell  likely represents waste rock that may need to be removed to
access the ore (Fig. 3B). The boundary  between the ore shell and the pyrite shell is cryptic and typically is defined
operationally on the basis of a cut-off copper grade.  Therefore, some of the "waste" material with significant,
subeconomic copper grades  could be stockpiled for potential future beneficiation.  The  intrusions that produce
porphyry copper deposits can intrude  any rock type. Therefore, the NNP values of the  country  rock of
undiscovered deposits cannot be predicted reliably.  Likewise, geologic events following ore formation could
juxtapose a variety of rock types against an ore deposit, which can have a range of NNP values. In the case of
Pebble, subsequent volcanic activity after mineralization covered the eastern part of the deposit with material that
has limited acid-generating potential (Kelley and others, 2010; Pebble Partnership, 2011).
    The mining method will influence the amount of waste rock removed.  Open pit mining can  require the removal
of large volumes of potentially acid-generating  material. A waste-to-ore ratio  of 2:1, meaning that two tonnes of
waste are removed for each tonne of ore mined, is not  uncommon for porphyry copper  deposits (Porter and
Bleiwas,  2003).  Underground block caving of ore requires that a shaft or decline be sunk to facilitate mining.  The


                                                   11

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


amount of waste rock removed for block caving is much less than that removed in a typical open pit operation.  In
the specific case of Pebble, the volcanic rocks overlaying Pebble East have limited amounts of pyrite and are
generally classified as non-PAG material, which would not require special handling to mitigate acidic drainage
(Pebble Partnership, 2011). In fact, this material could be used for a variety of construction projects on site (e.g.,
road fill, tailings dam construction).  In contrast, the Pre-Tertiary rocks at Pebble are generally classified as PAG,
with some samples having uncertain potential for generating acid and fewer with no potential for generating acid
(non-PAG).  During mining, some of this rock will be waste rock removed to access the ore, and some of it will be
ore that will be processed to extract mineral concentrates.

                   1,000
-»-
0
Q
                  I
                  Q.
                  -z.
-i
0
i
                                                      Uncertain
                                     m
                                    non-PAG
                                       +
                                                                      PAG
                                                    +  •
                               a '
                              »*•
                                                        +
              "
              -I-
                                                          -\—H-
10                 100
   AP (kg CaCO3/t)
                                                                                  ,000
  Figure 5.  Plot of neutralizing potential (NP) and acid-generating potential  (AP) for mineralized rock types at the
  Bingham Canyon porphyry copper deposit, Utah. Modified from Borden (2003).


    The most profound influence that beneficiation of ore can have on mine tailings derived from froth flotation
centers on the fate of pyrite (Fuerstenau and others, 2007).  At many porphyry copper mines, the pyrite is
discharged with the waste tailings, thereby contributing to the acid-generating potential of the tailings.  However,
the option exists to produce a pyrite concentrate to manage more effectively the acid-generation risks associated
with tailings, to extract gold associated with the pyrite, or both. The production of a pyrite concentrate will decrease
the acid-generating potential  of the tailings.

Waste Rock
    Waste rock associated with porphyry copper deposits reflects the geologic history of the deposit. Because
porphyry copper deposits are associated with igneous rocks intruded into shallow levels of the Earth's crust, the
geochemical properties of the country rocks can vary widely, particularly in terms of their acid-base accounting
properties and their trace element compositions. The hydrothermal activity that forms the ore deposits introduces
                                                   12

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


sulfur, which commonly forms sulfide minerals such as pyrite, and a variety of trace elements. Introduced sulfur
may also occur as the sulfate minerals anhydrite (CaS04), or barite (BaSCU), which are environmentally benign
with respect to acid-generating potential.  In fact, for acid-base accounting, the portion of sulfur that occurs as
sulfate should be subtracted from the total amount of sulfur present to accurately estimate acid-generating potential
(Price,  2009). The hydrothermal alteration haloes around these deposits are significantly more extensive than the
ores themselves (Fig. 3) and commonly represent waste rock with significant associated environmental risks.
Rocks that form after the mineralization event, and not affected by supergene processes, are devoid of these
hydrothermal overprints of sulfur and trace elements.
                          NNP(kgCaCCVt)

                         I     I >0
                         Q^| Oto-25
                         |     | -25 to-50
                         ^H <-50
500 m
  Figure 6. Plan view of the distribution of net neutralizinig potential (NNP) values at the Bingham Canyon
  porphyry copper deposit, Utah.  NNP values above zero are "net alkaline"; those below zero are "net acid".
  Modified from Borden (2003).
    An early step in mining is to remove the waste rock to access the ore. For open pit mines, waste to ore
(stripping) ratios commonly can exceed 2:1 (Porter and Bleiwas, 2003). As discussed in the previous section, the
acid-generating potential of the waste rock can span the range from potentially acid-drainage generating (PAG) to
non-PAG. The ability of leachate generated from waste rock to mobilize metals and oxyanions will vary, depending
in part, on the pH of the resulting solution, which largely is a function of the pyrite content of the waste rock.
    The primary environmental concerns associated with waste rock are due to the oxidation of waste-rock
material, which may result in contamination of either groundwater or surface water. The oxidation of sulfide
minerals such as pyrite produces sulfuric acid, which then can dissolve metals and related elements from
associated sulfide,  silicate, and carbonate minerals.  The magnitude of this risk will depend upon waste
management practices and whether or not drainage  is treated.
                                                   13

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


    The geochemical characteristics of waste-rock dump drainage have been investigated by several studies.  Day
and Rees (2006) conducted a study of dump seepage associated with several operating or recently closed
porphyry copper and porphyry molybdenum mines in British Columbia, many of which are located in the Fraser
River watershed. Porphyry copper mines included in their study were Gibraltar, Huckleberry,  Island  Copper, and
Mount Polley; the data from Huckleberry were from  laboratory column tests only. These deposits fell into two
groups: those that produced low pH drainage and those that did not.  The pH of waste-dump  drainage from
Gibraltar and Huckleberry ranged from  neutral down to approximately 2, whereas drainage from Island Copper only
reached a low of approximately 4.5. In  contrast, the pH of waste-rock drainage at Mount Polley ranged between 7
and 8.5.  The concentrations of sulfate and metals were negatively correlated with pH. The maximum
concentrations of sulfate (<30,000 mg/L), Al (< 1,000 mg/L), Mn (< 100 mg/L),  and Cu (< 1,000 mg/L) were all
highest from Gibraltar; the highest concentrations of Zn (< 100 mg/L) were found in the Huckleberry column tests
(Day and Rees, 2006).  For comparison, Lister and  others (1993) found that 41 percent of the NPR  values for
waste rock at Island Copper were below 1, 23 percent were between 1 and 3, and 36 percent were  above 3, which
is consistent with the range of pH values, from 4.5 to 8, observed by Day and Rees (2003). Khorasanipour and
others (2011) found similar geochemical trends,  but in a more arid environment, for drainage  associated with
waste-rock dumps at the Sarcheshmeh mine in southeastern  Iran. The pH ranged between 3.1 and 6.3, specific
conductance between 0.72 and 2.25 mS/cm, sulfate between  365 and 1,590 mg/L, Al between < 0.05 and 60 mg/L,
Mn between 14.6 and 95.8 mg/L, Cu between 2.15  and 70 mg/L, and Zn  between 2.4 and 27.4 mg/L.
    In the vicinity of the proposed Pebble mine, the best insights into the potential behavior of waste rock come
from the humidity-cell tests being conducted  by the  Pebble Limited Partnership and its contractors (Pebble
Partnership, 2011).  Management of waste rock  during mine operation typically involves  placing waste rock in
subaerial piles on site. This configuration is similar  to the conditions of humidity-cell tests where samples are
exposed to a weathering protocol under unsaturated conditions (Price, 2009).  Standard  procedures for humidity-
cell tests require that rock be crushed to less than 6 mm, placed in cylinders, cycled through moist and dry air for
six days, and leached on the seventh day, all at  room temperature. This  requirement produces a material that  has
significantly more surface area than waste rock produced during mining, which makes the test material more
reactive than the actual material.  As such, this approach does not incorporate the temperature and precipitation
variations encountered on site, or the heterogeneous grain size of typical waste rock. "Barrel" kinetic tests were
conducted also, where rather than weathering samples in the  laboratory,  larger volumes of material were placed in
barrels in the field and the samples were exposed to site conditions. The goal of barrel testing is to scale-up
laboratory results to conditions that are more representative of the site in terms of amount and seasonality of
precipitation and temperature variations.  The barrel test results are only  discussed on a limited basis in this report.
However, despite these caveats, the humidity-cell results presented by the  Pebble Partnership (2011) provide
relevant information.
    Pebble Partnership (2011) has divided material at the site into several different groups, for both Pebble West
and Pebble East: Pre-Tertiary sedimentary and  volcano-sedimentary units,  Pre-Tertiary plutonic units, and Tertiary
volcanic units.  In general, results from the Pre-Tertiary rocks  from Pebble West and Pebble East were not
significantly different. The Pre-Tertiary rocks were present at  the time of mineralization and therefore have the
potential to be significantly mineralized. The Tertiary volcanic rocks were deposited after mineralization, and
therefore should have limited concentrations of sulfide minerals to serve as a sources of acidity and dissolved
metals.
    The results of the Pebble Partnership (2011) humidity-cell tests are summarized in Table 4.  Table 4 presents
the mean composition  of leachate from these a number of individual tests divided into three groups: Tertiary rocks,
hydrothermally altered Pre-Tertiary rocks (undifferentiated) from Pebble West, and hydrothermally altered Pre-
Tertiary rocks (undifferentiated) from Pebble  East. The results from the variety of Pre-Tertiary rock  types were
                                                   14

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


grouped together here with the assumption that individual waste-rock types would not be selectively removed
during mining. Individual humidity-cell tests can show a range of leachate concentrations that vary over the course
of the experiment.  In general, the concentrations of dissolved constituents are most erratic and highest during the
initial flush covering the first few one-week cycles in humidity-cell tests; several weeks after the start of the
experiments, the concentrations of dissolved constituents tend to stabilize. The average release rates  used in
Table 4 obscure this variability, although its  magnitude can be assessed  by the standard deviations presented with
means in Table 4.  The concentration of constituents in the leachate was calculated from the average release rate
data presented by the Pebble Partnership using the formula:

         Concentration (mg/L) = [Release (mg/kg/week) x Mass of Sample (kg)]/Leachate Recovered  (L),

where the average release rate, the mass of the solid sample, and amount of leachate recovered are provided in
the Pebble Partnership (2011) report.  The results from Pebble include a number of parameters (Pebble
Partnership, 2011): pH, conductivity, acidity, alkalinity, total dissolved solids, hardness, F, Cl, SCU, Al, Sb, As, Ba,
Be, Bi,  B, Cd, Ca,  Cr, Co, Cu, Fe, Pb, Mg, Mn,  Hg, Mo, Ni, K, Se, Si02, Ag, Na, Tl,  Sn, V, and Zn. The present
discussion focuses on pH, sulfate, Cu, Mo, As,  and Zn.  The pH of a solution is a master variable that controls the
solubility of most elements. Sulfate is a proxy for pyrite oxidation, which  produces the acid in acid-mine drainage.
Copper is a cationic species,  and the most likely inorganic ecologic stressor expected at the site, especially for
aquatic organisms. Zinc commonly occurs in base-metal hydrothermal systems, but typically not in economic
concentrations in porphyry copper deposits. Arsenic and molybdenum are oxyanion species, which behave
differently from cations; arsenic is a potentially significant stressor, especially with respect to drinking water
contamination, whereas molybdenum is an important ore constituent with less potential to be an environmental
stressor.
       The Pre-Tertiary rocks show a range of responses in the humidity-cell tests as reflected by the significant
standard deviations associated with their  mean leachate concentrations (Table 4).  The leachates from the Pre-
Tertiary rocks are  characterized by neutral to acidic pH values. As expected from the role of pyrite oxidation in acid
generation, the samples that  generated the  lowest pH values had the higher sulfate concentrations and lower
alkalinity values.  For example, the mean  pH for humidity-cell leachates for Pebble  East was 4.8 ± 1.9 compared to
6.6 ± 1.7 for Pebble West, presumably reflecting the higher grade and pyrite content of Pebble East.  The pH of the
samples correlated negatively with the alkalinity of the leachates. Copper concentrations generally correlate with
sulfate concentrations and low pH, as would be expected from the higher solubility  of metals with acidic pH
conditions.  The mean concentrations of copper in humidity-cell  leachates from both Pebble West and Pebble East
were high compared to other metals and exceeded 1 mg/L. The mean zinc concentration  reached 0.5 mg/L. In
contrast, the highest mean molybdenum concentration was less than 0.005 mg/L and the highest mean arsenic
concentration was 0.008 mg/L. The high  standard deviations associated with all parameters in the leachate
chemistry from Pre-Tertiary waste-rock types underscore the challenges  associated with predicting waste-rock
seepage chemistry with a high level of confidence. At an operating mine, the drainage from waste-rock piles will be
a mixture of direct leachates from the waste rock and local ambient surface water and precipitation.  The relative
proportion of these sources will depend upon local climatic conditions, the natural topography, alterations to the
natural topography made during mine construction, and engineering controls put in place during mine construction
to manage surface water. The range of potential compositions of seepage is shown in Figure 7, which  shows
average dissolved copper and hardness values for various waters.  The leachate values associated with the Pebble
East Zone humidity-cell tests (PEZ HCT), the Pebble West Zone humidity-cell tests (PWZ HCT), the Pebble West
Zone Barrel test (PWZ Barrel), and the Tertiary Waster Rock humidity-cell tests are all averages of mean release
rates from individual experiments. The mean values for the North Fork of the Koktuli  River are merely meant to
                                                   15

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


Table 4. Summary of geochemical results from mean humidity-cell tests on waste-rock samples conducted by the
Pebble  Partnership (2011).
Parameter

Pebble
Partnership
(2011) Source
PH
Alkalinity
Hardness
Cl
F
S04
Ag
Al
As
B
Ba
Be
Bi
Ca
Cd
Co
Cr
Cu
Fe
Hg
K
Mg
Mn
Mo
Na
Ni
Pb
Sb
Se
Sn
Tl
V
Zn
Units


S.U.
mg/L CaCOs
mg/L CaCOs
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Tertiary Waste Rock
Mean
Table 11 -31
(calc);
Appendix
11C(pH)
7.2
65.9
74.0
0.53
0.06
28.0
0.000011
0.08
0.0027
0.0177
0.0572
0.0003
0.0005
21.3
0.0002
0.0039
0.0006
0.0032
0.140
0.000010
1.85
5.06
0.1015
0.0063
7.21
0.0044
0.0001
0.0021
0.0019
0.0013
0.00007
0.0018
0.0159
Standard
Deviation
Table 11 -31
(calc);
Appendix 1 1C
(PH)
1.3
51.0
88.1
0.11
0.09
83.8
0.000003
0.21
0.0042
0.0122
0.0824
0.0005
0.0002
31.6
0.0006
0.0157
0.0002
0.0061
0.484
0.000001
2.24
7.49
0.3990
0.0138
12.46
0.0165
0.0002
0.0019
0.0020
0.0015
0.00003
0.0022
0.0500
Pebble West Pre-Tertiary
Waste Rock
Mean
Table 11 -21
(calc);
Appendix 1 1C
(PH)
6.6
18.5
59.2
0.52
0.12
60.8
0.000027
0.32
0.0015
0.0159
0.0136
0.0003
0.0007
12.7
0.0004
0.0070
0.0007
1.5989
1.671
0.000011
1.41
6.69
0.7289
0.0018
2.05
0.0068
0.0002
0.0031
0.0038
0.0001
0.00041
0.0007
0.0556
Standard
Deviation
Table 11 -21
(calc);
Appendix 1 1C
(PH)
1.7
16.4
51.9
0.01
0.12
68.4
0.000044
0.85
0.0018
0.0085
0.0087
0.0003
0.0004
8.9
0.0007
0.0146
0.0004
3.2469
6.042
0.000002
0.72
8.68
1.5653
0.0018
0.03
0.0143
0.0003
0.0018
0.0057
0.0001
0.00098
0.0004
0.1080
Pebble East Pre-Tertiary Waste
Rock
Mean
Table 11 -21
(calc);
Appendix 1 1C
(PH)
4.8
9.9
21.9
0.91
0.11
51.9
0.000019
0.38
0.0080
0.0125
0.0045
0.0006
0.0006
6.3
0.0032
0.0097
0.0016
1.4162
10.195
0.000010
0.96
1.50
0.3386
0.0043
2.07
0.0105
0.0004
0.0008
0.0032
0.0019
0.00009
0.0024
0.4786
Standard
Deviation
Table 11 -21
(calc);
Appendix 1 1C
(PH)
1.9
14.1
23.1
0.91
0.16
52.0
0.000013
0.58
0.0189
0.0052
0.0056
0.0006
0.0003
5.3
0.0083
0.0120
0.0023
2.1609
16.051
0.000001
0.69
3.40
1.0745
0.0070
0.06
0.0168
0.0004
0.0018
0.0024
0.0022
0.00010
0.0056
1.3618
                                               16

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


represent generic, uncontaminated surface water in the vicinity of the Pebble deposit. The triangular field shown in
Figure 7 defined by the composition of the North Fork of the Koktuli River, the average humidity-cell  results from
samples of the Pebble East Zone, and the barrel test results from the Pebble West Zone represent the likely range
of potential surface-water compositions downstream of Pre-Tertiary (i.e., mineralized) waste-rock piles in the
vicinity of the Pebble deposit (mine).  Likewise, the dashed line connecting the average composition of the North
Fork of the Koktuli River and  the average humidity-cell results for Tertiary waste rock represents the likely range of
potential surface-water compositions downstream  of Tertiary (i.e., unmineralized) waste-rock piles in the vicinity of
the Pebble deposit (mine).  The location of the hypothetical compositions either within the triangular  field for those
waters associated with the Pre-Tertiary waste-rock piles or along the join associated with Tertiary waste-rock piles
will depend on the water balance of the contributing drainages and will be influenced by the mine plan.
                     100000 -3
                      10000
CUO
3-  1000
OJ
Q_
Q_
O    100
 QJ
_>    10
 O
 to
 to
                         0.1
                                     PEZ
                                     HCT
                                                   PWZ
                                                   Barrel
                                                            • pre-Tertiary Waste
                                                              Rock
                                                            • North Fork Koktuli
                                                              River
                                                            * Tertiary Waste Rock
                                         10          100          1000

                                          Hardness mg/L CaC03
                                                           10000
  Figure 7. Dissolved copper concentrations and water hardness values for various potential end-member waters
  around the Pebble site in the Bristol Bay watershed associated with waste-rock piles.  The humidity-cell test
  concentrations are from Table 4. The barrel-test results and the mean concentration for the North Fork of the
  Koktuli River are from Pebble Partnership (2011).  The triangle represents the range of potential compositions
  that could be expected for seepage from Pebble West and Pebble East waste rock piles and the dashed line
  represents the range of potential compositions that could be expected from piles of Tertiary waste rock (see text).
  Abbreviations: PWZ, Pebble West Zone; PEZ, Pebble East Zone; HCT, Humidity-Cell Test.

    The average humidity-cell test results for the Tertiary volcanic rocks yielded more coherent results than did the
Pre-Tertiary rocks discussed above.  Invariably, the humidity-cell test results show no ability to generate acid with
all pH values ranging between 7 and 9 with a mean pH 7.2 ± 1.3.  Sulfate concentrations generally range between 1
and 100 mg/L with a mean concentration of 28.0 mg/L, but the lack of correlation with pH suggests that the
resulting sulfate may  be derived from benign sulfate minerals rather than acid-generating iron sulfide minerals.
Copper concentrations were low and generally correlated with sulfate concentrations.
                                                   17

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


Tailings
    Mill tailings are the waste products from froth flotation, a process used to produce concentrates of economic
minerals. The specific minerals separated greatly influence the character of the waste material. For porphyry
copper deposits, it is typical to separate the copper-sulfide minerals [chalcopyrite (CuFeS2) and bornite (CusFeS^]
as a copper concentrate, and the molybdenum-sulfide mineral, molybdenite (MoS2) as a molybdenum concentrate
(Fuerstenau and others, 2007). Gold commonly is associated with the copper sulfide minerals or pyrite.  The gold
associated with the copper concentrate will be recovered during smelting, typically conducted off-site. Gold
associated with pyrite will require additional processing commonly on-site, as described above, to recover the gold.
Thus, pyrite, the main source of acid-mine drainage, can be disposed with the tailings or it can  be separated as a
concentrate to either recover gold or to more effectively manage acid-generation risks. Therefore, the acid-
generating potential and mobility of trace metals will be affected by whether or not pyrite is separated from tailings
prior to disposal.
    A greater number of environmental concerns are associated with tailings due to their finer grain size compared
to waste rock. Like waste rock, tailings can weather and the associated leachate can contaminate surface water
and groundwater (Stollenwerk, 1994; Brown and others, 1998; Khorasanipour and others,  2011). Furthermore,
because of the sand to silt size grains, tailings are prone to be transported by waters, especially in the case of
tailings dam failure, and wind. Thus, they present additional potential risks to aquatic organisms through sediment
contamination.
    A compilation of geochemical  analyses of "pristine", unoxidized tailings from porphyry copper deposits is
presented in Table 5. These data include analyses of tailings from the Aitik mine, Sweden (R. Seal, unpublished
data), the El Teniente mine, Chile (Smuda and others, 2008; Dold and Fontbote, 2001), the Andina mine, Chile
(Dold  and Fontbote, 2001), the El  Salvador mine, Chile (Dold and Fontbote, 2001), and the Sarcheshmeh mine,
Iran (Khorasanipour and others, 2011).  It is important to note that none of these tailings had a  pyrite concentrate
removed.
    A summary of the geochemistry of tailings derived from metallurgical testing of drill core from the  Pebble
deposit is summarized in Table 6 from the PLP Environmental Baseline Document (Pebble Partnership, 2011).
That report presents data from three sample sets, 2004, 2005, and 2008, which were used in the humidity-cell tests
described below. The 2004 and 2005 samples were from Pebble West. The 2008 samples were from Pebble West
and Pebble East. The analyses for all sets included acid-base accounting analyses. The analyses for the 2004
and 2005 samples focused on a more restricted group of analytes, limited mostly to elements for which regulatory
guidance exists (Ag, As, Cd, Co, Cr, Cu, Hg, Mn, Mo, Ni, Pb, Sb,  Se, Tl, and Zn).  The analyses for the 2008
samples included a larger group of analytes (Ag, Al, As, Au, B, Ba, Be,  Bi, Ca, Cd, Ce, Co, Cr,  Cs, Cu, Fe, Ga, Ge,
Hf, Hg, In, K, La,  Li, Mg, Mn, Mo, Na, Nb, Ni, P, Pb, Rb, Re, S, Sb, Sc,  Se, Sn, Sr, Ta, Te,  Th, Ti, Tl, U, V, W, Y,
Zn, and Zr.  The table includes average values, the standard deviation for the average, and the low and high
values. For the entire dataset, paste  pH values are near neutral, ranging from 6.6 to 8.9. The NP/AP ratio ranges
from 0.1 to 9.0, corresponding to probably acidic drainage generating values (PAG) to not probably acidic drainage
generating (non-PAG), with the average being 2.7 (non-PAG). None of the tailing samples presented in Table 5
had pyrite separated; all of their NNP values are negative, indicating  a net acidic character, unlike the Pebble
tailings, which had pyrite removed. Otherwise, the overall chemistry of the tailing samples in Tables 5 and 6
compares favorably in terms of the range of values. It is worth noting that the 2005 LT C2  Combined  Pre-Cleaner
Tailings sample (Table 11-46 of the Pebble Project Environmental Baseline Document) has a copper  concentration
(2,050 mg/kg) that is 68 percent of the 0.3 percent cut-off grade, a molybdenum concentration (188 mg/kg) that 80
percent of the published resource molybdenum grade, and one of the lowest NNP values (-30 kgCaCOs/t).  Further
metallurgical testing presumably will seek to improve copper and molybdenum recovery, which also will improve
the separation of sulfide minerals and increase NNP of the resulting tailings.


