EPA910-R-14-001C | January 2014
  EPA
  United States
  Environmental Protection
  Agency
      An Assessment of Potential Mining Impacts
     on Salmon Ecosystems of Bristol Bay, Alaska
                                     Volume 3 - Appendices E-J


Region 10, Seattle, WA
www.epa.gov/bristolbay

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                                        EPA910-R-14-001C
                                           January 2014
AN ASSESSMENT OF POTENTIAL MINING IMPACTS ON
  SALMON ECOSYSTEMS OF BRISTOL BAY, ALASKA

             VOLUME 3—APPENDICES E-J
                U.S. Environmental Protection Agency

                       Region 10

                       Seattle, WA

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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: Non-Salmon Freshwater Fishes of the Nushagak and Kvichak River Drainages

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

APPENDIX D: Traditional Ecological Knowledge and Characterization of the Indigenous
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]: Compensatory Mitigation and Large-Scale Hardrock Mining in the Bristol Bay
Watershed

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AN ASSESSMENT OF POTENTIAL MINING IMPACTS ON
  SALMON ECOSYSTEMS OF BRISTOL BAY, ALASKA

             VOLUME 3—APPENDICES E-J
 Appendix E: Bristol Bay Wild Salmon Ecosystem: Baseline
        Levels of Economic Activity and Values

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Bristol Bay Wild Salmon Ecosystem
Baseline Levels of Economic Activity and Values
John Duffield
Chris Neher
David Patterson
Bioeconomics, Inc. Missoula, 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
December 2013
For:
NatureServe
Conservation Services Division
       UAA  Institute of Social
       and Economic Research
       UNI VFRSITY rf ALASKA ANCHORAGE              BIOECONOMICS