                                                  18

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012
Table 5. Geochemical composition of porphyry copper tailing samples from the literature and unpublished USGS
studies.
Mine
Country
Sample No.
Source
AI203
CaO
Fe203
K20
MgO
MnO
Na20
P205
Si02
Ti02
As
Ba
Be
Bi
Cd
Co
Cr
Cu
Mn
Mo
Ni
Pb
Sb
U
V
Zn
S
Carbonate C
Total C
LOI
NNP
Unit

%
%
%
%
%
%
%
%
%
%
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
%
%
%
%
kg CaCOs/t
Aitik El Teniente El Teniente
Sweden Chile Chile
Aitik 1 Channel Sediment
average average
1 2 2
15.65
3.425
10.3
4.775
2.185
0.32
2.36
0.64
54.4
0.74
3.50 33.0 36.0
930.5 382 384
1.55
1.505
<0.01
61.45
20 67 64
478 1035 921
2165 358 376
11.75 89 101
14.15 23 23
9.85
2.77
4.45
155.5 243 230
74 62 58
2.64 3.62 3.43
0.01
0.01
3.55
-74.3
Cauquenes-
Teniente
Chile
T1 average
3










92.9
470.3




29.4
3037
334.5
108.5

20


208.9
92.94




-18.2
Piquenes-
Andina
Chile
A2 average
3










62.0
721.3




14.4
2515.2
592.3
53

36.9


125.5
208.98




-28.3
El Salvador
Chile
E2 average
3










136.3
418.3




8.5
5091 .2
67.3
234.6

22.5


139.9
42.9




-101.6
Sarcheshmeh
Iran
S6/S7 average
4










18.5




27.6
53
1205
700.5
96.7
40
46.0



210





Sources: 1. This study; 2. Smuda and others (2008); 3. Dold and Fonbote (2001); 4. Khorasanipour and others (2011)
    Additional insights into aquatic concerns associated with tailings can be found in case studies from mines. The
geochemical characteristics of tailings seepage have been investigated by several studies. Smuda and others
(2008) investigated the geochemical environment associated with tailings at the El Teniente porphyry copper
deposit, Chile.  They found a range of values for various water-quality parameters associated with the tailings pond.
These parameters included pH (7.2-10.2), sulfate (1556-5574 mg/L), Fe (1.44-8.59 mg/L), Al (below detection -
0.886 mg/L), Mn (0.001-20.1 mg/L), Ni (0.008-0.393 mg/L), Cu (0.003-0.250 mg/L), Zn (0.007-130 mg/L), Mo
(0.033-13.2 mg/L), and As (below detection-0.345 mg/L). Khorasanipour and  others (2011) studied the
                                                   19

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


geochemical environment associated with tailings at the Sarcheshmeh mine, Iran. They too found a range of
values for water-quality parameters such as pH (3.6-7.9),sulfate (1348-4479 mg/L), Fe (<0.01-19.3 mg/L), Al (<0.5-
154 mg/L), Mn (5.6-73.7 mg/L), Ni (0.088-1.74 mg/L), Cu (< 0.002-149.9 mg/L), Zn (0.094-20.3 mg/L), Mo (0.027-
2.9 mg/L), and As (< 0.005-0.04 mg/L).


Table 6. Geochemical composition of test tailings samples from the Pebble deposit from the Pebble Project
Environmental Baseline Document.  Summary statistics include all samples presented in Tables 11-46 and 11-47 in
Pebble Partnership (2011).
Parameter
Ag
As
Ba
Be
Bi
Cd
Co
Cr
Cu
Hg
Mn
Mo
Ni
Pb
Sb
Se
Tl
U
V
Zn
Paste pH
Total S
Sulfate
Sulfide
AP
TIC
TIC
NP (Modified)
NP/AP
NNP
Units
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
Standard Unit
%
%
%
kg CaCOa/t
%
kg CaCOa/t
kg CaCOa/t
ratio
kg CaCOa/t
Average
0.7
25.2
30.0
0.3
0.6
0.1
8.1
149.9
682.9
0.1
359.9
51.9
67.7
15.0
1.0
1.8
0.3
0.4
87.3
87.4
8.2
0.5
0.0
0.5
14.2
0.3
22.6
13.5
2.7
-0.5
Standard
Deviation
0.5
31.6
10.6
0.1
0.5
0.1
10.2
177.3
414.0
0.1
201.4
35.1
111.6
16.6
1.0
2.0
0.2
0.2
36.0
66.3
0.4
0.9
0.0
0.9
27.8
0.2
15.5
6.9
1.9
27.2
Low
0.23
4.2
20
0.18
0.2
0.03
2.2
6
142
<0.01
84
10.5
6.3
3.3
0.2
0.4
0.07
0.17
36
29
6.6
0.09
-0.01
0.05
1.56
0.05
4.5
4.6
0.1
-110.2
High
2.17
169
50
0.64
1.98
0.4
45.9
748
2050
0.56
880
188
452
88.4
5.41
8.8
1.2
0.87
149
267
8.9
4.19
0.2
4.12
128.8
0.75
62.5
25.9
9
22.4
                                                 20

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


    Morin and Hutt (2001) compared predictions for tailing leachate chemistry with actual drainage chemistry at the
Bell mine in British Columbia on the basis of samples collected seven years after closure.  The predictions
indicated that drainage from the tailing piles would start at near neutral pH conditions, but would turn acidic over the
course of several decades. Their post-closure sampling results indicated that acid generation is roughly 100 times
less than predicted.  The authors attributed this discrepancy to basing prediction on an insufficient number of
humidity-cell tests and incorrect assumptions about the rate of sulfide oxidation. Weibel and others (2011) found
similar results in studies of a  porphyry copper mine in Chile.
    As with the waste rock at Pebble, the best insights into the potential behavior of mill tailings come from the
humidity-cell tests being conducted by the Pebble Limited Partnership and its contractors (Pebble Partnership,
2011). The Pebble Partnership initiated two sets of humidity-cell tests on tailings derived from preliminary
metallurgical testing: one set in 2005 and one set in 2008 (Pebble Partnership, 2011). Humidity-cell tests represent
one of the best predictors of long-term weathering of tailings in an aerobic environment (Price, 2009). The test
conditions are most representative of unsaturated tailings exposed at the  surface of a pile. The geochemical
environment found at depth in the saturated zone is typically quite different (Blowes and others, 2003). The 2005
tailings samples originated from a relatively simple set of metallurgical methods, whereas the 2008 samples
originated from a greater variety of metallurgical processing methods. The humidity-cell tests for the tailings
samples were conducted using standard procedures, as described above for the waste-rock samples (Price, 2009).
However, the grain size of the tailings is well below the 6 mm maximum size of waste-rock samples, which means
that the tailings should be more reactive than the waste-rock samples in humidity-cell tests. The results included
the same set of parameters as with the waste-rock testing. As for the waste-rock samples, the following discussion
focuses on pH, sulfate, copper, zinc,  molybdenum, and arsenic.
    The mean humidity-cell results were similar for both the 2005 and 2008 sets of tailings (Pebble Partnership,
2011). Both sets had pH values ranging between 7 and 8.5 in experiments lasting up to five years for the 2005
samples and for more than one year  for the 2008 samples (Table 7). As with the waste-rock samples, individual
humidity-cell tests for tailings can show a range of leachate concentrations that vary over the course of the
experiment. In general, the concentrations of dissolved constituents are most erratic and highest in the initial flush
covering the first few one-week cycles in humidity-cell tests; several weeks after the start of the experiments, the
concentrations of dissolved constituents tends to stabilize. The average release rates used in Table 7 obscure this
variability, although its magnitude can be assessed by the standard deviations present with means in Table 7.
Sulfate concentrations for both sets (2005 and 2008)  generally are below 40 mg/L after the initial flush of soluble
sulfate salts. The mean sulfate release concentration was 17.4 ± 8.0 mg/L. The mean copper (5.3 ± 2.2 pg/L), and
zinc (3.2 ± 1.7 pg/L) concentrations were less than those from the  waste-rock samples, whereas the molybdenum
(33.5  ± 23.7 |jg/L), and arsenic (5.5 ± 8.4 pg/L) concentrations were higher (Table 4).
    The chemical  composition of the pond on  top of the tailing impoundment is difficult to estimate, but bounds can
be placed on its composition. During  mine operation, the water should represent a mixture of the supernatant
solution from the mill that is pumped  with the tailings slurry to the impoundment, solutes derived from aerobic
leaching of the tailings material, which can be limited  by the average humidity-cell results from tailings, and ambient
surface water and precipitation, which can be  approximated generically by the mean composition of the North Fork
of the Koktuli River.  The range of potential compositions is shown in Figure  8 by the triangle, which limits the range
from these three sources in terms of  dissolved copper concentration and water hardness. The supernatant solution
has the highest copper concentration and water hardness of the three end members. The variability of its
composition in the samples from metallurgical testing is reflect by the standard deviations shown in Table 7.  The
location of the hypothetical compositions either within the triangular field for those waters associated with the Pre-
Tertiary waste-rock piles will depend  on the water balance of water-management practices during and after mining.
                                                   21

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


Table 7. Summary of geochemical results from mean humidity-cell tests on tailing samples and the supernatant
solution from metallurgical testing conducted by the Pebble Partnership (2011)
Parameter
Pebble Partnership
(2011) Source
PH
Alkalinity
Hardness
Cl
F
S04
Thiosalts (S203)
Ag
Al
As
B
Ba
Be
Bi
Ca
Cd
Co
Cr
Cu
Fe
Hg
K
Mg
Mn
Mo
Na
Ni
Pb
Sb
Se
Sn
Tl
V
Zn
Units

S.U.
mg/L CaCOs
mg/L CaCOs
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Tailings Humidity Cell
Average Standard Deviation
Table11-49(calc);
Appendix 11L(pH)
7.8
59.7
66.8
0.52
0.451
17.4
nr
0.00001
0.02
0.0055
0.0107
0.0092
0.0002
0.0005
22.6
0.00001
0.0002
0.0005
0.0053
0.03
0.000010
4.02
2.55
0.0441
0.0335
2.10
0.0005
0.00006
0.0018
0.0015
0.0029
0.00005
0.0008
0.0032
Table11-49(calc);
Appendix 11L(pH)
0.2
15.5
13.6
0.08
0.440
8.0
nr
0.00000
0.03
0.0084
0.0010
0.0050
0.0000
0.0000
3.9
0.00000
0.0002
0.0000
0.0022
0.00
0.000000
1.69
2.07
0.0224
0.0237
0.26
0.0001
0.00001
0.0017
0.0006
0.0040
0.00000
0.0008
0.0017
Supernatant
Average Standard Deviation
Table 11 -48
7.9
74.8
322.8
nr
nr
318.7
44.1
0.00002
0.07
0.0172
nr
nr
nr
nr
116.0
-0.00008
-0.0001
-0.0010
0.0078
0.02
-0.000037
25.95
8.00
0.0719
0.0697
43.78
-0.0008
0.00023
0.0060
0.0076
nr
0.00002
nr
0.0043
Table 11 -48
0.3
20.4
254.8
nr
nr
372.1
156.1
0.00025
0.08
0.0212
nr
nr
nr
nr
101.2
0.00018
0.0004
0.0012
0.0049
0.32
0.000103
8.16
5.53
0.0631
0.0560
132.40
0.0018
0.00062
0.0058
0.0062
nr
0.00022
nr
0.0080
nr: not reported
                                                22

-------
         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


    The composition of water potentially seeping from the base of tailing piles is more problematic to estimate. At
depth in the saturated zone in tailing piles, dissolved oxygen is rapidly removed by reaction with trace amounts of
sulfide minerals, which limits the ability to generate acid during further interaction with tailings material. In these
acid-limited environments, silicate minerals such as feldspars and trace amounts of carbonate minerals can
effectively neutralize acid and restrict the ability of groundwater to dissolve additional metals  and other trace
elements (Blowes and others, 2003).  Under these conditions, the chemical composition of seepage from a tailings
pile should fall along the join between the average humidity-cell test composition and ambient surface water and
groundwater (Figure 8).
                   10
                CUO

                l_
                OJ
                Q.
                Q_
                O
                QJ

               ~O
                to
                    8 -
6 -
                    2 -
                                          • North ForkKoktuli River

                                          • Tailings Average HCT

                                          + Supernatant Average
                               50      100      150      200      250

                                          Hardness mg/L CaC03
                                                       300
350
  Figure 8. Dissolved copper concentrations and water hardness values for various potential end-member waters
  around the Pebble site in the Bristol Bay watershed associated with a tailings impoundment. The humidity-cell
  test concentrations are from Table 7. The mean concentrations for the North Fork of the Koktuli River are from
  Pebble Partnership (2011). The triangle represents the range of potential compositions that could  be expected
  for a tailing pond during mine operation; after closure, once ore processing has ceased, the join  between the
  North Fork and the Tailings Average HCT compositions may be more representative of the range of potential
  compositions (see text). Abbreviations: HCT, Humidity-Cell Test.


Copper Concentrate
    Limited data are available on the geochemistry of copper concentrates from porphyry copper deposits. The
geochemical analysis by USGS laboratories of a single sample of a copper concentrate from the Aitik porphyry
copper deposit is presented in Table 8. X-ray diffraction analysis indicates that the sample is dominated by
chalcopyrite with trace amounts of pyrite, quartz, and possibly molybdenite. The ideal composition of chalcopyrite is
34.6 weight percent Cu, 30.4 weight percent Fe,  and 34.9 weight percent S. For the analysis presented in Table 8,
                                                  23

-------
         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


the Cu concentration is above the upper detection limit. However, the analyzed concentration of S (33.4 wt. %)
indicates that the sample is greater than 95 percent chalcopyrite, whereas that of Fe (25.8 wt. %) indicates
approximately 85 percent chalcopyrite. The most notable trace elements in this concentrate are Zn (2190 mg/kg),
presumably reflecting the presence of minor sphalerite, Mo (1100 mg/kg), presumably reflecting the presence of
molybdenite, and Mn (346 mg/kg), likely hosted by sphalerite or traces of the Fe-carbonate mineral siderite.


Table 8.  Geochemical analysis of the copper concentrate (Aitik 2) from the Aitik porphyry copper mine, Sweden
Element
Al
Ca
Fe
K
Mg
Na
Ti
Ag
As
Ba
Bi
Cd
Co
Cu
Ga
In
Mn
Mo
Ni
Pb
Sb
Te
Th
TI
U
V
Zn
S
Units
%
%
%
%
%
%
%
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
%
Concentration
0.98
0.32
25.8
0.49
0.11
0.19
0.05
>10
12
59
44.9
2.4
53.9
>10000
0.88
2.35
345
1100
72.1
64.9
43.4
4.1
1.5
0.2
2.2
23
2190
33.4
    The solution chemistry associated with the transport of concentrate as a slurry in a pipeline can be assessed
by conducting leaching experiments on the Aitik copper concentrate sample described above, which is
mineralogically similar to copper concentrates from most porphyry copper mines.  In flotation circuits, chalcopyrite
is not especially sensitive to pH, but pH may be adjusted to alkaline values to separate molybdenite or pyrite
(Fuerstenau and others, 2007).
                                                  24

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


    The leachability of elements from copper concentrate was evaluated using the Synthetic Precipitation Leaching
Procedure (USEPA Method 1312), and a modification of this protocol. The standard procedure reacts a sample in
a 20:1 (solution: sample) ratio with a weak acidic solution (pH 5), made of a mixture of sulfuric and nitric acids,
under continuous agitation for 18 hours, after which the solution is sampled. Additional leaching experiments were
conducted in which the copper concentrate sample was leached following the  same procedure except that the
starting leaching solution was either distilled water + NaOH solutions (pH 6, 7, 8, 9), or distilled water + Na2C03
solutions (pH 7, 9) adjusted to various starting pH values.  The purpose of these experiments was to evaluate the
range of starting pH values that may be associated with a copper-concentrate slurry discharged from a mill to a
pipeline.
    The results of the leaching experiments on the copper concentrate are presented in Table 9.  Results from a
copper tailings sample from Aitik are also presented  in Table 9.  One of the most striking features  of these
experiments using the copper concentrate is that regardless of the starting pH (pH = 5 to 9), the final pH after 18
hours for all experiments ended  up between 4.1 and 4.2. Equally striking was the fact that dissolved copper
concentrations in the leachate ranged between 15,300 and 16,800 pg/L, dissolved iron concentrations ranged
between 5,480 and 10,200 pg/L, and dissolved sulfate ranged between 183.7 and 208.8 mg/L.

Summary

    The Pebble deposit in the Bristol Bay watershed, southwestern Alaska, shares many geologic attributes with
typical porphyry copper deposits throughout the world. These features include: (1) its spatial  association with
coeval granitic intrusions;  (2) its  large tonnage of ore and its low grade, although the size of Pebble places it in the
upper 5 percent of porphyry copper deposits globally; (3) the association of copper, molybdenum, and gold; (4) the
style of mineralization as veinlets, stockworks, and disseminations with igneous and sedimentary host rocks; and
(5) its zoned ore-mineral and alteration assemblages. From an environmental  perspective, the acid-generating
potential of Pebble  is similar to that found at other porphyry copper deposits: waste rock and  tailings span the
range from potentially acidic drainage generating to non-potentially acidic drainage generating due to the low
contents of pyrite and other sulfide minerals as potential sources of acid, and the presence of silicate minerals such
as feldspars and trace amounts of carbonate minerals to neutralize acid. Humidity-cell tests by Pebble Partnership
(2011) indicate that drainage associated with Pre-Tertiary waste rocks is likely to  have higher concentrations of
solutes and lower pH than  drainage associated with mine tailings. Solutions associated with a copper concentrate
slurry are likely to be weakly acidic and have high concentrations of dissolved  copper and zinc.
                                                   25

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


Table 9. Geochemical analyses of dissolved constituents (< 0.45 pm) in leachates from tailings and copper
concentrate from the Aitik Mine, Sweden, using USEPA Method 1312 and a modified leaching method.
Field No.
Base (Acid)
Starting pH
Final pH
Spec.
Cond.
DO
T
Alkalinity

Ag
Al
As
Ba
Ca
Cd
Co
Cr
Cu
Fe
K
Mg
Mn
Mo
Na
Ni
Pb
Sb
Se
Si02
U
Zn
Cl
F
N03
S04
Units
S.U.
s.u.
pS/cm

mg/L
°C
mg/L
CaC03
M9/L
M9/L
M9/L
M9/L
mg/L
M9/L
M9/L
M9/L
M9/L
M9/L
mg/L
mg/L
M9/L
ug/L
mg/L
M9/L
M9/L
M9/L
M9/L
mg/L
M9/L
M9/L
mg/L
mg/L
mg/L
mg/L
Tailings
WSP*
5
7.3
133

10
22.6
9.3

<1
158
<1
50.5
16
O.02
0.43
<1
0.8
<50
2.15
0.38
20
<2
4.67
<0.4
O.05
0.47
<1
1.8
<0.1
0.6
0.8
0.2
0.7
43.6
Copper Concentrate
WSP*
5
4.2
349



0

<10
1,910
<10
38.6
30
6.3
157
<1
16,500
7,940
3.4
5.5
931
<20
0.41
634
6.16
17.4
<10
<2
33.7
2,040
2.6
1.4
0.4
192.6
NaOH
6
4.2
362



0

<10
1,820
<10
39.2
28.9
6
151
<1
16,300
9,190
3.7
5.2
887
<20
0.52
607
6.93
13.4
<10
<2
33.8
1,920
2.6
1.5
O.08
200.8
NaOH
7
4.2
350



0

<10
1,790
<10
40
29
5.9
152
<1
15,400
7,440
3.4
5.3
891
<20
0.84
613
6.15
16.6
<10
<2
31.2
1,950
2.8
1.5
O.08
191.4
NaOH
8
4.2
345



0

<10
1,770
<10
40.7
28.5
5.9
151
<1
15,300
7,070
3.4
5.3
880
<20
0.89
609
6.08
16.2
<10
<2
31.9
1,940
2.6
1.5
O.08
185.1
NaOH
9
4.1
372



0

<10
1,850
<10
38.5
28.7
6
151
<1
16,800
10,200
3.8
5.2
883
<20
1
607
7.92
14.7
<10
<2
34
1,940
2.6
1.5
O.08
208.8
Na2C03
7
4.2
340



0

<10
1,950
<10
37.9
28.2
6.3
154
<1
16,300
5,560
3
5.5
918
<20
0.87
620
5.36
16.8
<10
<2
34.8
2,040
2.6
1.6
O.08
183.7
Na2C03
9
4.2
340



0

<10
1,870
<10
36.2
28.3
6
152
<1
15,600
5,480
3.1
5.4
899
<20
1.5
612
5.55
16.6
<10
<2
33
1,980
2.5
1.5
O.08
184.5
*WSP: Mixture of H2S04 and HMOs with pH = 5.0 in accordance with EPA Method 1312.
                                                 26

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


References Cited
ALS Chemex, 2008, Bristol Bay Native Corp iron, titanium, platinum Kemuk Mounatin Propsect, data on 8338' of
  core from 14 holes Nushagak Basin in Southwest Alaska, Dillingham District, Alaska: Alask aDivision of
  Geological & Geophysical Surveys Geologic Materials Center Data Report 355,189 p. 1 DVD.

Blowes, D.W., Ptacek, C.J., and Jurovec, J., 2003, Mill tailings: Hydrogeology and geochemistry, in Jambor, J.L.,
  Blowes, D.W., and Ritchie, A.I.M.., eds., Environmental Aspects of Mine Wastes: Mineralogical Association of
  Canada Short Course Series Volume 31, p. 95-116.

Borden, R.K., 2003, Environmental geochemistry of the Bingham Canyon porphyry copper deposit, Utah:
  Environmental Geology, v. 43, p. 752-758.

Bouley, B.A., St. George, Phil, and Wetherbee, P.K., 1995, Geology and discovery at Pebble Copper, a copper-
  gold porphyry system in southwest Alaska, in Schroeter, T.G., ed., Porphyry deposits of the Northwestern
  Cordillera of North America: Canadian Institute of Mining, Metallurgy and Petroleum Special Volume 46, p. 422-
  435.

Brown, J.G., Bassett, R.L., and Glynn, P.O., 1998, Analysis and simulation of reactive transport of metal
  contaminats in ground water in Pinal Creek Basin, Arizona. Journal of Hydrology, v. 209, p. 225-250.

Day, S., and Rees, B., 2006, Geochemical controls on waste-rock dump seepage chemistry at several porphyry
  mines in the Canadian Cordillera: Seventh International Conference on Acid Rock Drainage (ICARD)
  Proceedings, St. Louis, MO, Barnhisel, R.I., ed., American Society of Mining and Reclamation, Lexington, KY, p.
  439-456.

Decker, J., Bergman, S.C., Blodgett, R.B., Box, S.E., Bundtzen, T.K.,  Clough, J.G., Coonard, W.L., Gilbert, W.G.,
  Miller, Ml., Murphy, J.M., Robinson, M.S., and Wallace, W.K., 1994, Geology of southwestern Alaska., in
  Plafker, G., and  Berg, H.C., eds., The Geology of Alaska: Boulder, Colorado, Geological Society of America, The
  Geology of North America, v. G-1, p. 285-310.

Detterman, R.L., and Reed, B.L., 1980,  Stratigraphy, structure, and economic geology of the Iliamna quadrangle,
  Alaska: U.S. Geological Survey Bulletin  1368-B, 86 p.

Dold,  B.,  and Fontbote, L, 2001, Element  cycling and secondary mineralogy in porphyry copper tailings as a
  function of climate, primary mineralogy,  and mineral  processing: Journal of Geochemical Exploration, v. 74, p. 3-
  55.

Fuerstenau, M.C.,  Jameson, G., and Yoon, R.-H. (eds.), 2007, Froth Flotation: A Century of Innovation: Society of
  Mining, Metallurgy, and Exploration, Littleton, CO, 891 p.

International Network for Acid Prevention (INAP), 2011, Global Acid Rock Drainage Guide
  (http://www.gardguide.com, accessed 11/10/2011).

Jergensen, G.V., II (ed.), 1999, Copper Leaching, Solvent Extraction,  and Electrowinning Technology: Society of
  Mining, Metallurgy, and Exploration, Littleton, CO, 296 p.
                                                  27

-------
         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


John, D.A., Ayuso, R.A., Barton, M.D., Blakely, R.J., Bodnar, R.J., Dilles, J.H., Gray, F., Graybeal, FT., Mars, J.C.,
  McPhee, O.K., Seal, R.R., Taylor, R.D., and Vikre, P.G., 2010, Porphyry copper deposit model, chap. B of
  Mineral deposit models for resource assessment: U.S. Geological Survey Scientific Investigations Report 2010-
  5070-6,169 p.

Kelley, K.D.,  Lang, J., and Eppinger, R.G., 2010, Exploration geochemistry at the giant Pebble porphyry Cu-Au-Mo
  deposit, Alaska: SEG Newsletter, no. 80, p. 1-23.

Kesler, S.E., Chryssoulis, S.L., and Simon, G., 2002, Gold in porphyry copper deposits: its abundance and fate:
  Ore Geology Reviews,  v. 21, p. 103-124.

Khorasanipour, M., Tangestani, M.H., Naseh, R., and Hajmohammadi, H.,  2011, Hydrochemistry, mineralogy and
  chemical fractionation of mine and processing wastes associated with porphyry copper mines: a case study of
  the Sarcheshmeh mine, SE Iran:  Applied Geochemistry, v. 26, p. 714-730.

Lister, D., Poling, G.W., Home, I.A., and Li, M.G., 1993, Prediction and reality: Static analyses versus actual rock
  weathering in waste dumps at Island Copper Mine, Port Hardy, B.C.: Proceeding of the 17th Annual British
  Columbia Mine Reclamation Symposium, Port Hardy, BC, p. 109-118.

Lowell, J.D.,  and Guilbert, J.M., 1970, Lateral and vertical alteration-mineralization zoning in porphyry ore deposits:
  Economic  Geology, v. 65, p. 373-408.

Marsden, J.O., and House, C.I., 2006, The Chemistry of Gold Extraction, 2nd Edition: Society of Mining, Metallurgy,
  and Exploration, Littleton, CO, 651 p.

Morin, K.A., and Hutt, N.M., 2001, A comparison of past predictions and current conditions at Bell Mine, British
  Columbia,  Canada: Securing the  Future Proceedings, Skelleftea, Sweden, p. 576-585.

Newberry, R.J., Allegro, G.L., Cutler, S.E., Hagen-Levelle, J.H., Adams, D.D., Nicholson,  L.C., Weglarz, T.B.,
  Bakke, A.A., Clautice, K.H., Coulter, G.A., Ford, M.J., Myers, G.L., and Szumigala, D.J., 1997, Skarn deposits of
  Alaska, in  Goldfarb, R.J., and Miller, L.D., eds., Mineral deposits of Alaska: Economic Geology Monograph 9, p.
  355-395.

Nokleberg, W. J., Plafker, G., and Wilson, F.H.,  1994, Geology of south-central Alaska., in Plafker, G., and Berg,
  H.C., eds., The Geology of Alaska:  Boulder, Colorado, Geological Society of America, The Geology of North
  America, v.G-1, p. 311-366.

Northern Dynasty Minerals, 2011, Preliminary Assessment of the Pebble Project: unpublished report, Wardrop,
  February 17, 2011,579 p.

Pebble Partnership, 2011, Pebble Project Environmental Baseline Document 2004 through 2008, unpublished
  report, 30,  378 p.

Porter, K.E.,  and Bleiwas, D.I., 2003, Physical aspects of waste storage from a hypothetical open pit porphyry
  copper operation: U.S.  Geological Survey Open-File Report 03-143, 63 p.

Price, W.A.,  2009, Prediction Manual for Drainage Chemistry from Sulphidic Geologic Materials: MEND Report
  1.20.1, 579 p.
                                                  28

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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


Rombach, C.S., and Newberry, R.J., 2001, Shotgun deposit: granite porphyry-hosted gold-arsenic mineralization in
  southwestern Alaska, USA: Mineralium Deposita, v. 36, p. 607-621.

Schmidt, J.M., Light, T.D., Drew,  L.J., Wilson, F.H., Miller, Ml., and Saltus, R.W., 2007, Undiscovered locatable
  mineral resources in the Bay Resource Management Plan area, southwestern Alaska: A probabilistic
  assessment: U.S. Geological Survey Scientific Investigations Report 2007-5039, 50 p.

Seal, R.R., II, and Hammarstrom, J.M., 2003, Geoenvironmental models of mineral deposits: examples from
  massive sulfide and gold deposits: Environmental Aspects of Mine Wastes, J.L. Jambor, D.W. Blowes, and A.I.M.
  Ritchie (eds.), Mineralogical Association of Canada Short Series, v. 31, p. 11-50.

Seedorff, E., Dilles, J.H., Proffett, J.M., Jr.,  Einaudi, M.T., Zurcher, L, Stavast, W.J.A., Johnson, D.A., and Barton,
  M.D.,  2005, Porphyry deposits: Characteristics and origin of hypogene features: Economic Geology 100th
  Anniversary Volume, p. 251-298.

Sinclair, W.D., 2007, Porphyry deposits, in Goodfellow,  W.D., ed., Mineral Deposits of Canada: A Synthesis of
  Major Deposit-Types, District Metallogeny, the Evolution of Geological Provinces, and Exploration Methods:
  Geological Association of Canada, Mineral Deposits Division, Special Publication No. 5, p. 223-243.

Singer, D.A., Berger, V.I., and Moring, B.C., 2008, Porphyry copper deposits of the world: Database and grade and
  tonnage models, 2008: U.S. Geological Survey Open-File Report 2008-1155,45 p.

Smuda,  J., Dold,  B., Spangenberg, J.E., and Pfeifer, H.-R., 2008, Geochemistry and stable isotope composition of
  fresh alkaline porphyry copper tailings; Implications on sources and mobility of elements during transport and
  early stages of deposition: Chemical Geology, v. 256, p. 62-76.

Stollenwerk, K.G., 1994, Geochemical interactions between constituents in acidic groundwater and alluvium in an
  aquifer near Globe, Arizona. Applied Geochemistry, v. 9, p. 353-369.

Szumigala, D.J.,  Harbo, L.A., and Hughes,  R.A., 2009, Alaska's Mineral Industry 2009. Alaska  Division of
  Geological and Geophysical Surveys, Special Report 64, 81 p.

Tarkian, M., and Stribrny, B.,  1999, Platinum-groups elements in porphyry copper deposits: a reconnaissance
  study: Mineralogy and Petrology, v. 65, p. 161-183.

U.S. Environmental Protection Agency, 1994, Method 1312; Synthetic precipitation leaching procedure: 30 p.
  (http://www. epa.gov/wastes/hazard/testmethods/sw846/pdfs/1312.pdf).

U.S. Geological Survey, 2011, Mineral Commodity Summaries 2011, 201 p.
  (http://minerals.usgs.gov/minerals/pubs/mcs/2011/mcs2011.pdf)

Wallace, W.K., Hanks, C.L., and  Rogers, J.F., 1989, The southern Kahiltna terrane: Implications for the tectonic
  evolution of southwestern Alaska: Geological  Society of America Bulletin, v. 101, p. 1389-1407.

Weibel,  L., Dold,  B., and Cruz, J., 2011, Application and limitation of standard humidity cell tests at the Andina
  porphyry copper mine, CODELCO, Chile: Eleventh SGS Biennial Meeting, Proceedings, September 26-29, 2011,
  Antofagasta, Chile, p. 976-978.
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         Geologic and Environmental Characteristics of Porphyry Copper Deposits-April 2012


White, W.W., III, Lapakko, K.A., and Cox, R.L., 1999, Static-test methods most commonly used to predict acid-mine
  drainage: Practical guidelines for use and interpretation, in Plumlee, G.S., and Logsdon, M.J., eds., The
  Environmental Geochemistry of Mineral Deposits, Part A.  Processes, Techniques, and Health Issues: Society of
  Economic Geologists Reviews in Economic Geology, Volume 6A, p. 325-338.

Wilson, F.H., Mohadjer, S., Labay, K.A., and Shew, N., 2006, Preliminary Integrated Geologic Map Databases for
  the United States: Digital Data for the Reconnaissance Bedrock Geologic Map for the Northern Alaska Peninsula
  area, Southwest Alaska: U.S. Geological Survey Open-File Report 2006-1303.
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DRAFT                                                 EPA910-R-12-004Bc
DO NOT CITE OR QUOTE                                   April 2013
                                                      Second External Review Draft
                                                      www.epa.gov/bristolbay
      An Assessment of Potential Mining Impacts on Salmon
                  Ecosystems of Bristol Bay, Alaska


                   Volume 3 of 3 -Appendices E-J
        Appendix I: Conventional Water Quality Mitigation
     Practices for Mine Design, Construction, Operation, and
                                Closure
                                 NOTICE
   THIS DOCUMENT IS AN EXTERNAL REVIEW DRAFT. It has not been formally released by
   the U.S. Environmental Protection Agency and should not be construed to represent Agency
   policy. It is being circulated for comment on its technical accuracy and policy implications.
                       U.S. Environmental Protection Agency
                                Seattle, WA

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DRAFT                                                       May 2012
DO NOT CITE OR QUOTE                                   External Review Draft
  Conventional Water Quality Mitigation
 Practices for Mine Design, Construction,
             Operation, and Closure
                      Barbara A. Butler, Ph.D.
               U.S. EPA Office of Research and Development
              National Risk Management Research Laboratory
              Land Remediation and Pollution Control Division
                Remediation and Redevelopment Branch
                            NOTICE

     THIS DOCUMENT IS A PRELIMINARY DRAFT. It has not been formally released by
     the U.S. Environmental Protection Agency and should not be construed to
     represent Agency policy. It is being circulated for comment on its technical
     accuracy and policy implications.
                  Office of Research and Development
                 U.S. Environmental Protection Agency
                         Washington, DC

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                ***internal deliberative materials-do not cite, quote, or distribute***


Mitigation includes the steps needed to avoid, minimize, or compensate for any
potential adverse impacts on the environment from a given activity (Hough and
Robertson, 2009). Hardrock metal mining is an activity that provides metals for
numerous purposes, but it has the potential to have adverse effects on nearby aquatic
environments. Many mitigation measures developed to avoid or minimize impacts to
water quality and aquatic ecosystems have become current industry practice and
several of these are presented in this document for selected waste streams associated
with mining, along with discussions of accidents and failures associated with storage of
waste rock and tailings. Compensatory mitigation, which may be required under Section
404 of the Clean Water Act (CWA) when there are unavoidable impacts anticipated to
lead to the loss of wetland, stream, or other aquatic resource, is not included in this
Appendix.

The most important aspects of mitigation for any mining site are proper planning,
design, construction, operation, management, and closure of waste and water
containment and treatment facilities, and monitoring and maintenance over all mine-
life phases, including following closure. A failure in  any aspect of mitigation may result
in environmental and/or human health impacts.  Planning for design and construction
must consider site-specific factors such as climate, topography, hydrology, geology,
seismicity, and waste material specific factors such  as geochemistry, mineralogy,
particle size, and presence of process chemicals.  These factors should be based  upon
conservative estimates of future conditions to minimize potential for failure over time.
In addition, the planning and design should incorporate  considerations for the land's use
following closure of mining operations.
1. WASTE ROCK

Overburden is unconsolidated surface material that would be removed to expose the
ore/waste rock zone and often comprises alluvium, colluvium, glacial tills, or other soils;
overburden may be stockpiled separately for later use in reclamation. Waste rock
includes rock that is removed above the ore and rock that is removed along with the
ore, but cannot be mined economically at the time of mining (sub-economic ore). The
particle size distribution of waste rock may vary from sand-sized fines to large boulders,
with the quantity in a given particle size class dependent upon the site geology and the
specifics of the method(s) in which it was extracted (e.g., blasting strength). The sources
of potential environmental influence to surface water from waste rock piles include
sediment loading due to erosion and deposition of fugitive dusts, and contaminant
loading due to leaching of acidity and inorganic contaminants, such as metals and
metalloids, contained in the waste rock. Precipitation and surface water run-on can
lead to weathering and erosion of materials into runoff (dissolved and particulate)
transported to surface water.  Percolation  and infiltration that lead to leaching and
transport of ions through seepage of the leachate to groundwater may occur also, as
may seepage through sloped pervious material to a surface water body.  Additional

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routes of environmental exposure include movement of material mass (e.g., through
rockslides due to physical instability) into a water body and wind erosion carrying finer
particles (dust) through the air.

Waste rock, and other mining materials may be classified as potentially acid-generating
(PAG) or non-acid generating (NAG, also called non-PAG); this distinction is determined
through geochemical characterization, acid-base accounting  (ABA) static tests, and
kinetic leachate testing [e.g., see (American Society for Testing and Materials (ASTM)
2000, Hornberger and Brady 1998, Lapakko 2002)]. ABA tests are rapid methods to
determine the acid-generation potential (AP) and neutralization potential (NP) of a rock
or mining  waste material, independent of reaction rates (i.e., in contrast to kinetic
tests). These potentials are then compared to one another by either their differences
(net neutralization potential, NNP) or their ratios (neutralization potential ratio, NPR).

Although methods used for ABA have limitations, it is common industry practice to
consider materials that have an NPR of 1 or less as potentially acid generating (PAG)
(e.g., Brodie et al., 1991; Price, 2009; Price and Errington, 1998) and materials with a
ratio greater than 3 (Brodie et al., 1991) or 4 (Price and Errington, 1998) as having no
acid generation potential (non-PAG or NAG).  Materials having ratios between 1 and 4
require further testing via kinetic tests and geochemical assessment for classification
(Brodie et al., 1991; Price, 2009; Price and Errington, 1998). This further testing and
assessment are necessary because if neutralizing minerals react before acid generating
minerals, the neutralizing effect may not be realized and acid might be generated in the
future. Additionally, some toxic elements (e.g., selenium and arsenic) may be released
from mining materials under neutral or higher pH conditions, which would be observed
during kinetic leaching tests conducted at variable pH values.

Waste rock is susceptible to acid generation due to the open pore network allowing for
easy advection of air (Mining Minerals and Sustainable Development (MMSD) 2002) to
oxidize minerals, which subsequently are dissolved in water that encounters the rocks.

1.1 CONVENTIONAL PRACTICES

There are  numerous mitigation measures  available for waste rock piles. The selection of
mitigation measures are site-specific and depend on the sizes and amounts of the
material to be placed in the pile, the methods employed during mining, the mineralogy
of the material, the site's specific hydrology, climate, seismicity, and topography,  and
plans for future land-use.

1.1.1 Operational Phase

Non-reactive (i.e., NAG) waste rock might  be used in creation of mining roadways or
transported off-site for use in roadways or another purpose requiring rockfill, with
unused waste  rock stored in piles. Waste  rock piles generally are disposed in locations

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close to the mine site to reduce handling costs and are placed in locations that provide
physical stability. Waste rock and overburden piles typically are not placed on lined
foundations because of the cost and stability risk (Mining Minerals and Sustainable
Development (MMSD) 2002), but rather are constructed on natural terrain; although
the decision for lined or unlined piles is site-specific. Prior to placement of a waste rock
pile, the topsoil is removed and stockpiled for later use in reclamation. The angle of
repose (where the outer slope is just stable under static loading conditions) is typically
37-40° (Mining Minerals and Sustainable Development (MMSD) 2002), but will depend
on site-specific and material-specific factors. Piles constructed in lifts or by using
benches typically have lower slope angles and concurrent increased stability (U.S.
Environmental Protection Agency (U.S.EPA) 1995b, Mining Minerals and Sustainable
Development (MMSD) 2002).

When waste rock contains materials that have the potential to generate acid or release
metals, metalloids, or other ions of concern that would have environmental or human
health impacts, management of the materials must include practices to minimize
potential for any environmental impacts. Mitigation/management measures used
during the operational phase can include a variety of methods either used
independently or in combination; these  include diversion systems to route water away
from the pile, use of liners underneath the waste rock pile, selective handling /
segregation, blending and layering, minimization  of infiltration potential, leachate
collection systems and seepage drains and routing systems to divert leachate to
treatment facilities, addition of bactericides to slow oxidation of PAG, encapsulation,
and/or adding low permeability materials to slow infiltration rates (Boak and Beale
2008, Mining Minerals and Sustainable Development (MMSD) 2002, U.S. Environmental
Protection Agency (U.S.EPA) 1995b, U.S. Environmental Protection Agency (Region 10)
2003a, U.S. Environmental Protection Agency (Region 10) 2003b, Perry et al. 1998).
Additionally, the amount of waste  rock exposed to the environment can be reduced by
disposing the rock into depleted pits or underground mine tunnels, or through
reclamation activities conducted concurrent with active mining (called progressive
reclamation).

Selective handling involves placement of materials combined with management
strategies to avoid or minimize release of acidic drainage. Physical separation of PAG
and NAG materials will not prevent acid-rock drainage formation, but may be necessary
to control the amount and location of potential drainage and to manage the PAG
material. PAG material can be kept completely saturated to minimize air exposure (e.g.,
placed into the open pit post active mining), disposed in a separate lined or unlined
engineered containment system, or blended with NAG material and stored in an
aboveground pile, coupled with minimizing exposure to water.

Blending involves mixing waste rock types of varying acid-producing potential (AP) and
neutralization potential (NP) to create a  mixture that has acceptable quality (i.e., no net
acid-generation potential). The viability of blending as a mitigation measure depends  on

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the materials available and the mine plan, the stoichiometric balance between acid
generating and neutralizing materials, geochemical properties, reactivity of waste rock
types, flow pathways created within the waste rock pile, and extent of mixing and
blending.  If a site does not have sufficient neutralizing material with which to blend the
PAG material, limestone or other neutralizing rock might be used, if available from
another location on-site, or trucked into the site. The geochemical characteristics of the
materials being blended and mixed must be well-characterized in order to attain a
resultant mix that has no net acid production potential.