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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	47
  2.3.1 Sport Hunting	47
  2.3.2 Non-consumptive Wildlife Viewing / Tourism Economics	48
3.0 Bristol Bay Commercial Fisheries	51
  3.1 Introduction	51
  3.2 Overview of the Bristol Bay Salmon Industry	52
  3.3 Bristol Bay Salmon Harvests	57
  3.4 Bristol Bay Salmon Products and Markets	71
  3.5 Bristol Bay Salmon Prices	80
  3.6 Bristol Bay Salmon Ex-Vessel and Wholesale Value	92
  3.7 Bristol Bay Salmon Fishermen	96
  3.8 Bristol Bay Salmon Processors	105
  3.9 Bristol Bay Salmon Industry Employment	109
  3.10 Bristol Bay Salmon Industry Taxes	117
  3.11 Regional Distribution of Bristol Bay Permit Holders, Fishery Earnings, and Processing
  Employment	119
  3.12 Distribution of Salmon Permits and Earnings within The Bristol Bay Region	129
  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	202
  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)	45
Table 23.  Bristol Bay Subsistence Salmon Harvests by District and Location Fished, 2007	46
Table 24.  Estimated Total Annual Bristol Bay Area  Subsistence-Related Expenditures (2009 $)
	47
Table 25. ADF&G Reported Big Game Hunting in Bristol Bay and Alaska Peninsula Game
Management Units	48
Table 26. Estimated annual big game hunting expenditures for Bristol Bay region	48
Table 27. Comparison of Bristol Bay Drift Gillnet and Set Gillnet Fisheries (2006-10 Average)
	64
Table 28. Sales of Selected Sockeye Salmon Products	73
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	99
Table 31. Estimates of Bristol Bay Processor Costs, Prices and Profits	107
Table 32. Indicators and Estimates of Bristol Bay Salmon Industry Fishing Processing
Employment	112
Table 33. Monthly Employment in Food Manufacturing, by Borough or Census Area	116
Table 34. Selected Data and Estimates for Bristol Bay Salmon Taxes	118
Table 35. Comparison of Vessels Used in the Bristol Bay Drift Gillnet Fishery, by Residency of
Permit Holder	123
Table 36. Participation and Gross Earnings in Bristol Bay Salmon Fisheries	128
Table 37. Population, Permit Holders, and Salmon Earnings, by Community: 2000 & 2010 ... 130
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
FigureS. 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	43
Figure 10. Major Bristol Bay River Systems	53
Figure 11. Bristol Bay Commercial Salmon Harvests	57
Figure 12. Bristol Bay Fishing Districts. Source: ADFG map posted at:	58
Figure 13. Bristol Bay Commercial Sockeye Salmon Harvests, by District	59
Figure 14. Share of Bristol Bay Commercial Sockeye Salmon Harvest, by District	60
Figure 15. Naknek-Kvichak District Sockeye Salmon Harvests, by River of Origin	61
Figure 16. Bristol Bay Salmon Harvests, by Fishery	65
Figure 17. World Sockeye Supply	66
Figure 18. Alaska Salmon Supply	67
Figure 19. World Salmon and Trout Supply	68
Figure 20. Bristol Bay Sockeye Preseason Projection and Actual Commercial Catch	69
Figure 21. Bristol Bay Salmon Harvests, 1985-2009	70
Figure 22. Bristol Bay Sockeye Salmon Production	72
Figure 23. Share of Sockeye Salmon Production in Bristol Bay	72
Figure 24. Bristol Bay Sockeye Salmon Harvests and Production	74
Figure 25. Monthly Sales Volume of Bristol Bay Salmon Products	75
Figure 26. Alaska Frozen Sockeye Production and U.S. Frozen Sockeye Exports	77
Figure 27. Estimated End-Markets for Alaska Frozen Sockeye Salmon	78
Figure 28. Alaska Canned Sockeye Production and U.S. Canned Sockeye Exports	79
Figure 29. Average Ex-Vessel Price of Bristol Bay Sockeye Salmon, 1975-2010	80
Figure 30. Average Wholesale and Ex-Vessel Prices of Bristol Bay Sockeye Salmon	81
Figure 31. Average Monthly First Wholesale  Prices	83
Figure 32. Average Wholesale and Ex-Vessel Prices, Bristol Bay and Rest of Alaska	84
Figure 33. Average Ex-Vessel Prices of Sockeye Salmon, Selected Alaska Areas	84
Figure 34. Japanese Red-Fleshed Salmon Imports, May-April	85
Figure 35. Japanese Red-Fleshed Frozen Salmon Imports & Wild Sockeye Wholesale Price.... 86
Figure 36. Japanese Wholesale Prices and Bristol Bay Prices for Sockeye Salmon	87
Figure 37. Average United States Import Prices of Selected Farmed Salmon Products	88
Figure 38. U.S. Wholesale Prices for Selected Wild and Farmed Salmon Products	88
Figure 39. Monthly Average Wholesale Case Prices for Alaska Canned Sockeye Salmon	89
Figure 41. Ex-Vessel and First Wholesale Value: 1984-2010	93
Figure 42. Distribution of Nominal Value of Bristol Bay Sockeye Salmon	94
Figure 43. Distribution of Value of Bristol Bay Sockeye Salmon	95
Figure 44. Number of Limited Entry Permits  Issued and Fished in Bristol Bay	97
Figure 45. Average Gross Earnings of Bristol Bay Drift Gillnet Permit Holders	100

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Figure 46. Average Gross Earnings of Bristol Bay Set Gillnet Permit Holders	101
Figure 47. Average Prices Paid for Bristol Bay Limited Entry Permits	102
Figure 48. Average Permit Prices and Total Earnings: Bristol Bay Drift Gillnet Fishery	103
Figure 49. Average Prices and Earnings: Bristol Bay Set Gillnet Fishery	103
Figure 50. Northern Economies' Estimates of the Breakdown of Operating Costs	104
Figure 51. Number of Companies Reporting Salmon Production in Bristol Bay, by Product... 106
Figure 52. Selected Bristol Bay Salmon Processor Costs, 2001-2009	108
Figure 53. Selected Estimates of Bristol Bay Salmon Fishing and Processing Workers	113
Figure 54. Monthly Employment in Food Manufacturing, Bristol Bay Region	115
Figure 55. Bristol Bay Region Local Communities Source:
www.visitbristolbay.org/bbvc/images/bb  map  large.jpg	120
Figure 56. Number of Bristol Bay  Permit Holders by Residency	121
Figure 57. Permit Holders Average Earnings, by Residency	122
Figure 58. Share of Total Earnings of Bristol Bay Drift Gillnet Permit Holders, by Residency 124
Figure 59. Share of Total Earnings of Bristol Bay Set Gillnet Permit Holders, by Residency .. 125
Figure 60. Share of Bristol Bay Seafood Processing Employment, by Residency	126
Figure 61. Local Bristol Bay Resident Share of Salmon Fisheries: Selected Measures	127
Figure 62. Estimated Bristol Bay Area Population, by Area	131
Figure 63. Estimated Population by Region	131
Figure 64. Number of Drift Gillnet Holders, by Region	132
Figure 65. Number of Drift Gillnet Holders per 100 Residents, by Region	132
Figure 66. Number of Set Gillnet Holders, by Region	133
Figure 67. Number of Set Gillnet Permit Holders per 100 Residents, by Region	133
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 primarily personal use
and catch and release fishing, respectively. The limited harvest from these activities is relatively
low impact when compared to the commercial fishery harvest.
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                                                  Nushagak
                                                      Kvichak
Figure 1. Map of Bristol Bay Study Area