PAG materials may be kept isolated from direct exposure to precipitation and oxygen
transfer by layering NAG materials on top of them in the waste pile.  This would involve
layering of PAG with a mix of PAG-NAG material, with a top layer of NAG only material,
or another combination.

Encapsulation of a waste rock pile with an impermeable layer serves to limit infiltration
and oxygen transfer.  Progressive reclamation with multiple impermeable  layers within a
waste rock pile can minimize infiltration, seepage, and oxygen transfer.  Compaction is
used also, if it can be done safely (physically). Once a pile is covered, overburden or
other non-reactive material can be placed on top and the site vegetated to provide
stability against erosion and to meet regulatory requirements for restoration.

Some microorganisms are able to facilitate rapid oxidation of PAG sulfidic  minerals;
thus, a bactericide could be added to eliminate their presence and slow the oxidation
rate. Such an amendment must be mixed thoroughly into the PAG material as the pile is
constructed to ensure effectiveness.

Sub-economic ore removed during the active mining  phase might be segregated from
the primary waste rock pile to be mined if/when it becomes economically  feasible.
These piles may be mined with their resultant waste disposed into a  tailings
impoundment or placed directly in the completed pit, if mined  at closure.

Building an under-drain system to collect seepage/leachate water potentially containing
leached ions/acidity allows this water to be directed toward collection systems for
either use in processing or treatment and discharge to a surface water body. Diversion
structures collect and direct runoff and seepage to treatment and/or settling ponds.
Groundwater monitoring wells are used downstream of these structures to evaluate
their performance.

1.1.2 Closure and Post-Closure

During the closure phase of mining, a dry cover (or encapsulation) can be placed over
the waste rock pile to isolate it from water and oxygen, or the pile can placed into the
completed open pit to be kept below the water line (subaqueous disposal  if PAG
material), with choices dependent upon site specifics (O'Kane and Wels 2003).

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Additionally, in some settings, it is beneficial to fill the pit with waste rock and other
waste material and then construct a dry cover over the filled pit area.  When stored
above ground, the stockpiled overburden may be used to cover the pile and then it is
vegetated to provide stability against erosion. Blight and Fourie (Blight and Fourie 2003)
recommend that outer slopes reclaimed with vegetation not exceed 15 degrees.  Post-
closure monitoring, maintenance, and inspection are conducted indefinitely when a pile
requires long-term collection and treatment of leachate through use of the drainage
collection and  monitoring structures in place during the operational phase of mining.  A
number of different types of covers could be used, with each having their benefits and
limitations. Factors affecting the long-term performance of covers include physical
stability, volume change, vegetation, soil evolution,  and ecological stability (Wilson,
Williams and Rykaart 2003).

1.2 ACCIDENTS AND FAILURES

If waste rock piles are designed properly with appropriate mitigation measures,
monitored and maintained, release of contaminants is possible, but unlikely; however,
accidents and failures causing contaminants to be transported may still occur. Seven
major factors affecting  the physical stability of a  waste rock pile against failure are: 1)
configuration;  2) foundation conditions; 3) waste material properties; 4) method of
construction; 5) dumping rate; 6) piezometric and climatic conditions;  and 7) seismic
and blasting activities ((Piteau Associates Engineering  Ltd. 1991), as referenced in (U.S.
Environmental Protection Agency (U.S.EPA) 1995b). An additional factor to consider is
monitoring and maintenance for early detection of conditions that indicate inadequate
stability.  Although it depends on a number of site-specific factors, data indicate that
most waste dump failures occur on foundations  with slopes in excess of 20 degrees (U.S.
Environmental Protection Agency (U.S.EPA) 1995b).

Physical failures of waste rock piles may occur through slope failures. These result from
changes in the effective stresses of the rock material, variations in material properties
(including particle size and gravity sorting), or changes in the rock pile's geometry
(Pastor et al. 2002, Tesarik and McKibbin 1999).  Changes in effective stress can result
from earthquakes, human actions, changes in underlying soil properties, or through
changing pore  pressures resulting from rainfall, snowmelt, or changes  in drainage
conditions. Properties  of the rock will change over time due to weathering and from the
influence of acid dissolution, if any nearby PAG materials are oxidized and dissolved.
Changes in a waste rock pile's geometry can result from erosion or from actions such as
excavation, construction, or rebuilding/reshaping of the pile.

Waste rock piles typically have heterogeneous particle size distribution and varied
permeability throughout the depth and breadth  of the pile. In a field test using tracers,
Eriksson et al. (Eriksson, Gupta and Destouni 1997),  found that 55-70% of the total
water followed preferential flow pathways.  The authors also found that chemical
tracers behaved differently in weathered waste rock piles versus newer piles.  Results

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from Eriksson et al. (Eriksson et al. 1997), support the need for understanding longer-
term behavior of the materials and their distribution within a waste rock pile through
leaching tests, modeling, and field measurements.  Blending waste rock with limestone
is a standard practice to minimize the production of acidic leachate; however, the
mixing method used during construction of the pile construction may influence the
method's success. For example, Miller et al. (Miller et al. 2006), reported blending
during waste rock pile construction to have only limited success when using haul trucks,
due to insufficient blending of the limestone with the finer size fraction of waste rock,
but that better mixing was achieved using a conveyer and stacker. Morin and Hutt
(Morin and Hutt 2004), as presented in Price (Price 2009), found that variability  in
acidity from seeps of a single waste rock dump ranged from zero to approximately 90 g
CaC03/L (standard unit for acidity, where 50 grams of CaC03 neutralizes 1 mol H+) in one
year, which further supports the need for homogenous blending of neutralizing
materials and complete characterization of waste rock materials.

Isolation covers have the highest probability of success against geochemical failure (i.e.,
leaching of acidic and/or contaminant-laden water), with their purpose being to limit
infiltration and oxygen transfer.  In a study of a waste rock pile at a mine site in Papau
Province, Indonesia, however, Andrina et al.  (Andrina et al. 2006), found aspects of a
waste rock pile, including the type of waste rock, particle size distribution, and dumping
methods, each influenced variations in oxygen and temperature profiles. At that site,
they found that an impermeable surface cover had only a limited  effect  on oxygen
concentrations within the profile of the waste rock pile and concluded that advection of
airflow through the coarse rock / rubble zone at the foundation of the dump was the
primary pathway for oxygen transport.

Monitoring and maintenance activities must continue beyond construction of a  waste
rock pile. Although the pile may have been constructed based on sound slope stability
studies, and have appropriate covers and means to divert water, the properties  of the
pile may change over time and breaches to covers may occur. Additionally, freeze/thaw
cycling in colder climates may cause cracks, channeling, and exposure of surfaces below
the cover (Sartz et al. 2011) and should be considered when designing piles and
mitigation measures in  these climates. Such cycling could result in accelerated
weathering and leaching of materials (Dawson and Morin 1996, SRK Consulting 2009).
With careful monitoring and early remedy of observed defects, some catastrophic
consequences can be avoided.
2. TAILINGS

Tailings are a solid-liquid slurry material comprising fine-grained waste particles
remaining after ore processing (e.g., milling, flotation, separation, leaching) and typically
in the silt size-fraction ranging from 0.001 to 0.6 mm, along with water and residual
chemicals (Mining Minerals and Sustainable Development (MMSD) 2002, U.S.

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Environmental Protection Agency (U.S.EPA) 1994). Similar to waste rock, tailings
materials may be potentially acid-generating (PAG) or non-acid generating (NAG) and
testing is conducted to assess their characteristics. The majority of ore mined and
processed ends up as tailings.  Tailings slurries have a solids content from 15 to 55
percent weight (U.S. EPA 1994).  The liquid portion of tailings comprises water and
chemicals  used in processing of the ore (e.g., sodium ethyl xanthate, methyl isobutyl
ketone, hydroxy oxime, acids, alcohols). Cyanide and metals may be present if the
process includes cyanidation or pyrite suppression, with disposal of waste solution and
tailings in the tailings impoundment. Logsdon et al (Logsdon, Hagelstein and Mudder
1999) present concentrations of cyanide and various metals that might be expected (if
present in the ore) in solutions following gold extraction: total cyanide (50-2000 mg/l),
arsenic (0-115 mg/l), copper (0.1-300 mg/l), iron (0.1-100 mg/l), lead (0-0.1 mg/l),
molybdenum (0-4.7  mg/l), nickel (0.3-35 mg/l) and zinc (13-740 mg/l).

The sources of potential environmental impacts to water from tailings storage facilities
(TSF) are sediment loading and leaching of acidity and inorganic contaminants, such as
metals and metalloids, and other chemicals used that may be present in the processing
waste tailings. The main environmental influences originate from seepage of
contaminants into groundwater, leakage through containment walls, and exposure of
waterfowl (if a tailings pond is present) to chemical contaminants.  Additional routes of
environmental exposure include movement of material mass from structural failure of a
tailings impoundment (e.g.,  through breach of embankments) into a water body, and
wind erosion  carrying finer particles through the air during construction.

2.1 CONVENTIONAL PRACTICES

The selection and design of a tailings disposal site is site specific and depend on factors
such as climate, topography, geology, hydrology, seismicity, economics, and
environmental and human safety (e.g., see (Commonwealth of Australia 2007, U.S.
Environmental Protection Agency (Region 10) 2003a, U.S. Environmental Protection
Agency (Region  10) 2003b).  The most basic requirements of any tailings storage facility
(TSF), also called a tailings disposal facility, are that it is safe, stable, and economical,
and that it presents negligible  public health and safety risks and acceptably low social
and environmental impacts  during operation and post-closure. Effective construction
must be based on a correct geotechnical assessment.

2.1.1 Operational Phase

Disposal options for tailings include 1) land-based placement  into an impoundment; 2)
disposal into underground workings or open pits; and 3) underwater (sub-aqueous)
disposal into an existing water body or a constructed water body.  The most common
method of disposal is into a  tailings slurry impoundment.  Tailings impoundments are
constructed as water-holding structures. This generally is accomplished by constructing
a tailings dam in a valley. As tailings are placed behind the dam, a basin is formed. The

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solid portion of the tailings settles and the liquid portion creates a tailings pond.
Construction of a tailings impoundment is done in lifts over the life of the mine. Tailings
deposited against the embankment in creation of beaches leads to water draining away
from the embankment, which reduces seepage and increases dam stability. Water
levels in the tailings pond are controlled through removal of excess water for use in the
mining process or for treatment and discharge to the local surface water; this minimizes
water storage to enhance stability.

Special care must be taken during operations and post-closure to isolate acid-
producing/metal  leaching tailings from oxidation. A common method is for disposal of
such tailings underwater (either into an existing water body or into a tailings pond).
Sub-aqueous disposal is common in Canada and is considered a BMP for long-term
isolation of tailings from oxidation; loss of any existing water body through this method
must be replaced (O'Kane and Wels 2003). Sub-aqueous disposal has the potential  for
problems with physical stability, seepage, and water quality; however, if properly
designed, constructed, and maintained, this type of storage provides good long-term
isolation post-closure.  At  least a 30-cm barrier of stagnant water should overly the
tailings (wave action would re-suspend particles closer to the surface if not stagnant); in
Canada, a minimum recommended depth is 100-cm (SRK Consulting 2005).  Sub-
aqueous disposal is not applicable in all environments (e.g., arid regions), and  disposal
into an existing water body is not supported at all in Australia (Witt et al.  2004).

Tailings impoundments can be constructed using upstream, downstream, and centerline
methods. The upstream method involves construction of walls on top of consolidated
and desiccated tailings in an upstream direction, using waste rock or tailings for
construction material;  the downstream method involves construction with waste rock
or borrow materials in a downstream direction; and the centerline method involves
construction of the walls above a fixed crest alignment, using waste rock, borrow
materials, or tailings (Commonwealth of Australia 2007).  According to the International
Commission on Large Dams (ICOLD), from a seismic standpoint, tailings dams built by
the upstream method are less stable than dams built by either the downstream or the
centerline method (International Commission on Large Dams (ICOLD) 2001). The state
of Idaho considers upstream construction unsuitable for impoundments intended to be
very high and/or to contain large volumes of water or solids
(http://www.idl.idaho.gov/Bureau/Minerals/bmp  manuall9927pl6-ch4.pdf). The
downstream method is considered more stable from a seismic standpoint, but it also is
the most expensive option; centerline construction is a hybrid of upstream and
downstream construction types and has risks and costs lying between them (Chambers
and Higman 2011, Martin  et al. 2002).

When tailings impoundments are constructed in earthquake-prone locations,  a critical
design criterion is magnitude of earthquake that could be expected to occur. The most
conservative design would consider the maximum credible earthquake (MCE), which
would be the largest quake that could occur reasonably at any location at the  mine  site,

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based on seismological and geological evidence and interpretation (Chambers and
Higman 2011).

Dewatering (thickening) of tailings prior to disposal enables  more process water to be
directly recycled back to mineral processing plant to reduce  losses and operational
demand, while reducing the amount of water stored in the TSF.  Reduction of water
quantity will reduce risks of overtopping, seepage, and evaporative losses of water that
could be used in the mining process (rather than fresh water). Depositional beach
angles also are steeper, which aids in containment.

Paste tailings technology requires thickening (water content ~ 20%) the tailings and
placing them onto a lined disposal site. Dry stack tailings require filtering the tailings
and placing the tailings onto a lined pad.  Tailings thickened  to a paste and filtered
tailings can be 'stacked' for long-term storage. This method is relatively new, but has
the advantages of reduced potential for liquefaction during  an earthquake and tailings
release from a breach in containment would be localized instead of flowing long
distances (Witt et al. 2004).  Filtered (e.g., moisture content ~ < 20%) and stacked
tailings require a smaller footprint for storage, are easier to  reclaim both at closure and
by progressive reclamation, and have  lower potential for structural failure and
environmental impacts (Martin et al. 2002). Additionally, in cold climates, dry stacking
prevents pipes from freezing, prevents frosting problems associated with conventional
impoundments, and assists in retention and recycling of process water during cold
weather operations (Access Consulting Group 2007). Disadvantages include that dry
stacking is not appropriate for acid-generating tailings and pumping to the storage
facility is difficult due to high viscosity and resistance to flow (filtered tailings for
stacking are transported to storage via truck).  There also  is  potential for generation  of
dusts (Witt et al. 2004). Thickened and paste tailings disposal is becoming more
widespread; past limitations were high costs and lack of suitable thickener technology
(Commonwealth of Australia 2007). This type of storage has less application at larger
operations where tailings ponds may serve a dual role of process and excess water
storage as well as tailings storage.  Dry stacked tailings disposal is most applicable in  arid
regions or in cold regions where water handling is difficult (Martin et al.  2002).

Mitigation measures for a TSF may include any combination of a liner, under-drains,  and
decant systems when there is expectation of seepage or the presence of groundwater,
and prevention of the formation of low permeability lenses  or layers on tailings beaches
that could cause future seepage or stability concerns (Commonwealth of Australia
2007). Liners can include a high-density polyethylene (HOPE) or other type of
geosynthetic material, a clay cover over an area of high hydraulic conductivity, or a
combination. A properly constructed  clay liner could be expected to have a saturated
hydraulic conductivity of 10"8 m/s and a geomembrane to have a hydraulic conductivity
of ~ 10"10 m/s; however, the lifetime of a  geomembrane may vary widely, depending on
a number of factors, including composition and site temperature.  For example, Koerner
et al. (2011) presents that a nonexposed  HOPE liner could have a predicted lifetime ("as

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measured by its half life") of 69 years at 40 °C to 446 years at 20 °C. Where
geomembranes are used, a drainage layer atop the membrane is commonly included to
reduce the water pressure on the liner and minimize leakage. Liners may cover the
entire impoundment area, or only the pervious bedrock or porous soils.  Full liners
beneath TSFs are not always used; however, there is a growing requirement to use
liners to minimize risks of groundwater contamination, with new mines in Australia
being required to justify why one wouldn't be required (Commonwealth of Australia
2007).  Under-drains serve a dual purpose of reducing water saturation of the tailings
sediments to improve geotechnical strength and safety of the facility as well as for
directing drainage toward a  storage area for subsequent treatment. If seepage from the
TSF is expected (or if observed during monitoring), mitigation or remedial measures
include interception trenches and/or seepage recovery wells to be installed around the
perimeter and  downstream to capture the water for redirection to a treatment facility.
A spillway diversion commonly is constructed to provide a catchment for precipitation
runoff.

The flotation process used to produce metal sulfide concentrates from porphyry
deposits results in two tailings waste streams: one from the rougher circuit (to remove
gangue material  comprising silicates and oxides) and one from the cleaner circuit
(pyrite-rich). It is possible to use a technique called "selective flotation" to separate
most of the pyrite into the cleaner circuit tailings (PAG) with the rougher tailings
comprising mostly NAG. Traditionally, these tailings streams were combined, but they
could be separated selectively, with the PAG being discharged deeper into the TSF and
the NAG discharged and used as a cover for the PAG. Success is dependent upon the
ore and the efficiency of a clean separation (Martin et al. 2002).

In leaching of gold ore, mitigation practices include not locating leaching operations in
or near a water body, detoxification of materials prior to disposal or closure, and
ensuring that the solution can be contained in the presence of increased flows, up to
the maximum reasonable storm event (U.S. Environmental Protection Agency (U.S.EPA)
1995a).  When tank leached, the tailings and spent solution are stored in the TSF. The
conventional method for recovery of gold from ore typically involves tank leaching with
dilute (100-500 ppm) sodium cyanide (Logsdon et al. 1999). Following leaching, either
zinc metal or activated carbon is added to the solution to recover the gold. The residual
solution either is treated in a water treatment plant or stored with the process tailings
in the TSF pond.  When stored in the TSF pond, the cyanide concentrations should be
such that there would be no adverse effects to wildlife, such as birds landing on the
pond. Although  rates could  depend on the climate and other site specifics, cyanide
concentrations are known to decrease through natural attenuation, including
volatilization and subsequent interactions with UV, biological oxidation, and
precipitation (Logsdon et al. 1999).

Monitoring groundwater quality for contaminant transport includes piezometers for
groundwater mounding assessment. Regular inspections/monitoring for TSF stability
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include evaluation of seepage discharges through the dams, foundations, abutments,
and liners; phreatic surface in ponds and dams; pore pressures; horizontal and vertical
movement; and the status of leak detection systems, secondary containment, auto flow
measurement and fault alarms, condition of pump and pipelines. Azam and Li (Azam
and Li 2010) point out the importance of monitoring pore water pressures and
embankment deformation based on correlation with several types of failure, and
provides a basis to rectify the situation before failure ensues.

2.1.2 Closure and Post-Closure

Closure  requires the TSF to have either a continuous water cover or an engineered cover
to prevent oxidation of tailings. Sufficient capital is required to finance inspections,
maintenance, and repairs in post-closure for as long as the tailings exist.

Closure  of a TSF includes containment/encapsulation, minimization of seepage,
stabilization with a surface cover to prevent erosion and infiltration, diversions and
collection of precipitation, and design of final landform to minimize post-closure
maintenance (the final landform desired should be considered during the planning
phase).  There are a number of cover types and depths that can be chosen; the choice is
site specific and depends on climate, type and volume of tailings, size and geometry of
the TSF, available cover material, and the end-use for the property (e.g.,  (O'Kane and
Wels 2003, Wilson et al. 2003). A conventional cover is typically a low hydraulic
conductivity layer of clay (and/or a geosynthetic membrane) overlain with protective
soil layers and generally 1.2 to 1.5 meters thick (O'Kane and Wels 2003).  The soil layers
minimize deterioration due to desiccation, frost action, erosion, animal burrowing, and
infiltration of plant roots [(Caldwell and Reith 1993) as reported in (O'Kane and Wels
2003)].  Covers are not used for submerged tailings, and placing covers on tailings that
have not been dewatered can cause future stability problems
(http://www.idl.idaho.gov/Bureau/Minerals/bmp manuall9927pl6-ch4.pdf).

Diversions and spillway structures are constructed to minimize potential  erosion of the
cover from surface water. Traditionally, water in TSF ponds has been drained as
completely as possible prior to closure to reduce  potential for overtopping and erosion
of the embankments; raising water levels in large dams could cause considerable long-
term risk. However, water covers might be used when feasible to maintain a
submerged condition, such as in regions where the hydrology is well-understood and
the terrain is flat, such as has been used and encouraged in Canada (Martin et al. 2002).

Regardless of the type of reclamation used for closure, the reclaimed facility must be
monitored and maintained to ensure stability over time.  Post-closure monitoring for
contaminant transport is the same as during the operational phase, with piezometers
for assessment of ground water mounding and monitoring wells for groundwater
quality.  The reclaimed facility should be monitored for any deformations, structural
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changes, or weaknesses, and the surfaces should be inspected for intrusion by animals,
humans, or vegetation, any of which could compromise long-term stability.


2.2 ACCIDENTS AND FAILURES

The main causes of physical failures of tailings storage facilities are related to 1) a lack of
control on the water balance; 2) lack of control on construction; and 3) a general lack of
understanding of the features that control safe operating conditions (International
Commission on Large Dams (ICOLD) 2001).  Additionally, the upstream method for dam
construction was found to be more prone to failure as compared to those constructed
via the downstream method  most likely due to embankment material generally having a
low relative density and high water saturation (U.S. EPA, 1994).

In order of prevalence, failure mechanisms observed forTSFs are slope instability,
earthquakes, overtopping, inadequate foundations, seepage, and structural problems
(Blight and Fourie 2003, Commonwealth of Australia 2007).  Failure during operation
could occur from any of the following: 1) rupture of delivery pipeline or decant water
return pipeline; 2) rainfall induced erosion or piping of outer tailings face; 3)
geotechnical failure or excessive deformation of containment dyke; 4) overfilling of the
tailings storage facility leading to overtopping by water; 5) seepage through
containment dyke; and/or 6) seepage into the foundation. In addition to the above
(aside from deliver and return pipelines), failures post-closure could result from failure
of the spillway (if present), or failure of the cover through internal or external forces,
including weathering of materials, erosion, extreme weather events, or intrusion by
vegetation or wildlife (Commonwealth of Australia 2007, Witt et al.  2004).

Earthquakes can cause liquefaction, which is a process in which a soil mass loses shear
resistance through increased water pressure. Liquefaction in the absence of an
earthquake is called static liquefaction.  Static liquefaction can result from slope
instability or another mechanism.  As reported in Davies (Davies 2001), upstream
constructed dams are  "more susceptible to liquefaction flow events and are solely
responsible for all major static liquefaction events"; the author also states that
earthquakes are  of little concern for non-upstream dams. Liquefaction of a large
volume of tailings causes them to flow out of a breach as a viscous liquid which is
capable of moving long distances before coming to rest.  For example, 3 million cubic
meters of tailings escaped at Bafokeng, South Africa, and travelled 42 km before the
remaining 2 million cubic  meters was stopped by flowing into a water retention dam
(Blight and Fourie 2003).  Conventional TSF materials can have very low shear strength
and are susceptible to liquefaction. Therefore, earthquake-induced liquefaction is a key
design consideration to minimize risks of failure resulting from an earthquake event
(Martin et al. 2002). Earthquake risks also are reduced when tailings have a higher
density or are dry tailings.
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Overtopping is caused by excessive water inflow, such as through precipitation or rapid
snowmelt, and is cited as being the primary failure mode for almost half of all reported
incidents occurring at inactive dams (Davies 2001).  Overtopping can result in erosion
and breaching of the embankment to release tailings and contaminated water
downstream. Internal erosion by water (called piping) is a slow process and related to
seepage/infiltration causing internal water pressures to exceed the critical hydraulic
gradient and result in a pathway through which particles are carried.  Guidelines exist
forTSF design to minimize this risk; however, Jantzer and Knutsson (Jantzer and
Knutsson 2010) believe that, at least in Sweden, critical gradient guidelines are
insufficient to yield long-term stability. Unstable materials experience particle migration
at much lower hydraulic  gradients than do more stable or compacted materials.

Structural failure could result in the release of large amounts of tailings solids and
water; for example, a failure at Church Rock, New Mexico released 357,000 cubic
meters of tailings water and ~990 tons of solids into an adjacent stream in 1979 (Witt et
al. 2004). Closed facilities are  more prone  to failures caused by external erosion,
primarily because of a lack of frequent monitoring, which occurs more easily when the
site is occupied daily during  active mining.  Diversion ditches help prevent erosion by
redirecting surface  flow away from the TSF. Usually, failures result from a combination
of factors, with climate, tailings properties, and geometry influencing which of these
processes is likely to be the most prominent cause.  Seepage-related failures are the
main failure mode for tailings dams constructed using downstream or centerline
methods (Davies 2001).  Increases in seepage rates  or turbidity can be key indicators of
a developing failure situation (Alaska Department of Natural Resources (AK DNR) 2005).
Thus,  adequate planning, suitable design, and  monitoring and control of operation and
post closure may prevent deteriorative actions.

The failure  rate of tailings dams depends directly on the engineering methods used  in
design and  the monitoring and inspection programs in the other mine-life stages.
According to Witt et al. (Witt et al. 2004), with an assumption of 3500 worldwide tailings
dams  and failure rates of 2-5 dams per year, the annual probability of a TSF failure is
between 1  in 700 to 1 in  1750, in contrast to < 1 in 10,000 apparent for conventional
water dams. Using data  obtained from the World Information Service of Energy (WISE,
www.wise-uranium.org/mdaf.html) for the 10 years prior to March 22, 2011, Chambers
and Higman (Chambers and  Higman 2011) report that the worldwide failure rate of
tailings dams has remained at 1 failure every 8 months (i.e. two failures every 3 years).
Azam  and Li (Azam  and Li 2010), using databases from the United Nations
Environmental Protection (UNEP), the International Commission on Large Dams (ICOLD),
the World Information Service of Energy (WISE), the United States Commission on Large
Dams (USCOLD), and the United States Environmental Protection Agency (U.S. EPA),
found that causes of observed failures occurring in the years of 2000-2009, regardless of
country (e.g.,  North American, South American, European, Asian, African,  and
Australian), were unusual weather, management, seepage, instability, and defect, in
order of decreasing percentage contribution. Weather causes were observed to have
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increased by 15% from pre-2000 failures and management issues by 20%.  Azam and Li
(Azam and Li 2010) report that failures in all but Europe and Asia have decreased since
2000; this is attributed to improved engineering practices, with none from 2000-2009
being due to subsidence of the foundation or to overtopping. Additionally, seismic
liquefaction was not a causal mechanism in failures between 2000 and 2009, but
accounted for 14% of failures prior to 2000. Data presented indicate that failures
peaked to about 50 per decade in the 1960's through the 1980's and has dropped to
about 20 per decade over the last 20 years, with the frequency of failure occurrences
shifting to developing  countries. The authors also estimate that, on average, one fifth of
the stored tailings are  released resulting from tailings dam failure. Dalpatram
(Dalpatram 2011) presented  a slide at a recent Workshop on Dam Break Analysis that
indicated volumes released range from 20-40% of the stored tailings.

Reports of failures generally discuss physical failures causing a large release of tailings
and/or water, but failure in design,  construction, monitoring, and/or maintenance of the
entire TSF system could result in slow release of contaminants into surface water or
groundwater. Additionally, releases could result from compromise to the cover over
PAG material or from inaccurate prediction of acid-generation potential for storage of
PAG versus NAG tailings.
3. PIT

Following open-pit mining, a wide and deep hole remains that typically is filled in (or fills
naturally) with water to form a pit lake.  The source of environmental influence from
pits and resultant lakes includes their size and the potential for acid-rock drainage (ARD)
from dissolution of sulfidic minerals exposed on pit walls. Contaminated water may
seep into groundwater, overflow  into surface water, or adversely affect waterfowl
landing in the formed pit lake. Additionally, the steep pit slopes generally remain after
closure and continue to pose a risk to wildlife from falling into the pit and not being able
to get out.  Mitigation methods chosen will depend on site-specific considerations, as
well as the future use envisioned  for the pit (McCullough 2011).

3.1 CONVENTIONAL PRACTICES

3.1.1 Operational Phase

During the operational phase, pit  walls are monitored closely for signs of weakness that
might lead to a failure. Suggested means for reducing operational hazards from a slope
failure in a pit include "1) safe geotechnical designs; 2) secondary supports or rock fall
catchment systems; 3) monitoring devices for adequate advance warning of impending
failures; and 4) proper and sufficient scaling of loose/dangerous material from
highwalls" (Girard 2001). Typically, water is pumped or drained out of the pit to allow
safe access as well as to expose material being mined.
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3.1.2 Closure and Post-Closure

At closure, pits may be used as a repository for waste rock, followed by sealing of the
area against air and water exposure, such as by an isolation cover, to minimize the
potential for generation of acidity. Partial backfilling and regrading of upper levels with
subsequent vegetation and/or creation of wetlands  provides for passive water
treatment. Most commonly, pits naturally fill with water over time, from groundwater,
surface water, and precipitation inflows.  Filling may be accelerated by pumping water
from the TSF or other storage ponds both to minimize exposure of any PAG rock wall
materials and PAG waste  rock and/or tailings disposed into the pit at closure to oxygen,
and to balance high pore water pressures to help prevent slope failures. Once the
desired water level is achieved to retain the pit lake  as a sink, water can be directed
away from entering the pit through diversions that were used during the operational
phase, or pit water can be pumped and treated prior to discharge to a surface water
body.

Because the pit walls contain mineralized rock that has been  exposed during the  mining
period, and during the period over which the pit lake forms, pit lake water can become
acidic and/or contain metals and metalloids from natural geochemical processes. If
acidity is anticipated from pit walls, mitigation measures to control for acid generation
(e.g., sealing the  rock against oxidation) and/or for ensuring that any such acidic or
metal/metalloid-laden water would not migrate to surface or groundwater must be
considered.

Water quality modeling can assist  in identifying if a pit lake will become acidic and/or
accumulate  metals and metalloids. The three basic  processes of importance and
considered in modeling include the chemical loading by water sources flowing into the
pit; loading from the rock walls, benches, and fractures behind the walls, and the
geochemistry of the water during the time it has been in the  pit (Morin and Hutt, 2001).
Factors important in these processes include the time of exposure of a surface to both
oxygen and water, and the surface area of reactive materials exposed.  During mining,
oxidized pit wall surfaces are washed with precipitation and that water is pumped out of
the pit, but not all surfaces are reached by precipitation (e.g., fractures behind walls)
and may have years of accumulation of oxidized minerals that will release acid and/or
metals/metalloids into the pit lake once exposed to  water. Although not the only issue,
one inherent difficulty in prediction is that it is difficult to measure or estimate
percentages of surface areas that are flushed regularly, intermittently, or never during
the operational phase of mining for use in modeling anticipated pit water chemistry
(Morin, 1994). Nonetheless, modeling is  useful in planning for closure and post-closure
of the pit.

If production of acidity and contaminant  ions are anticipated, and exposed surfaces
cannot be covered or sealed against oxidation, chemicals may be added to the pit lake
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to neutralize acidity and precipitate metals. Organic material and microorganisms may
be added and conditions optimized for sulfate-reducing bacteria (SRB) to allow for
formation of insoluble metal sulfides in the anaerobic regions of the lake. If pit water
becomes contaminated, treatment of any water leaving the pit would be necessary to
meet applicable water quality standards prior to any discharge.

Barriers, such as fences, berms, or other structures, are constructed to mitigate
unauthorized access by humans and access by wildlife and should be monitored and
maintained regularly for stability.


4. UNDERGROUND MINE WORKINGS

The sources of potential environmental influences from underground mining are similar
to those for open pit mining, i.e., waste rock piles, tailings, dust,  and wastewater. An
additional source of potential  impact to both groundwater and surface water is from
acid  rock drainage from tunnels and adits created during mining. Depending on many
factors, including the depth of the underground mine to the surface and the strength of
the overburden rock, mine workings have the potential to subside and may create a
depression in the landscape and alterations in surface and ground water flows.

4.1 CONVENTIONAL PRACTICES

The mitigation measures to prevent potential significant environmental impacts from
wastes originating from underground  mining are similar to those for open pit mining. In
addition, waste rock and or tailings may be disposed in mined out tunnels, which may
assist in minimizing  impacts from subsidence. Additionally, void-filling grout may be
used to mitigate subsidence. In regions where there is potential for ground water
interaction with mine workings, cracks may be sealed with grouting or other material.
Additionally, groundwater flow paths  may be intercepted  (such as by grouting of faults
and sheer zones, or  by a grout curtain) and thus redirected to avoid the mined out area,
minimizing contact of the water with potentially acid-generating rock surfaces (e.g.,
(Wireman and Stover 2011)).  In some cases, the mine workings are flooded, which, if
done prior to oxidation occurring on PAG surfaces and kept anaerobic, will minimize the
formation of acidic drainage.
5.0 DUST

Mining activities can generate dust during multiple stages in the operational phase,
including those generated during construction of roads, trucking of materials, and heavy
equipment exhaust. Fugitive dusts are diffuse and generated through wind erosion of
large areas, including waste rock piles, tailings, the  pit, and other disturbed areas. Other
dusts originate at locations where  processes are occurring, such as blasting, crushing,
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grinding, and milling. Dusts containing metals from mining activity pose human health
concerns through inhalation. The particles are carried by the wind and may cause
environmental concerns through sedimentation in water bodies and/or by being
transported further downstream.

5.1 CONVENTIONAL PRACTICES

Mitigation of dust from processing points within mining operations can include
collection by dry collectors, wet scrubbers, enclosures at the source, and/or wetting of
surfaces (Commonwealth of Australia 1998). A cover on a truck bed can minimize dusts
originating from materials being hauled. Wetting of surfaces is most useful for active
blasting, haul roads, and material movement and placement activities, and may involve
the use of water or water mixed with a chemical dust suppressant. Typically, dust from
waste rock piles is controlled by wetting during the operational phase.  During closure,
waste rock piles are covered and vegetated; this can be done as piles are completed
during the operational phase to minimize potential for dust production. Although wet
slurry tailings do not pose a dust issue, dust from large dry beaches of tailings facilities is
a concern, and wetting or using special products to stabilize the surfaces is used for
temporary wind erosion and dust control.  Tailings beaches are covered with gravel (or
other material) and may be vegetated during closure.
6. STORM AND WASTEWATER

Storm and wastewater have the potential to contain suspended sediment and
particulate and dissolved contaminants that could contaminant water bodies if they
were to leave the site untreated.  The main environmental influences originate from
seepage of contaminants into groundwater, leakage through barriers (e.g., tailings
embankment), and flooding or washout into nearby surface water bodies.

6.1 CONVENTIONAL PRACTICES

Mitigation of stormwater begins with designing components using an accurate site
water balance to assure adequate storage and treatment capacity.  Conventionally,
runoff and seepage are diverted through ditches and diversion channels to a treatment
pond, or to a settling pond if the water source is solely from precipitation.  Water from
settling ponds can be decanted and discharged (if it meets required water quality
criteria), or used in the mining process if of sufficient quality.  Spillway diversions
commonly are constructed around waste rock and tailings facilities to provide
catchments for precipitation runoff.  Excess water in tailings ponds is controlled through
removal and treatment for use in  the mining processes or discharge to the surface
water.  Traditionally, water in TSF ponds is drained as completely as possible prior to
closure to minimize potential for overtopping due to precipitation.  For TSF ponds
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containing sub-aqueously disposed PAG tailings, sufficient water would remain in the
pond post-closure to ensure they remain isolated from oxygen.

Stormwater from undisturbed areas may require treatment only for sediment, which is
accomplished through simple settling in a sedimentation pond. Stormwater from
disturbed areas and mining wastewater is treated via either active or passive methods
prior to being used in the mining process or released into a water body. Active
treatment of wastewater generally involves a chemical addition (e.g., lime, alum, iron
oxides) to precipitate and/or adsorb metals and metalloids followed by dewatering of
the precipitated solid and disposal; and/or a physical process (e.g., reverse osmosis,
filtration, microfiltration). Operating mines generally have high volumes of water
needing treatment prior to discharge to a surface water body and thus rely on active
treatment methods. Active treatments also include microbial methods, such as the use
of contained bioreactors, but these generally require lower flows and are options for
post-closure or co-treatment during operations. Passive treatments are those that
capitalize on natural processes and do not require constant reagent addition for
operation.  Wetlands are an example of a commonly used passive treatment system for
water contaminants, as are anaerobic biochemical reactors (also called sulfate-reducing
bioreactors).  Passive treatment options are most commonly used post-closure,
although they can be used during the operational phase for other purposes.  For
example, a  biochemical reactor could be used to treat contaminants present in brine
from reverse osmosis treatment.  Passive treatment technologies generally require large
land areas and low flows to allow sufficient time for biological processes to convert
them to non-toxic forms. Additional passive and active treatment options for potential
use post-closure can be found in U.S. EPA (2006).
7. CHEMICALS

Chemicals used at mining sites have the potential to enter into the environment through
accidental spills during transport, storage, and/or use, or from excess usage in processes
to recover metals being mined (e.g., during flotation/frothing, cyanidation, or smelting).

7.1 CONVENTIONAL PRACTICES

Conventional practices include having a chemical hygiene plan and training of all
personnel in the proper handling of chemicals, including how to deal with cleanup of
spills, provision of spill kits and personal protective equipment, and availability of MSDS
for consultation (e.g., see (Logsdon et al. 1999)). Secondary containment (dikes or
collection basins) must be used and incompatible chemicals must be isolated from one
another during storage and use. Storage containers are commonly equipped with
indicators and instrumentation to monitor levels in tanks to ensure that a spill does not
occur, or that any spill/leak is captures quickly when it begins.
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8. PIPELINES

A slurry-concentrate pipeline break or spill has potential to affect aquatic life adversely,
if into a nearby stream. Additionally, placement of pipelines results in land disturbance
and can cause soil/sediment to enter streams through runoff.

8.1 CONVENTIONAL PRACTICES

Pipelines that might be necessary for mining operations include those for transport of
slurry, return water, and fuel for the mining site.  Standard practices for construction,
operation, and monitoring of slurry pipelines are  available from the American Society of
Mechanical Engineers (American Society of Mechanical Engineers (ASME) 2003).

Mitigation measures for pipelines include using the proper pipe material, protection
against leaks, breaks, and corrosion, containment drains or sumps along the corridor,
and secondary containment of the pipeline where crossing a river or transportation
route.  Protection includes increased wall thickness, corrosion inhibitors, and internal
linings or coatings. Joints, welds, valves, etc. are  designed to accommodate expected
stress, as based on flows desired for the pipeline. Pipelines may be equipped with
monitoring systems to detect flow, temperature, or pressure changes, along with alarms
and automatic shutoffs. Pipelines are stress-tested for leaks and weaknesses prior to
being placed into operation; and they require routine inspections over the course of
their use.  Mitigation of construction impacts, such as soil erosion and turbid storm
water runoff caused by pipe installation (e.g., excavation and boring), can include silt
fences, ditches, or other temporary diversions. Pipelines that are constructed near
water bodies require containment and may or may not be placed above ground on
bridge structures.
9. NON-MINING MATERIAL AND DOMESTIC WASTE

Mining operations produce a number of wastes in addition to waste mineral materials.
Additionally, there is domestic waste produced from persons employed. These wastes
have the potential to attract wildlife (food wastes), or to contaminate water bodies
(e.g., sewage waste) and thus must be managed.

9.1 NON-MINING MATERIAL AND  DOMESTIC WASTE

At remote mining sites, non-hazardous wastes generally are managed on site. Non-
hazardous solid wastes typically would  be disposed in engineered solid waste  landfills
that meet regulatory requirements. For some types of wastes, and in some locations,
incineration may be an acceptable alternative. Recycling of segregated wastes such as
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paper and plastic may be preferable, but high transportation costs could make this
option economically unattractive.

Sanitary waste often is treated via a decentralized system (e.g., septic tank) or in a
packaged sewage treatment plant, with the effluent discharged after verification that it
meets the permitted discharge standards. Sewage sludge may be land-farmed, hauled
to a licensed treatment facility, or land filled on site depending on local requirements.
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REFERENCES

Access Consulting Group. 2007. Minto Mine tailings management plan. Available online:
      http://www.emr.gov.yk.ca/mining/pdf/mml minto  tailings management plan.
      pdf, accessed April 24, 2012.
Alaska Department of Natural Resources (AK DNR). 2005. Guidelines for Cooperation
      with the Alaska Dam Safety Program. 230. Dam Safety and Construction Unit,
      Water Resources Section, Division of Mining, Land and Water.
American Society for Testing and Materials (ASTM). 2000. D 5744-96, Standard test
      method for accelerated weathering of solid materials using a modified humidity
      cell. American Society for Testing and Materials.
      http://www.astm.org/DATABASE.CART/HISTORICAL/D5744-96.htm (last
      accessed.
American Society of Mechanical Engineers (ASME). 2003. Slurry transportation piping
      systems, ASME Code for pressure piping, An American Standard. B31.11-2002
      (Revision of ASME B31.11-1989). American Society of Mechanical Engineers.
      http://files.asme.org/catalog/codes/printbook/13875.pdf (last accessed.
Andrina, J., G. W. Wilson, S. Miller & A. Neale. 2006. Performance of the acid rock
      drainage mitigation waste rock trial dump at Grasberg Mine. In Proceedings of
      the 7th International Conference on Acid Rock Drainage (ICARD), March 26-30,
      ed. R. I. Barnhisel, 30-44. St. Louis, MO: American Society of Mining and
      Reclamation.
Azam, S. & Q. Li (2010) Tailings dam failures: a review of the last one hundred years.
      Geotechnical News, December 2010, 50-53.
Blight, G. E. & A. B. Fourie. 2003. A review of catastrophic flow failures of deposits of
      mine waste and  municipal refuse. In Occurrence and mechanisms of flow-like
      landslides in natural slopes and earthfills, Proceedings of the International
      Workshop, Sorrento, Italy, 14-16 May, ed. L. Picarelli. Sorrento, Italy.
Boak, R. & G. Beale. 2008. Mine closure and reclamation - practical examples of options
      and issues. In Mine Water and the Environment, Paper #71, Ostrava (VSB -
      Technical University of Ostrava). 1 Oth 'nternational Mine Water Association
      Congress, Karlsbad, Czech Republic, June 2-5, eds. N. Rapantova & Z. Hrkal.
Brodie, M. J., L.  M. Broughton & A. M. Robertson, Dr. 1991. A conceptual rock
      classification system for waste management and a laboratory method  for ARD
      prediction from rock piles. In Preprint for the 2nd International Conference on the
      Abatement of Acid Drainage, Montreal, Quebec, September 16-18, 17.
Caldwell, J. A. & C. C. Reith. 1993. Principles and practice of waste encapsulation.
      Michigan: Lewis Publishers.
Chambers, D.  M. & B. Higman. 2011. Long term risks of tailings dam failure. 21.
      Bozeman, MT: Report by the Center for Science in Public Participation, Bozeman,
      MT. www.csp2.org.
Commonwealth of Australia. 1998. Best practice environmental management in mining
      - dust control. 50. Australia Department of the Environment.
                                                                             21

-------
                ***internal deliberative materials-do not cite, quote, or distribute***


—. 2007. Tailings management - leading practice sustainable development program for
       the mining industry. 88. Australian Government, Department of Industry,
       Tourism and Resources.
Dalpatram, A. 2011. Estimation of tailings dam break discharges. In USSD Workshop on
       Dam Break Analysis Applied to Tailings Dams. Denver, Colorado.
Davies, M. P. (2001) Impounded mine tailings: What are the failures telling us? CIM
       Distinguished Lecture Series 2000-2001. The Canadian Mining and Metallurgical
       Bulletin, 94, 53-59.
Dawson, R. F. & K. A. Morin. 1996. Acid  mine drainage in permafrost regions: issues,
       control strategies and research requirements. 103. Prepared for Department of
       Indian and Northern Affairs, Canada. MEND Project 1.61.2. Report CG25047.
Eriksson, N., A. Gupta & G. Destouni (1997) Comparative analysis of laboratory and field
       tracer tests for investigating preferential flow and transport in mining waste
       rock. Journal of Hydrology, 143-163.
Girard, J. M. 2001. Assessing and monitoring open pit mine highwalls. In Proceedings of
       the 32nd Annual Institute on Mining Health, Safety and Research. Salt Lake City,
       UT, Aug. 5-7, eds. F. M. Jenkins,  J. Langton, M. K. McCarter & B. Rowe. University
       of Utah.
Hornberger, R. J.  & K. B. C. Brady (1998) Kinetic (leaching) tests for the prediction of
       mine drainage quality. Coal mine drainage prediction and pollution prevention in
       Pennsylvania, 7-1-7-54.
Hough, P. & Robertson, M. (2009) Mitigation under Section 404 of the Clean Water Act:
       where it comes from, what it means. Wetlands Ecology  and Management,
       17:15-33.
International Commission on Large Dams (ICOLD). 2001. Tailings dams, risk of dangerous
       occurrences, lessons learnt from practical experiences, Bulletin 121.
       International Commission on Large Dams, United Nations Environmental
       Programme.
Jantzer, I. & S. Knutsson. 2010. Critical hydraulic gradients in tailings dams in long-term
       perspective. In  Mine Closure 2010. Proceedings of the 5th International
       Conference on Mine Closure: From What Should be Done to What Has Been
       Done,  November 23-26, Vina del Mar, Chile, eds. A. Fourie,  M. Tibbell & J. Wiertz,
       541-553.: Australian Center for Geomechanics.
Koerner, R.M., Hsuan, Y.G., & Koerner, G.R. 2011. GRI White Paper #6 on Geomembrane
       lifetime prediction: unexposed and exposed conditions, Updated 2011.
       http://www.geosynthetic-institute.org/papers/paper6.pdf  (last accessed April
       20, 2012.
Lapakko, K. 2002. Metal mine rock and waste characterization tools: An overview. 31.
       London, England: Commissioned by the MMSD project of the International
       Institute for Environment and Development (IIEA) and the World Business
       Council for Sustainable Development (WBCSD).
Logsdon, M. J., K. Hagelstein & T. I. Mudder. 1999. The management of cyanide in gold
       extraction. International Council on Metals and the Environment.
                                                                             22

-------
                ***internal deliberative materials-do not cite, quote, or distribute***


       http://commdev.org/files/1183 file 28 Cyanide Mgmt Gold Extraction.pdf
       (last accessed October 16, 2011).
Martin, T. E., M. P. Davies, S. Rice, T. Higgs & P. C. Lighthall. 2002. Stewardship of tailings
       facilities. Commissioned by the MMSD project of the International Institute for
       Environment and Development (IIEA) and the World Business Council for
       Sustainable Development (WBCSD). http://pubs.iied.org/pdfs/G01027.pdf (last
       accessed May 26, 2011).
McCullough, C. (2011) Re-defining sustainability- better planning promises better pit
       lake outcomes. CIM Magazine, 6, 46-47.
Miller, S., Y. Rusdinar, R. Smart, J. Andrina & D. Richards. 2006. Design and construction
       of limestone  blended waste rock dumps - lessons learned from a 10-year study
       at Grasberg. In Proceedings of the 7th International Conference of Acid Rock
       Drainage (ICARD), March 26-30, St. Louis, MO, ed. R.I. Barnhisel, 1287-1301.
       American Society of Mining and Reclamation.
Mining Minerals and Sustainable Development (MMSD). 2002. Mining for the Future -
       Appendix A: Large volume waste working paper, No. 31. Commissioned by the
       MMSD project of the International Institute for Environment and Development
       (IIEA) and the World Business Council for Sustainable Development (WBCSD).
       http://pubs.iied.org/pdfs/G00883.pdf (last accessed September 22, 2011).
Morin, K. A. 1994. Prediction of water chemistry in open pits during operation and after
       closure. In Proceedings of the 18th Annual British Columbia Mine Reclamation
       Symposium, Vernon, BC.
Morin, K. A. & N. M.  Hutt. 2004. Equity Division - Review of 2003 ARD assessment of
       ARD mechanisms. Placer Dome, Canada: Prepared for Mike Aziz, Equity Division.
Morin, K. A. & N. M.  Hutt. 2001. Prediction of water chemistry in mine lakes: the
       minewall technique. Ecological Engineering.  17, 125-132.
O'Kane, M. & C. Wels. 2003. Mine waste cover system design - linking predicted
       performance to groundwater and surface water impacts. In Proceedings of the
       6th Annual International Conference on Acid Rock Drainage, July 12-18, Cairns,
       Queensland, Australia, 341-349.
Pastor, M., M. Quecedo, J. A.  Fernandez Merodo, M.I. Herrores, E. Gonzalez & P. Mira
       (2002) Modeling tailings dams and mine waste dumps failures. Geotechnique, 52,
       579-591.
Perry, E., L. Holland,  R. Evans, J. Schueck & D. Maxwell (1998) Special handling
       techniques in the prevention of acid mine drainage. Coal mine drainage
       prediction and pollution prevention in Pennsylvania, 22.
Piteau Associates Engineering Ltd. 1991. Mined rock and overburden piles -
       investigation and design manual: Interim guidelines. Prepared for the British
       Columbia Mine Waste Rock Pile Research Committee, May 1991.
Price, W. A. 2009. Prediction Manual for Drainage Chemistry from Sulphidic Geologic
       Materials. 579. Report prepared by CANMET - Mining and MineralSciences
       Laboratories  for the Mine Environment Neutral Drainage (MEND)  Program,
       Natural Resources Canada.
                                                                             23

-------
                ***internal deliberative materials-do not cite, quote, or distribute***


Price, W. A. & J. C. Errington. 1998. Guidelines for metal leaching and acid rock drainage
       at minesites in British Columbia. 92. BC: British Columbia Ministry of Energy and
       Mines.
Sartz, L,  E. Larsson, S. Sa'dbom & M. Ba'ckstrom. 2011. Weathering of waste rock in
       different climatic conditions - a kinetic freeze/thaw and humidity cell
       experiment. In Proceedings of the 11th International Mine Water Association
       (IMWA) Congress - Mine Water- Managing the Challenges, September 4-11,
       eds. T. R. Rude, A. Freund & C. Wolkersdorfer, 453-456.
SRK Consulting. 2005. Tailings alternatives assessment. Doris North Project, Hope Bay
       Nunavut, Canada. 85. Vancouver, BC.
—. 2009. Mine waste covers in cold regions. MEND Project 1.61.5., 119. Vancouver, B.C.,
       Canada: Prepared for Mine Environment Neutral Drainage program (MEND) by
       SRK Consulting.
Tesarik, D. R. & R. W. McKibbin. 1999.  Material properties affecting the stability of a 50-
       year-old rock dump in an active mine. Report of Investigations 9651. 28.
       Pittsburgh, PA: U.S. Department of Health and Human Services, National
       Institute for Occupational Safety and Health.
U.S. Environmental Protection Agency (Region 10). 2003a. EPA and HardRock Mining: A
       Source  Book for Industry in the Northwest and Alaska. Appendix C.
       Characterization of Ore, Waste Rock, and Tailings. 43. Seattle, WA.
—. 2003b. EPA and Hard rock Mining: A Source Book for Industry in the Northwest and
       Alaska. Appendix F. Solid Waste Management., 43. Seattle, WA.
U.S. Environmental Protection Agency (U.S. EPA). 2006. Engineering Issue: Management
       and treatment of water from hard rock mines. Office of Research and
       Development, Cincinnati, OH. EPA 625-R-06-014. 42.
U.S. Environmental Protection Agency (U.S.EPA). 1994. Technical report: Design and
       evaluation of tailings dams. Office of Solid Waste, Washington, DC. EPA 530-R-
       94-038. 59.
—. 1995a. Office of Compliance sector notebook project - Profile of the metal mining
       industry. 137. Washington, D.C.: Office of Compliance/Office of Enforcement and
       Compliance Assurance.
—. 1995b. The design and operation of waste rock piles at noncoal mines. 53.
       Washington, DC: Office of Solid Waste.
Wilson, G. W.,  D. J. Williams & E. M. Rykaart. 2003. The integrity of cover systems - An
       update. In Proceedings of the 6th Annual International Conference on Acid Rock
       Drainage, 1-8. Cairns, Queensland, Australia.
Wireman, M. & B. Stover (2011) Hard-rock mining and water resources. Groundwater
       News &  Views, 6.
Witt, K. J., M. Schonhardt, R. Saarela, J. Csicsak, M. Csovari, A. Varhegyi, D. P. Geogescu,
       C. A. Radulescu,  M. Zlagnean, J. Bohm, A. Debreczeni, I. Gombkoto, A. Xenidis, E.
       Koffa, A. Kourtis & J. Engels. 2004. Report - Tailings management facilities - Risks
       and Reliability. 178.
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DRAFT                                                 EPA910-R-12-004Bc
DO NOT CITE OR QUOTE                                   April 2013
                                                      Second External Review Draft
                                                      www.epa.gov/bristolbay
      An Assessment of Potential Mining Impacts on Salmon
                  Ecosystems of Bristol Bay, Alaska


                   Volume 3 of 3 -Appendices E-J


      Appendix J: Compensatory Mitigation and Large-Scale
          Hardrock Mining in the Bristol Bay Watershed
                                 NOTICE
   THIS DOCUMENT IS AN EXTERNAL REVIEW DRAFT. It has not been formally released by
   the U.S. Environmental Protection Agency and should not be construed to represent Agency
   policy. It is being circulated for comment on its technical accuracy and policy implications.
                       U.S. Environmental Protection Agency
                                Seattle, WA

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DRAFT                                                    April 2013
DO NOT CITE OR QUOTE                                 Internal Review Draft
                     Appendix J
       Compensatory Mitigation  and
    Large-Scale Hardrock Mining in the
             Bristol Bay Watershed
                         Palmer Hough
                 U.S. Environmental Protection Agency
                         Office of Water
               Office of Wetlands, Oceans and Watersheds

                         Heather Dean
                 U.S. Environmental Protection Agency
                          Region 10
                     Alaska Operations Office
                           NOTICE

     THIS DOCUMENT IS A PRELIMINARY DRAFT. It has not been formally released by
     the U.S. Environmental Protection Agency and should not be construed to
     represent Agency policy. It is being circulated for comment on its technical
     accuracy and policy implications.
                 Office of Research and Development
                 U.S. Environmental Protection Agency
                        Washington, DC

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Comments from the public and peer review members on the May 2012 draft Bristol Bay
Assessment raised concerns that the topic of compensatory mitigation was not
adequately addressed, in particular that the discussion of compensatory mitigation
included in Appendix I of the May 2012 draft assessment did not discuss the efficacy of
potential compensatory mitigation measures.  In response to these comments, this
appendix, which focuses exclusively on compensatory mitigation, has been added to the
Bristol Bay Assessment. This appendix provides an overview of Clean Water Act Section
404 compensatory mitigation requirements for unavoidable impacts to aquatic
resources and discusses an array of measures that various entities have proposed as
having the potential to compensate for the unavoidable impacts to wetlands, streams,
and fish identified in the Bristol Bay Assessment. Please note that any formal
determinations regarding compensatory mitigation can only take place in the  context of
a regulatory action. The Bristol Bay Assessment is not a regulatory action, and thus a
complete evaluation of compensatory mitigation is considered outside the scope of the
assessment.

1 Overview of Clean Water Act Section 404 Compensatory Mitigation Requirements

Compensatory mitigation refers to the restoration, establishment, enhancement, and/or
preservation of wetlands, streams, or other aquatic resources conducted specifically for
the purpose  of offsetting authorized impacts to these resources (Hough and Robertson,
2009). Compensatory mitigation regulations jointly promulgated by the U.S.
Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (ACOE)
(40 CFR §§ 230.91 - 230.98 and 33 CFR §§ 332.1 - 332.8) state that "the fundamental
objective of compensatory mitigation is to offset environmental losses resulting from
unavoidable impacts to waters of the United States authorized by [Clean Water Act
Section 404 permits issued by the ACOE]" (40 CFR Part 230.93(a)(l)). Compensatory
mitigation enters the analysis only after a proposed project has incorporated all
appropriate and practicable means to avoid and minimize adverse impacts to  aquatic
resources (40 CFR Part 230.91(c)).

Section 404 permitting requirements for compensatory mitigation are based on what is
"practicable  and capable of compensating for the aquatic resource functions that will be
lost as a result of the permitted activity" (40 CFR Part 230.93(a)(l)). In determining
what compensatory mitigation will be "environmentally preferable," the ACOE "must
assess the likelihood for ecological success and sustainability, the location of the
compensation site relative to the impact site and their significance within the
watershed, and the costs of the compensatory mitigation project"(40 CFR Part
230.93(a)(l)).  Furthermore, compensatory mitigation requirements must be
commensurate with the amount  and  type of impact associated with a particular Section
404 permit (40 CFR Part 230.93(a)(l)). The regulations recognize that there may be
instances when the ACOE cannot issue a permit "because of the lack of appropriate and
practicable compensatory mitigation  options" (40 CFR Part 230.91(c)(3)).

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1.1 Compensatory Mitigation Methods

Compensatory mitigation can occur through four methods: aquatic resource restoration,
establishment, enhancement, or in certain circumstances, preservation (40 CFR Part
230.93(a)(2)). Restoration  is the reestablishment or rehabilitation of a wetland, stream,
or other aquatic resource with the goal of returning natural or historic functions and
characteristics to a former  or degraded aquatic resource.  When it is an option,
restoration is generally the preferred method,  due in part to its higher likelihood of
success as measured by gain in aquatic resource function, area, or both. Establishment,
or creation, is the development of a wetland or other aquatic resource where one did
not exist previously, with success measured as a net gain in both area and function of
the aquatic resource.

Enhancement includes activities conducted within existing aquatic resources that
heighten, intensify, or improve one  or more aquatic resource functions, without
increasing the area of the aquatic resource. Examples include improved floodwater
retention or wildlife habitat. Preservation is the permanent protection of aquatic
resources and/or upland buffers or  riparian areas through legal and physical
mechanisms, such as conservation easements and title transfers. Because preservation
does not replace lost aquatic resource area or functions, regulations limit its use to
situations in which the resources to be preserved provide  important functions for and
contribute significantly to the ecological sustainability of the watershed, and those
resources are under threat of destruction or adverse modification (40 CFR Part
230.93(h)).

1.2 Compensatory Mitigation Mechanisms

There are three general mechanisms for achieving the four methods of compensatory
mitigation (listed in order of preference as established  in 40 CFR 230.93(b)): mitigation
banks, in-lieu fee programs, and permittee-responsible mitigation.  A mitigation bank is
a site with restored, established, enhanced, or preserved aquatic resources, riparian
areas and/or upland buffers that the ACOE has approved for use to compensate for
losses from future permitted activities. The bank approval process establishes the
number of available compensation credits, which permittees may purchase  upon  ACOE
approval that the bank represents appropriate compensation. The bank sponsor is
responsible for the success of these mitigation sites.

For in-lieu fee mitigation, a permittee provides funds to an in-lieu fee program sponsor
who  conducts compensatory mitigation projects under agreement with the ACOE,
typically after pooling funds from multiple permittees.  The in-lieu fee program sponsor
is responsible for the success of these mitigation sites.

In permittee-responsible mitigation, the permittee undertakes and bears full
responsibility for the implementation and success of the mitigation. Mitigation may

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occur either at the site where the regulated activity caused the loss of aquatic resources
(on-site) or at a different location (off-site), preferably within the same watershed.

Although it is the permit applicant's responsibility to propose an appropriate
compensatory mitigation option, mitigation banks and in-lieu fee programs are the
federal government's preferred forms of compensatory mitigation as they "usually
involve consolidating compensatory mitigation projects where ecologically appropriate,
consolidating resources, providing financial planning and scientific expertise (which
often is not practical for permittee-responsible compensatory mitigation projects),
reducing temporal losses of functions, and reducing uncertainty over project success"
(40 CFR 230.93(a)(l); see also 40 CFR 230.93(b)).

1.3 Watershed Approach and the Location, Type, and Amount of Compensation

Regulations regarding compensatory mitigation require the use of a watershed
approach to "establish compensatory mitigation requirements in [Department of the
Army] permits to the extent practicable and appropriate" (40 CFR 230.93(c)(l)). Under
the regulations, the  watershed approach to compensatory mitigation site selection and
planning is an analytical process for making compensatory mitigation decisions that
support the sustainability or improvement of aquatic resources in a watershed.  It
involves consideration of watershed needs, and how locations and types of
compensatory mitigation projects address those needs (40 CFR 230.92). The regulations
specifically state that compensatory mitigation generally should occur within the same
watershed as the impact site and in a location where  it is most likely to successfully
replace lost functions and services (40 CFR 230.93(b)(l)). The goal of this watershed
approach is to "maintain and improve the quality and quantity of aquatic resources
within watersheds through strategic selection of compensatory mitigation sites" (40 CFR
230.93(c)(l)).

The regulations emphasize using existing watershed plans to inform compensatory
mitigation decisions, when such plans are determined to be appropriate for use in this
context (40 CFR 230.93(c)(l)). Watershed  plans that could support compensatory
mitigation decision-making are typically:

       "...developed by federal, tribal, state, and/or local government agencies  or
       appropriate non-governmental organizations, in consultation with relevant
       stakeholders, for the specific goal of aquatic resource restoration, establishment,
       enhancement and preservation.  A watershed plan  addresses aquatic resource
       conditions in the watershed, multiple stakeholder interests, and land uses.
       Watershed plans may also identify  priority sites for aquatic resource restoration
       and protection" (40 CFR 230.92).

Where appropriate plans do not exist, the  regulations describe the types of
considerations and information that should be used to support a watershed approach to

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compensation decision-making. Central to the watershed approach is consideration of
how the types and locations of potential compensatory mitigation projects would
sustain aquatic resource functions in the watershed.  In order to achieve that goal, the
regulations emphasize that mitigation projects should, where practicable, replace the
suite of functions typically provided by the affected aquatic resource, rather than
focusing on specific individual functions (40 CFR 230.93(c)(2)). For this purpose,
"watershed" means an "area that drains to a common waterway, such as a stream, lake,
estuary, wetland, or ultimately the ocean" (40 CFR 230.92). Although there is flexibility
in defining geographic scale, the watershed "should not be larger than is appropriate to
ensure that the aquatic resources provided through compensation activities will
effectively compensate for adverse environmental impacts resulting from [permitted]
activities" (40 CFR 230.93(c)(4)).

With regard to type, in-kind mitigation (i.e., involving resources similar to those being
impacted) is generally preferable to out-of-kind mitigation, because it is most likely to
compensate for functions lost at the impact site (40 CFR 230.93(e)(l)).  Furthermore,
the regulations recognize that, for difficult-to-replace resources such as  bogs, fens,
springs, and streams, in-kind "rehabilitation, enhancement, or preservation" should be
the compensation of choice, given the greater likelihood of success of those types of
mitigation (40 CFR 230.93(e)(3)).

The amount of compensatory mitigation required must be, to the extent practicable,
"sufficient to  replace lost aquatic resource functions" (40 CFR 230.93(f)(l)), as
determined through the use of a functional or condition assessment. If  an applicable
assessment methodology is not available,  the regulations require a minimum one-to-
one acreage or linear foot compensation ratio (40 CFR 230.93(f)(l)).  Certain
circumstances require higher ratios, even  in the absence of an assessment methodology
(e.g., use of preservation, lower likelihood of success, differences in functionality
between the impact site and compensation project, difficulty of restoring  lost functions,
the distance between the impact and compensation sites) (40 CFR 230.93(f)(2)).

1.4 Compensatory Mitigation Guidance for Alaska

In addition to the federal regulations regarding compensatory mitigation, the agencies
have also developed compensatory mitigation guidance applicable specifically to Alaska.
In their 1994 Alaska Wetlands Initiative Summary Report, EPA and the Department of
the Army concluded that it was not necessary to provide "broad exemptions" from
mitigation sequencing in Alaska, given the "inherent flexibility provided  by" the
regulations and associated guidance. The  agencies also recognized that "it may not
always be practicable to provide compensatory mitigation through wetlands restoration
or creation in areas where there is a high proportion of land which is wetlands. In cases
where potential compensatory mitigation  sites are not available due to the abundance
of wetlands in a region and lack of enhancement or restoration sites, compensatory
mitigation is not  required under the [Section 404(b)(l)] Guidelines" (EPA et al., 1994).  In

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promulgating the compensatory mitigation regulations in 2008, EPA and the ACOE
specifically referenced the 1994 policy and reiterated the flexibility and discretion
available to decision-makers (e.g., 40 CFR 230.91(a)(l), 40 CFR 230.93(a)(l)).

While opportunities for wetland restoration and creation continue to be rather limited
in Alaska, a number of other wetland compensatory mitigation options (e.g., mitigation
banks, in-lieu fee programs) have become available since 1994. Moreover, it is
important to note that the 1994 policy applies only to compensatory mitigation for
impacts to wetlands and is silent with regard to compensatory mitigation for impacts to
Alaska streams.  Furthermore, subsequent guidance issued by the ACOE' Alaska District
in 2009 clarifies that fill placed in streams or in wetlands adjacent to anadromous fish
streams in Alaska will require compensatory mitigation (ACOE 2009). A 2011
supplement to the Alaska District's 2009 guidance further recommends that projects in
"difficult to replace" wetlands, fish-bearing waters, or wetlands within 500 feet of such
waters will also likely require compensatory mitigation, as will "large scale projects with
significant aquatic resource  impacts," such as "mining development" (ACOE 2011).

The ACOE's 2009 Alaska guidance also provides sample compensatory mitigation ratios
based on the type of mitigation and the ecological value of the impacted resource (high,
moderate, or low). These guidelines include streams in the high quality category,
indicating compensation ratios of 2:1 for restoration and/or enhancement and 3:1 for
preservation (ACOE 2009).

2 Compensatory Mitigation Considerations for the Bristol Bay Assessment

2.1 Important Ecological Functions and Services Provided by Affected Streams and
Wetlands

Bristol Bay's stream and wetland resources support a world-class commercial and sport
fishery for Pacific salmon and other important fish. They have also supported a salmon-
based culture and subsistence-based lifestyle  for Alaska Natives in the watershed for at
least 4,000 years. Bristol Bay's streams and wetlands support production of 35 species
offish including all five species of Pacific salmon found in North America: sockeye
(Oncorhynchus nerka), coho (0. kisutch), Chinook or king (0. tshawytscha), chum (0.
keta), and pink (0. gorbuscha).  Because no hatchery fish are raised or released in the
watershed, Bristol Bay's salmon populations are entirely wild.  These fish are
anadromous, hatching and rearing in freshwater systems, migrating to the sea to grow
to adult size, and returning to freshwater systems to spawn and die. Bristol Bay's
streams and wetlands support a diverse array of salmon populations that are unique to
specific drainages within the Bay and this population diversity is key to the stability of
the overall  Bristol Bay salmon fishery (i.e., the portfolio effect) (Schindler et al. 2010).

As discussed in detail in the  Bristol Bay Assessment (see Chapter 7), streams and
wetlands that would be lost as a result of the  mine footprints described in the

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assessment's scenarios provide important ecological functions. These headwater
streams and associated wetlands provide spawning habitat for coho and sockeye
salmon and likely spawning habitat for anadromous and resident forms of Dolly Varden.
They also provide rearing habitat for chum salmon, sockeye salmon, Chinook salmon,
coho salmon, Dolly Varden, rainbow trout, Arctic grayling, slimy sculpin, northern pike,
and ninespine stickleback (Johnson and Blanche in press, ADFG 2012a).

In addition to providing habitat for stream fishes,  headwater streams and wetlands
serve an important role in the stream network by contributing nutrients, water, organic
material, and macroinvertebrates downstream, to higher order streams in the
watershed. In the northeastern United States, headwaters contribute approximately
70% of the water volume and 65% of the nitrogen flux to second-order streams and 55%
of the volume and 40% of the nitrogen flux to fourth- and higher-order rivers (Alexander
et al. 2007).  The contributions of headwaters to downstream systems results from their
high density in the dendritic stream network.  Headwater streams also have high rates
of instream nutrient processing and storage due to extensive hyporheic zone
interactions resulting from a large bed surface area compared to the volume of the
overlying water (Alexander et al. 2007).

Both invertebrates and detritus are exported from headwaters to downstream reaches
and provide an important energy subsidy for juvenile salmonids (Wipfli and Gregovich
2002).  Headwater wetlands and associated wetland vegetation can also be important
sources of dissolved  organic matter, particulate organic matter, and macroinvertebrate
diversity (King et al. 2012), contributing to the chemical, physical, and biological
condition of downstream waters (Shaftel et al. 2011, Dekar et al. 2012, Walker et al.
2012). The losses of headwater streams and wetlands due to the mine footprint  would
reduce inputs of organic material, nutrients, water, and macroinvertebrates to reaches
downstream of the mine footprints.

2.2 Identifying the Appropriate Watershed Scale for Compensatory Mitigation

As previously noted, the regulations regarding compensatory mitigation specifically
state that compensatory mitigation generally should occur within the same watershed
as the impact site and  in a location where it is most  likely to successfully replace lost
functions and services  (40 CFR 230.93(b)(l)).

For the mine scenarios evaluated in the Bristol Bay Assessment, the lost functions and
services occur in the watersheds that drain to the North Fork Koktuli (NFK) and South
Fork Koktuli (SFK) Rivers and Upper Talarik Creek (UTC).  Accordingly, the most
appropriate geographic scale  at which to compensate for any unavoidable impacts
resulting from such a project would be within  these same watersheds, as this location
would offer the  greatest likelihood that compensation measures would replace the
"suite of functions typically provided by the affected aquatic resource" (40 CFR
230.93(c)(2)). An important consideration is that compensation projects within these

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watersheds appear to offer the only opportunity to address impacts to salmon
populations that are unique to these drainages (Yocom and  Bernard 2013) and thus
sustain the population diversity that is key to the stability of the overall Bristol Bay
salmon fishery (i.e., the portfolio effect) (Schindler et al. 2010).

If there are no practicable or appropriate opportunities to provide compensation in
these watersheds, it may be appropriate to explore options in adjoining watersheds.
However, defining the watershed scale too broadly would likely fail to ensure that
wetland, stream and associated fish losses from the mine scenario are effectively offset,
because compensation in a different watershed(s) would not address impacts to the
portfolio effect from losses in the impacted watersheds.  Similarly, compensation in
different watersheds would not address impacts to the subsistence fishery where users
depend on a specific temporal and  spatial distribution  of fish to ensure nutritional needs
and cultural values are maintained  (see Bristol Bay Assessment Chapter 12).

3 Potential Compensatory Mitigation Measures in Bristol Bay

The mine scenarios evaluated in the Bristol Bay Assessment identify that the mine
footprints alone will result in the loss of (i.e., filling, blocking or otherwise eliminating)
hundreds to thousands of acres of high-functioning wetlands and tens of miles of
salmon-supporting streams. Such extensive habitat losses could also result in the loss of
unique salmon populations, potentially eroding the genetic diversity that is essential to
the stability of the overall Bristol Bay salmon fishery (i.e.  reduction in the "portfolio
effect").

The public and peer review comments on the  draft Bristol Bay Assessment identified an
array of compensation measures that commenters believed could potentially offset
these impacts to wetlands, streams, and fish.  Yocom and Bernard (2013) recently
reviewed the likely efficacy of a subset of these potential measures at offsetting
potential adverse effects.  The following discussion does  so for the complete array of
compensation measures proposed  by commenters, in the order that the regulations
prescribe for considering compensation mechanisms:  (1) mitigation bank credits; (2) in-
lieu fee program credits; and (3) variations of  permittee-responsible mitigation.

3.1 Mitigation Bank Credits

There are currently no approved  mitigation banks with service areas1 that cover the
impact site for the mine scenarios;  thus, no mitigation  bank credits are available.
Should one or more bank sponsors pursue the establishment of mitigation bank sites to
1 The service area is the watershed, ecoregion, physiographic province, and/or other geographic area
within which the mitigation bank or in-lieu fee program is authorized to provide compensatory mitigation
(40CFR230.98(d)(6)(ii)(A)).

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address the impacts associated with the mine scenario, they would likely encounter the
same challenges described below in section 3.3.

3.2 In-Lieu Fee Program Credits

There is currently one in-lieu fee program approved to operate in the Bristol Bay
watershed, administered  by The Conservation Fund (TCP) since 1994. The TCP program
operates statewide, and the Bristol Bay watershed falls within one of its service areas.
According to TCP, its compensation projects consist almost entirely of wetland
preservation. To date, TCP has completed four wetland preservation projects in the
Bristol Bay watershed, financed in part with in-lieu fee funds. The majority of in-lieu
fees collected by the TCP  program have been for relatively small  impacts to  aquatic
resources. Statewide, TCP has accepted in-lieu fees to compensate for a few projects
with over 50 acres of impacts; to date, the largest impact represented in the TCP
program is the loss of 267 acres of wetlands associated with the  development of the
Point Thomson natural gas production/processing facilities on Alaska's Beaufort Sea
coast. Thus, it is not clear if this program could effectively provide the magnitude of
compensation necessary to address the loss of hundreds to thousands of acres of high
functioning wetlands and tens of miles of salmon-supporting streams associated with
the mine scenario.  In addition, it is likely that any in-lieu fee sponsor seeking to address
the impacts associated with the mine scenario would encounter  the same challenges
described below in section 3.3.

3.3 Permittee-Responsible Compensatory Mitigation

Currently, there is no watershed plan for the NFK, SFK, or UTC, or other components of
the Nushagak or Kvichak River drainages that could serve as a guide to permittee-
responsible compensatory mitigation, by identifying degraded aquatic resources or
immediate or long-term aquatic resource needs that a mitigation project could address.
In the absence of such a plan, the regulations call for the use of a watershed approach
that considers information on watershed conditions and  needs, including potential sites
and priorities for restoration and preservation (40 CFR 230.93(c)). When a watershed
approach is not practicable, the next option is to consider on-site (i.e., the same site as
the impacts, or adjoining  land) and in-kind compensatory mitigation for project impacts,
taking into account both practicability and compatibility with the proposed project (40
CFR 230.93(b)(5)). When  such measures would be impracticable, incompatible, or
inadequate, the last resort would be off-site and/or out-of-kind mitigation opportunities
(40CFR230.93(b)(6)).

3.3.1 Opportunities within the NFK, SFK, and UTC Watersheds

In the context of the mine scenario, the primary challenge to both a watershed
approach and on-site compensatory mitigation is the absence of existing degraded
resources and watershed  needs within the NFK, SFK and  UTC watersheds. Specifically,

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these three watersheds are largely unaltered by human activities, and there appear to
be no sites that a mitigation project could restore or enhance to offset the magnitude of
impacts expected from the mine scenarios.

Here we discuss other specific suggestions for potential compensation measures within
the NFK, SFK and UTC watersheds provided in the public and peer review comments.

3.3.1.1 Beaver Dam Removal

One commenter suggested the removal of beaver dams as a potential compensation
measure. Beavers preferentially colonize headwater streams because of their shallow
depths and narrow widths (Collen and Gibson 2001, Pollock et al. 2003). An aerial
survey of active beaver dams in the mine area, conducted in October 2005, mapped a
total of 113 active beaver colonies (PLP 2011). Presumably, the rationale for this
recommendation is that beaver dams can block fish passage, limiting fish access to
otherwise suitable habitat and, therefore, the removal of beaver dams could increase
the amount of available fish habitat. This rationale is based upon early research that led
to the common fish management practice of removing beaver dams in order to protect
certain fish populations like trout (Saylor 1935, Reid 1952, in Pollock et al. 2004).
However, more recent research has documented numerous benefits of beaver ponds to
fish populations and habitat (Pollock et al. 2003, Murphy et  al. 1989).  For example,
Bustard and Narver (1975) found that a series of beaver ponds on Vancouver Island had
a survival rate for overwintering juvenile coho salmon that was twice as  high as the 35%
estimated for the entire stream. Also, compared to historical levels, Pollock et al. (2004)
estimated a 61%  reduction in summer habitat capacity for coho salmon in one
Washington watershed, largely as the result of the  loss of beaver ponds.

Kemp et al. (2012) recently published a definitive review of the effects of beaver in
stream systems, indicating that they have a positive impact on sockeye, coho, and
Chinook salmon as well as Dolly Varden,  rainbow trout, and steelhead. Using meta-
analysis and weight-of-evidence methodology, the  review showed that most (71.4%)
negative effects, such as low dissolved oxygen and  impediment to fish movement, lack
supportive data and are speculative in nature, whereas the majority (51.1%) of positive
impacts cited are quantitative in nature and well-supported by data (Kemp et al. 2012).
In addition to increased invertebrate (i.e., food) production and habitat heterogeneity,
the study cited the importance of beaver ponds as  rearing habitat due to the increased
cover and protection that higher levels of woody material and overall structural
diversity provide.  Other studies have identified beaver ponds as excellent salmon
rearing habitat because they have high macrophyte cover, low flow velocity,  and
increased temperatures, and they trap organic materials and nutrients (Nickelson et al.
1992, Collen and  Gibson 2001, Lang et al. 2006). Studies in Oregon have shown that
salmon abundance is positively related to pool size, especially during low flow
conditions (Reeves et al. 2011), and beaver ponds provide particularly large pools.

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During winter, beaver ponds typically retain liquid water below the frozen surface,
providing refugia for coho salmon (Nickelson et al. 1992, Cunjak 1996).

Beaver dams generally do not constitute significant barriers to salmonid migration even
though their semi-permeability may temporarily limit fish  movement during periods of
low stream flow (Pollock and Werner 2003, Rupp 1954, Card 1961, Bryant 1984, Pollock
and Werner 2003). Even when beaver dams impede fish movements seasonally (i.e.,
under low flow conditions), the effects are typically temporary, with higher flows from
storm events ultimately overtopping them or blowing them out (Leidholt-Bruner et al.
1992, Kemp et al. 2012). Even the temporary effect may be  limited, when seasonal
rainfall is at least average (Snodgrass and Meffe 1998, Kemp et al. 2012). Adding to the
body of evidence, Pacific salmon and other migratory fish  species commonly occur
above beaver dams. One study in southeast Alaska documented coho  salmon upstream
of all surveyed beaver dams, including one that was two meters high; in fact, the survey
recorded highest coho densities in streams with beaver (Bryant 1984).  Other surveys
have documented both adult and juvenile sockeye salmon, steelhead, cutthroat, and
char upstream of beaver dams (Bryant 1984, Swales et al.  1988, Murphy et al. 1989,
Pollock etal. 2003).

The current body of literature describing the effects of beaver dams on salmonid species
shows that there are generally more positive associations  with beaver dam activity than
negative associations (Kemp et al. 2012). Hence, removal  of beaver dams as a means of
compensatory mitigation could lead to a net negative impact on salmonid abundance,
growth, and productivity.  Moreover, since the mine scenario would eliminate or block
several streams with active beaver colonies in the headwaters of the SFK and UTC, the
benefits provided by those habitats would be part of the suite of functions that
compensatory mitigation should aim to offset.

3.3.1.2. Flow Management

One commenter suggested that fish habitat productivity could be improved through
careful water management at the mine scenario site, including the storage and strategic
delivery of excess water to streams and aquifers without adverse impacts such as
seasonally incompatible temperatures.  Although flow management has been
performed at  certain mine sites with limited success (e.g.,  Red Dog Mine, Alaska),  we
are unaware of any documentation of successful attempts to control the temperature of
water releases at mine sites. Purposeful release of low temperature water has been a
common practice downstream of hydroelectric dams in the Pacific Northwest.
However, in contrast to tailings impoundments, these hydroelectric  reservoirs generally
contain cold, relatively clean water at the depth from which  they release water.
According  to the  Bristol Bay Assessment, large  amounts of water would be necessary to
mimic natural flow conditions in the NFK, SFK, and UTC watersheds, posing enormous
logistical challenges to operators, particularly in attempting to mimic periods of natural
high flow (i.e., spring runoff or fall rain events). Highly experimental and unpredictable
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activities are generally discouraged as compensatory mitigation (40 CFR 230.93(a)(l);
see also 73 FR 19633). However, if specific flow management plans prove to be feasible
and ecologically beneficial, such measures would likely be required to minimize the
impacts of flow reduction (e.g., aquatic habitat loss) resulting from water use at the
mine, rather than compensating for unavoidable impacts.

3.3.1.3 Spawning Channel Construction

One commenter suggested the creation of spawning channels as a means to
compensate for lost salmon spawning areas. The intent of a constructed spawning
channel is to simulate a natural salmon stream by regulating flow, gravel size, and
spawner density (Hilborn 1992). There is some history of using constructed spawning
channels to mitigate for the impacts of various development projects on fish, based on
the premise that they would produce fry, which would result in more adult fish
returning. However, there are very few studies regarding the efficacy of such channels
in the published literature.  Hilborn (1992) indicates that success, measured by
increased production of adult fish from such channels, is unpredictable and generally
unmonitored. Constructed spawning channels also require annual maintenance and
cleaning, and salmon using them can be prone to disease outbreaks (Mulcahy et al.
1982). The need for frequent  maintenance would be contrary to the  regulations' intent
that compensatory mitigation  projects be self-sustaining (40 CFR 230.97(b)). In light of
their uncertain track record, it does not appear that constructed  spawning channels
would provide reliable and sustainable fish habitat.

3.3.1.4 Preservation

As described above, preservation as compensatory mitigation for the mine scenarios
would require a site that is very large, performs similarly important aquatic functions,
and is under threat of destruction or adverse modification. No commenters identified
specific potential preservation sites, either within these watersheds or elsewhere in
Bristol Bay. One challenge in identifying appropriate preservation sites is the high
percentage of state and federal land ownership in the area.  Public lands can provide
mitigation, but only if the mitigating measure—in this case, preservation—is "over and
above [that] provided by public programs already planned or in place" (40 CFR
230.93(a)(3)). Further, the aquatic functions of any preservation site  downstream from
the proposed mine scenario would be subject to degradation from the direct,
secondary, and cumulative effects  of the  mine itself. These factors could limit most
properties of adequate area and similar aquatic function from serving as acceptable
mitigation sites. Moreover, there is no precedent for such a preservation-dominated
compensation approach  in the context of this type and magnitude of ecological losses.

3.3.2 Off-site and/or Out-of-Kind Opportunities
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There are a few scattered degraded sites in more distant portions of the Nushagak and
Kvichak River watersheds that could potentially benefit from restoration or
enhancement.

3.3.2.1 Old Mine Site Remediation

The U.S. Geologic Survey (USGS) identifies four small mine sites within the Nushagak
and Kvichak River watersheds: Red Top (in the Wood River drainage), Bonanza Creek (a
Mulchatna  River tributary), Synneva orScynneva  Creek (a Bonanza Creek tributary), and
Portage Creek (in the Lake Clark drainage)  (USGS  2008, 2012).  These sites could provide
opportunities for performing ecological restoration or enhancement. However, due to
their relatively small size and distant location, it is unlikely that these sites could provide
sufficient restored or enhanced acreage or ecological function to offset what would be
lost at the mine scenario site. Further, some mitigation measures have already occurred
at these mines; for example, there have been some remediation activities at Red Top
mine, although traces of mercury and diesel-range organics remain in soils (BLM 2000).
Resolution of liability and contamination issues at these old mines would be necessary
before they could serve as compensatory mitigation sites for other projects.

3.3.2.2 Road Removal

Another potential type of off-site restoration in the region is the removal of existing or
abandoned roads. As described in detail in Appendix G, roads have persistent,
multifaceted impacts on ecosystems and can strongly affect water quality and fish
habitat. Common long-term  impacts from roads  include: 1) permanent loss of natural
habitat; 2) increased surface runoff and  reduced groundwaterflow; 3) channelization or
structural simplification of streams and hydrologic connectivity; and 4) persistent
changes in the chemical composition of water and soil (Darnell et al. 1976).  More
recent literature identifies three other categories of impact common to roads: 1)
disruption of movements of animals, including fishes and other freshwater species; 2)
aerial transport of pollutants via road dust; and 3) disruption of near-surface
groundwater processes, including interception or re-routing of hyporheic flows, and
conversion of subsurface slope groundwater to surface flows (Trombulak and Frissell
2000, Forman 2004).  Road removal, thus,  could facilitate not only the reestablishment
of former wetlands and stream channels, but also the enhancement of nearby aquatic
resources currently degraded by the road(s).

Commenters did not offer specific suggestions for potential road  removal sites. As
Appendix G highlights, the Nushagak and Kvichak River watersheds are almost entirely
roadless areas (see Figure 1). Further, it is unlikely that local communities would
support removal of any segments of the few existing roads in the watersheds.  Thus, it
would appear there are very few, if any, viable opportunities to provide environmental
benefits through road removal.
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3.3.2.3 Road Stream Crossing Retrofits

Another potential type of off-site enhancement in the region is to retrofit existing road
stream crossings to improve fish passage through these man-made features. Stream
crossings can adversely impact spawning, rearing (Sheer and Steel 2006, Davis and Davis
2011), and refuge habitats (Price et al. 2010), as well as reduce genetic diversity
(Wofford et al. 2005, Neville et al. 2009). These changes can in turn reduce long-term
sustainability of salmon populations (Hilborn et al. 2003, Schindler et al. 2010). Fish
passage is a well-documented problem commonly associated with declines in salmon
and other fish populations in many regions of the United States (Nehlsen et al. 1991,
Bates et al. 2003), including Alaska (ADFG 2012b).

Removing and replacing failing crossings that serve as barriers  to fishes could improve
fish passage and re-open currently inaccessible habitat. However, as noted in Section
3.3.2.2, the Nushagak and Kvichak River watersheds are almost entirely roadless areas,
and thus offer few, if any, viable opportunities to provide the extent of environmental
benefits necessary to offset the magnitude of impacts associated with the mine scenario
and associated development. Further, prior to concluding that any effort to retrofit
existing stream crossings would be appropriate compensatory  mitigation, it would first
be necessary to determine that no other party has responsibility for the maintenance of
fish passage at those stream crossings (e.g., through the terms or conditions of a Section
404 permit that authorized the crossing).

Alone, the transportation corridor for the mine scenario would create approximately 70
new stream crossings between the mine site and  Cook Inlet (Appendix G).  Of the 64
stream crossings within the Nushagak and Kvichak River basins, 20 would be over
streams listed as supporting anadromous fishes in the State of Alaska's Anadromous
Waters Catalog and an additional 33 would be over streams that are likely to support
salmonid fishes based on a stream gradient of < 12% (Table 10-8). As detailed in the
Bristol Bay Assessment, there will be numerous challenges associated  with ensuring that
these stream crossings do not create new barriers to fish that would expand and
exacerbate adverse impacts associated with the mine footprint.

3.3.2.4 Hatchery Construction

One commenter referenced the potential use of hatcheries as  a compensation measure.
Such a proposal would be very problematic, particularly in the  context of Bristol Bay,
where the current salmon population is entirely wild. There are several concerns over
the introduction of hatchery-produced salmon to the Bristol  Bay watershed, best
expressed by the National Oceanic and Atmospheric Administration's Northwest
Fisheries Science Center:

      Over the past several decades, wild salmon populations have declined
      dramatically, despite, and perhaps sometimes because  of, the contribution of
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       hatcheries. Many salmon stocks in Washington and Oregon are now listed as
       either threatened or endangered under the U.S. Endangered Species Act. With
       this decline has come an increased  focus on the preservation of indigenous wild
       salmon stocks.

       Hatcheries have the potential to assist in the conservation of wild stocks, but
       they also pose some risks. At this time, scientists still have many questions about
       the extent to which hatchery programs enhance or threaten the survival of wild
       populations. Additional research and investigation is needed (NOAA 2012).

Many of the potential risks associated with fish hatcheries concern reductions in fitness,
growth, health, and productivity that result from decreases in genetic diversity when
hatchery-reared stocks hybridize with wild salmon populations. Hatchery-raised salmon
have lower genetic diversity than  wild salmon (Christie et al. 2011, Yu et al. 2012).
Consequently, when hatchery-raised  salmon hybridize with wild salmon, the result can
be a more genetically homogenous population, leading to decreases in genetic fitness
(Waples 1991). In some cases, wild populations can become genetically "swamped" by
hatchery stocks. Zhivitovsky et al. (2012) found evidence of such swamping in a wild
chum salmon population in Kurilskiy Bay, Russia during a  two-year period of high rates
of escaped hatchery fish. This genetic homogenization is of concern because hatchery-
raised fish stocks are  considered less  genetically "fit" and therefore could increase the
risk of collapse of salmon fisheries. This concern is supported by a review of 14 studies
by Araki et al. (2008), which suggests that nonlocal hatchery stocks reproduce very
poorly in the wild. The authors of this review also  found that wild stocks reproduce
better than both hatchery stocks and hatchery stocks that use wild, local fish.

Hatchery fish  can also compete directly for food and  resources with wild salmon
populations in both freshwater and marine environments (Rand et al. 2012).  Ruggerone
et al. (2012) examined the effect that Asian hatchery chum salmon have had on wild
chum salmon in Norton Sound since the early 1980's. They found that an increase in
adult hatchery chum  salmon abundance from 10 million to 80 million adult fish led to a
72% reduction in the  abundance of the wild chum  salmon population.  They also found
smaller adult  length-at-age, delayed age-at-maturation, and reduced productivity were
all associated with greater production of Asian hatchery chum since  1965 (Ruggerone et
al. 2012).  In addition to this competition for resources, hatchery-raised subyearling
salmon can also predate upon wild subyearling salmon, which tend to be smaller in size
(Naman and Sharpe 2012).

Despite extensive efforts to restore federally listed Pacific Northwest salmon
populations, they remain imperiled, and  hatchery fish stocks may be a contributing
stressor (Kostow 2009). Given the exceptional productivity of the wild Bristol Bay
salmon population, hatcheries, while they  can produce fish, would appear to pose
greater ecological risks than benefits  to this unique and valuable wild salmon
population.
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3.3.2.5 Fish Stocking

Since many of the fish used in fish stocking originate in hatcheries, fish stocking raises
many of the same concerns as hatcheries and thus would also be a problematic form of
compensatory mitigation in the context of the Bristol Bay. Although stocking has been a
common practice in other regions, even in previously fishless habitats (e.g., Red Dog
Mine, Alaska), a large body of literature describes widespread impacts of such
management decisions. Fish stocking throughout western North America and
worldwide has had documented impacts on other fish (Townsend 2003,  Knapp et al.
2001), nutrient cycling (Eby et al. 2006, Schindler et al. 2001, Johnson et al. 2010),
primary production (Cucherousset and  Olden 2011, Townsend 2003), aquatic
macroinvertebrates (Cucherousset and Olden 2011, Dunham et al. 2004, Pope et al.
2009), amphibians (Finlay and Vredenberg 2007, Pilliod and Peterson 2001), and
terrestrial species (Epanchin et al. 2010).  While fish stocking has provided limited
benefits in certain circumstances, it would appear from the growing body of literature
that the ecological costs of fish stocking far outweigh any potential benefits.

3.3.2.6 Commercial Fishery Harvest Reductions

One commenter suggested reducing commercial fishery harvests to compensate for fish
losses due to  large-scale mining. The State of Alaska currently manages  the Bristol Bay
commercial fisheries for Maximum Sustained Yield, allowing the fishery to harvest the
surplus production (i.e., fish that would not have contributed to the reproductive output
of the population due to competition) from the stocks. The populations managed with
this approach are those of the Nushagak and Kvichak Rivers, rather than their individual
tributaries. Due to the density-dependent self-regulation of populations in individual
tributaries, increasing escapement into the Nushagak and/or Kvichak Rivers would
address neither localized reductions in  carrying capacity or productivity due to habitat
loss or degradation from the  mine scenarios, nor resulting reductions in  the overall
productivity of the system as a whole.  Furthermore, although there has been some
concern that harvest of returning salmon has reduced ecosystem productivity in this
region, Hilborn (2006) found that paleoecological analysis of returns does not indicate
decreased production due to commercial fishing. In light of these considerations,
reducing the commercial fishery harvest would not appear to be an effective
mechanism to offset impacts to fish productivity associated with mining.

3.3.2.7 Other Suggested Compensation Measures

Comments also included suggestions that compensatory mitigation for impacts to fish
and other aquatic resources could take the form of making payments to organizations
that support salmon sustainability or investing in various public education, outreach, or
research activities designed to promote salmon  sustainability. Although these kinds of
initiatives can provide benefits in other contexts, compensatory mitigation for impacts
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authorized under Section 404 of the Clean Water Act can only be provided through
purchasing credits from an approved mitigation bank or in-lieu fee program or
conducting permittee-responsible compensatory mitigation projects (40 CFR 230.92).

4 Conclusion

The mine scenarios evaluated in the Bristol Bay Assessment show that the mine
footprint alone will result in the loss (i.e., filling, blocking or otherwise eliminating) of
hundreds to thousands of acres of high-functioning wetlands and tens of miles of
salmon-supporting streams.  In addition to these direct losses, these mine scenarios
would also result in extensive adverse secondary and cumulative impacts  to wetlands,
streams, and fish that would have to be addressed. Such extensive habitat losses and
degradation could also  result in the loss of unique salmon populations, potentially
eroding the genetic diversity essential to the stability of the overall Bristol Bay salmon
fishery.  There are significant challenges regarding the potential efficacy of
compensation measures proposed by commenters for use in the Bristol Bay region,
raising questions as to whether sufficient compensation measures exist that could
address impacts of this type and magnitude.
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REFERENCES

ACOE (U.S. Army Corps of Engineers). 2009. Alaska District Regulatory Guidance Letter,
RGL ID No. 09-01.

ACOE (U.S. Army Corps of Engineers). 2011. Memorandum for Regulatory Division,
Alaska District, 3 March 2011.

ADFG (Alaska Department of Fish and Game). 2012a. Alaska Freshwater Fish Inventory
Database, available at: http://www.adfg. a laska.gov/index.cf m?adfg=ff inventory, ma in
(last visited October 26, 2012).

ADFG (Alaska Department of Fish and Game). 2012b. Fish Passage Improvement
Program, Fish Passage Inventory Projects, available at
http://www.adfg.alaska.gov/index.cfm?adfg=fishpassage.projects (last visited October
19, 2012).

Alexander, R., E. Boyer,  R. Smith, G. Schwarz, and R. Moore. 2007. The role of headwater
streams in downstream water quality. Journal of the American Water Resources
Association 43:41-59.

Bates, K., B. Barnard, B. Heiner, J.P. Klavis, and P.D. Powers. 2003. Design of road
culverts for fish passage. Washington Department of Fish and Wildlife, Olympia. 112 pp.

BLM  (Bureau of Land Management). 2000. Statement of Work, Red Top Mill Site (Retort)
Closure Project, available at:
http://www.blm.gov/pgdata/etc/medialib/blm/ak/afo/afo  nepa docs/0.Par.93968.File.
dat/CX07-021sow.pdf (last visited October 18, 2012).

Bryant, M.D. 1984. The  Role of Beaver Dams as Coho Salmon Habitat in southeast Alaska
Streams. In Walton, J.M. and D.B. Houston (eds.), PROCEEDING, OLYMPIC WILD FISH
CONFERENCES (Port Angeles, Washington: Peninsula College, Fisheries Technology
program): 183-192.

Bustard, D.R. and D.W. Narver. 1975. Aspects of the Winter Ecology of Juvenile Coho
Salmon (Oncorhynchus kisutch) and Steelhead Trout (So/mo gairdneri). Journal of the
Fisheries Research Board of Canada. 32(5): 667-680.

Christie, M.R., M.L. Marine, R.A. French, M.S. Blouin. 2011. Genetic adaptation to
captivity can occur in a single generation.  Proceedings of the National Academy of
Science 109: 238-242.

Collen, P. and R.J. Gibson. 2001. The general ecology of beavers (Castor spp.), as related
to their influence on stream ecosystems and riparian habitats, and the subsequent
                                                                             17

-------
                ***lnternal deliberative materials-do not cite, quote, or distribute***


effects on fish—A review. Reviews in Fish Biology and Fisheries 10:439-461.

Cucherousset, J. and J.D. Olden. 2011. Ecological Impacts of Nonnative Freshwater
Fishes. Fisheries 36(5): 215-230.

Cunjak, R.A. 1996. Winter habitat of selected stream fishes and potential impacts from
land-use activity. Canadian Journal of Fisheries and Aquatic Sciences 53 (Supplement
l):267-282.

Darnell, R.M.  W.E. Pequegnat, F.J. Benson, and R.A. Defenbaugh. 1976. Impacts of
Construction Activities in Wetlands of the United States. U.S. Environmental Protection
Agency, Ecological Research Series EPA-600/3-76-045, 396pp, available at
http://nepis.epa.gov/

Davis, J.C. and G.A. Davis. 2011. The influence of stream-crossing structures on the
distribution of rearing juvenile Pacific salmon. Journal of the North American
Benthological Society 30(4): 1117-1128.

Dekar, M.P., R.S. King, J.A. Back, D.F. Whigham, and C.M. Walker. 2012. Allochthonous
inputs from grass-dominated wetlands support juvenile salmonids in headwater
streams: evidence from stable isotopes of carbon, hydrogen, and nitrogen. Freshwater
Science 31:121-132.

Dunham, J.B., et al. 2004. Assessing the consequences of nonnative trout in headwater
ecosystems in western North America.  Fisheries 29(6): 18-26.

Eby, L.A., W.J. Roach, L.B. Crowder, and J.A. Stanford. 2006. Effects of stocking-up
freshwater food webs. Trends in Ecology & Evolution 21(10): 576-584.

EPA (U.S. Environmental Protection Agency), Department of the Army, U.S. Fish and
Wildlife Service, and National Marine Fisheries Service  (NOAA). 1994. Alaska Wetlands
Initiative Summary Report, May 13,1994, available at
http://www.epa.gov/owow/wetlands/pdf/alask.pdf (last visited October 25, 2012).

Epanchin, P.N.,  R.A. Knapp, and S.P. Lawler. 2010. Nonnative trout impact an alpine-
nesting bird by altering aquatic-insect subsidies. Ecology 91(8): 2406-2415.

Finlay, J.C. and V.T. Vredenburg. 2007.  Introduced trout sever trophic connections in
watersheds: Consequences for a declining amphibian. Ecology 88(9): 2187-2198.

Forman, R.T. T.  2004. Road ecology's promise: What's around the bend? Environment
46:8-21.
                                                                              18

-------
                ***lnternal deliberative materials-do not cite, quote, or distribute***


Fraser, D.J. 2008. How well can captive breeding programs conserve biodiversity? A
review of salmonids. Evolutionary Applications 4: 535-586.

Card, R. 1961. Effects of beaver on trout in Sagehen Creek, California. Journal of Wildlife
Management 25 (3): 221-242. doi:10.2307/3797848. JSTOR  3797848.

Hilborn, R. 1992. Institutional learning and spawning channels for sockeye salmon
(Oncorhynchus nerka). Can.). Fish. Aquat. Sci. 49:1126-1136.

Hilborn, R. 2006. Fisheries success and failure: The case of the Bristol Bay salmon
fishery. Bulletin of Marine Science 78(3):487-498.

Hilborn R., T.P. Quinn, D.E. Schindler, and D.E. Rogers. 2003. Biocomplexity and fisheries
sustainability. Proceedings of the National Academy of Sciences 100(11): 6564-6568;
Schindler, D.E., et al. 2010, supra note 67.

Hough, P.F. and M. Robertson. 2009. Mitigation under Section 404 of the Clean Water
Act: where it comes from, what it means. Wetlands Ecology  and Management, 17:15-
33.

Johnson, C. R., C. Luecke, S.C. Whalen, and M.A. Evans. 2010. Direct and indirect effects
offish on pelagic nitrogen and phosphorus availability in oligotrophic Arctic Alaskan
lakes. Canadian Journal of Fisheries and Aquatic Sciences 67(10): 1635-1648.

Johnson, J. and P. Blanche. In press. Catalog of Waters Important for Spawning, Rearing,
or Migration of Anadromous Fishes - Southwestern Region,  Effective June 1, 2012.
Special Publication No. 12-08. Alaska Department of Fish and Game, Anchorage, AK.

Kemp, P.S., T.A. Worthington, T.E.L. Langford, A.R.J. Tree, and M.J. Gaywood. 2012.
Qualitative and quantitative effects of reintroduced beavers on stream fish. Fish and
Fisheries. 13:158-181.

King, R.S., CM. Walker, D.F. Whigham,  S. Baird, and J.A. Back. 2012. Catchment
topography and wetland geomorphology drive macroinvertebrate community structure
and juvenile salmonid  distributions in southcentral Alaska headwater streams.
Freshwater Science 31(2):341-364.

Knapp, R.A., P.S. Corn, and D.E. Schindler. 2001. The Introduction of Nonnative Fish into
Wilderness Lakes: Good Intentions, Conflicting Mandates, and Unintended
Consequences. Ecosystems 4(4): 275-278.

Kostow, K. 2009. Factors that contribute to the ecological risks of salmon and steelhead
hatchery programs and some mitigating strategies.  Reviews in Fish Biology and
Fisheries 19: 9-31.
                                                                              19

-------
                ***lnternal deliberative materials-do not cite, quote, or distribute***
Lang, D.W., G.H. Reeves, J.D. Hall, and M.S. Wipfli. 2006. The influence of fall-spawning
coho salmon (Oncorhynchus kisutch) on growth and production of juvenile coho salmon
rearing in beaver ponds on the Copper River Delta, Alaska. Canadian Journal of Fisheries
and Aquatic Sciences 63:917-930.

Leidholt-Bruner, K., D.E. Hibbs, and W.C. McComb. 1992. Beaver Dam Locations and
Their Effects on Distribution and Abundance of Coho Salmon Fry in Two Coastal Oregon
Streams. Northwest Science. Retrieved 2011-04-16.

Mulcahy, D., J. Burke, R. Pascho, and C.K. Jenes. 1982. Pathogenesis of infectious
hematopoietic necrosis virus in adult sockeye salmon (Oncorhynchus nerka). Canadian
Journal of Fisheries and Aquatic Sciences 39:1144-1149.

Murphy, M.L., J. Heifetz, J.F. Thedinga, S.W. Johnson, and K.V. Koski. 1989. Habitat
utilization by juvenile Pacific salmon (Oncorhynchus) in the glacial Taku River, southeast
Alaska. Canadian Journal of Fisheries and Aquatic Sciences 46:1677-1685.

Naman, S.W. and C.S. Sharpe. 2012. Predation by hatchery yearling salmonids on wild
subyearling salmonids in the freshwater environment: A review of studies, two case
histories, and implications for management. Environmental Biology of Fishes.  94:21-28.

Nehlsen, W., J.E. Williams, and J.E. Lichatowich. 1991. Pacific salmon at the crossroads:
Stocks at risk from California, Oregon,  Idaho, and Washington. Fisheries 16(2): 4-21.

Neville,  H., J. Dunham, A. Rosenberger, J. Umek, and B. Nelson. 2009. Influences of
wildfire, habitat size, and connectivity on trout in headwater streams revealed by
patterns of genetic diversity. Transactions of the American Fisheries Society 138: 1314-
1327.

Nickelson, T.E., J.D. Rodgers, S.L. Johnson, and M.F. Solazzi. 1992. Seasonal changes in
habitat use by juvenile coho salmon (Oncorhynchus kisutch) in Oregon coastal streams.
Canadian Journal of Fisheries and Aquatic Sciences 49:783-789.

NOAA (National Oceanic and Atmospheric Administration). 2012. Salmon Hatchery
Questions and Answers, available at
http://www.nwfsc.noaa.gov/resources/search  faq.cfm?faqmaincatid=3 (last visited
October 26, 2012).

Pilliod, D.S. and C.R. Peterson. 2001. Local and Landscape Effects of Introduced Trout on
Amphibians in Historically Fishless Watersheds. Ecosystems 4(4): 322-333.

PLP (Pebble Limited Partnership). 2011. Environmental Baseline Document 2004
through 2008, Chapter 16:16.2-8. Anchorage, AK, available at
                                                                             20

-------
                ***lnternal deliberative materials-do not cite, quote, or distribute***


http://www.pebbleresearch.com/ebd/ (last visited October 26, 2012).

Pollock, M.M., M. Heim, and D. Werner. 2003. Hydrologic and geomorphic effects of
beaver dams and their influence on fishes. In THE ECOLOGY AND MANAGEMENT OF WOOD IN
WORLD RIVERS, Gregory, S.V., K. Boyer, and A. Gurnell (eds). American Fisheries Society:
Bethesda, MD; 213-233.

Pollock, M.M., G.R. Pess, T.J. Beechie, D.R. Montgomery. 2004. The Importance of
Beaver Ponds To Coho Salmon Production in the Stillaguamish  River Basin, Washington,
USA. North American Journal of Fisheries Management. 24:749-760.

Pope, K.L., J. Piovia-Scott, S.P. Lawler. 2009. Changes in aquatic insect emergence in
response to whole-lake experimental manipulations of introduced trout. Freshwater
Biology 54(5): 982-993.

Price, D.M., T. Quinn, and R.J. Barnard.  2010. Fish passage effectiveness of recently
constructed road crossing culverts in the Puget Sound region of Washington State.
North American Journal of  Fisheries Management 30: 1110-1125.

Rand, P.S., B.A. Berejikian, T.N. Pearsons, and D.L.G. Noakes. 2012. Ecological
interactions between wild and hatchery salmonids: An introduction to the special issue.
Environmental Biology of Fishes 94: 1-6.

Reeves, G.H., J.D. Sleeper, and D.W. Lang. 2011. Seasonal changes in habitat availability
and the distribution and abundance of salmonids along a stream  gradient from
headwaters to mouth in Reynolds, J. 1997. Ecology of overwintering fishes in Alaskan
freshwaters. Freshwaters of Alaska: Ecological Syntheses. Springer, New York.

Reid, K.A. 1952. The effect  of beaver on trout waters. Maryland Conservationist
29(4):21-23.

Ruggerone, G.T., B.A. Agler, and J.L. Nielson. 2012. Evidence for competition at sea
between Norton Sound chum salmon and Asian hatchery chum salmon. Environmental
Biology of Fishes. (94:149-163.

Rupp, R.S. 1954. Beaver-trout relationships in the headwaters of  Sunkhaze Stream,
Maine. Transactions of the  American Fisheries Society 84:75-85.

Schindler, D.E., R.A. Knapp, and P.R. Leavitt. 2001. Alteration of Nutrient Cycles and
Algal Production Resulting from Fish Introductions into Mountain Lakes. Ecosystems
4(4): 308-321.
                                                                             21

-------
                ***lnternal deliberative materials-do not cite, quote, or distribute***


Schindler, D.E., R. Hilborn, B. Chasco, C.P. Boatright, T.P. Quinn, L.A. Rogers, and M.S.
Webster. 2010. Population diversity and the portfolio effect in an exploited species.
Nature 465: 609-612.

Shaftel, R., R. King, and J.  Back. 2011. Breakdown rates, nutrient concentrations, and
macroinvertebrate colonization of bluejoint grass litter in  headwater streams of the
Kenai Peninsula,  Alaska. Journal of the North American Benthological Society 30:386-
398.

Sheer, M.B. and E.A. Steel. 2006. Lost watersheds: Barriers, aquatic habitat connectivity,
and salmon persistence in the Willamette and lower Columbia River basins.
Transactions of the American Fisheries Society, 135(6): 1654-1669.

Snodgrass, J.W. and G.K. Meffe, 1998. Influence of Beaver Ponds on Stream Fish
Assemblages: Effects of Pond Age and Watershed Position. Ecology 79, 928-942.

Swales,  S., F. Caron, J.R. Irvine, and C.D. Levings. 1988. Overwintering habitats of coho
salmon  (Oncorhynchus kisutch) and other juvenile salmonids in the Keogh River system,
British Columbia. Canadian Journal of Zoology 66:254-261.

Townsend, C.R. 2003. Individual, population, community,  and ecosystem consequences
of a fish invader in New Zealand streams. Conservation Biology 17(1): 38-47.

Trombulak, S. and C. Frissell. 2000. Review of ecological effects of roads on terrestrial
and aquatic communities. Conservation Biology. 14(1):18-30.

USGS (U.S Geological Survey). 2012. Alaska Resource Data File, available at
http://mrdata.usgs.gov/ardf/ (last visited October 18, 2012).

USGS (U.S Geological Survey). 2008. Alaska Resource Data File, New and Revised
Records Version  1.5, available at http://ardf.wr.usgs.gov/ardf  data/1225.pdf (last
visited October 17, 2012).

Walker, CM., R.S. King, D.F. Whigham, and S.J. Baird. 2012. Landscape and Wetland
Influences on Headwater Stream Chemistry in the Kenai Lowlands, Alaska. Wetlands: 1-
10.

Waples, R.S. 1991. Genetic interactions between hatchery and wild salmonids: Lessons
from the Pacific Northwest. Canadian Journal of Fisheries and Aquatic Sciences 48: 124-
133.

Wipfli, M.S. and D.P. Gregovich. 2002. Export of invertebrates and detritus from fishless
headwater streams in southeastern Alaska: Implications for downstream salmonid
production. Freshwater Biology 47:957-969.
                                                                              22

-------
                ***lnternal deliberative materials-do not cite, quote, or distribute***
Wofford, J.E.B., R.E. Gresswell, and M.E. Banks. 2005. Influence of barriers to movement
on within-watershed genetic variation of coastal cutthroat trout. Ecological Applications
15: 628-637.

Yocom, T.G. and R.L. Bernard. 2013. Mitigation of Wetland Impacts from Large-Scale
Hardrock Mining in Bristol Bay Watersheds. Seattle Journal of Environmental Law, Vol.
3, available at http://www.siel.org/vol3/mitigation-of-wetland-impacts-from-large-
scale-hardrock-mining-in-bristol-bav-watersheds (last visited April 5, 2013).

Yu, J.N., N. Azuma, and S. Abe. 2012. Genetic differentiation between collections of
hatchery and wild masu salmon (Oncorhynchus masou) inferred from mitochondrial and
microsatellite DNA analyses. Environmental Biology of Fishes. 94:25-271.
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