This report focuses on an overview of values based on existing data and previous studies, and
estimation of both the regional economic significance (focusing on jobs and income) of these
ecosystems using an existing regional economic model.  Total value in a social benefit-cost
framework is also considered. This report provides a preliminary but relatively comprehensive
estimate of the range of fishery-related values in this region (Figure 1).

This summary provides a brief characterization of each of the major sectors, followed by the
primary economic findings.
Subsistence and Village Economies

The Bristol Bay economy is a mixed cash-subsistence economy. The primary features of these
socio-economic systems include use of a relatively large number of wild resources (on the order
of 70 to 80 specific resources in this area), a community-wide seasonal round of activities based
on the availability of wild resources, a domestic mode of production (households and close kin),
frequent and large scale non-commercial distribution and exchange of wild resources, traditional
systems of land use and occupancy based on customary use by kin groups and communities, and
a mixed economy relying on cash and subsistence activities (Wolfe and Ellanna, 1983; Wolfe et
al. 1984). The heart of the cash-subsistence economy in Bristol Bay is the resident population of
7,475 individuals located in 25 communities (Table 1) spread across this primarily un-roaded
area (Figure 2). Archeological evidence indicates that Bristol Bay has been continuously
inhabited by humans at least since the end of the last major glacial period about 10,000 years
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ago. Three primary indigenous cultures are represented here: Aleuts, Yupik Eskimos, and the
Dena'ina Athapaskan 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
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
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

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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 Ocean
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)

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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).2 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
2 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
-1- \J Kll

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 modeling described in section below.

Table 6 provides an accounting of jobs and wages for the cash economy component of the
Bristol Bay mixed cash-subsistence economy. Kreig et al. (2007) describe the participation in the
subsistence side of the economy through sharing, bartering, and cash exchange for subsistence
harvests. An estimate of the number of jobs or livelihoods supported by the subsistence sector
                                           21

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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 Borass
(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 (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
  (PRIVATE/PUBLIC)
                                     ECOSYSTEM GOODS
                                         & SERVICES
                                           J
L
                            Use values^
     Pa;; i'jeU;e Value;
     e y. cuSrncc, i
                                                       a 9, lA' prowwn h«t*it
                                                       •af^iod. Hood DO-^JO),
Figure 5. 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
                                           25

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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
(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 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                   Population    Percent    Percent 18    Number of   Median household
                          2010       Alaska     or over     households     income 2009
                                    Native
Bristol Bay Borough
Dillingham Census Area
Lake & Peninsula Borough
Total Bristol Bay Region
State of Alaska
997
4,847
1,631
7,745
710,231
48.2%
80.4%
74.6%
73.8%
14.8%
77.4%
67.1%
69.8%
66.7%
73.6%
423 $
1,563 $
553 $
2,539 $
234,779 $
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
(20 10 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
                        Bristol Baii
 /    CN  ,  r
I PiJoi   ,-, ^,.-J~~->   ^J
tertf  J jx.
                                                                  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).

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                                                   Nushagak
                                                       Kviehak
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 # offish
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
spending"

$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 In rest of AK
31.1%
20.5%
0.0%
5.3%
4.1%
13.9%
9.2%
6.2%
4.1%
0.1%
5.4%
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.
7 A 1998-99 survey of the village of Atyqasuk (North Slope Borough) found that 33% 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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                       Salmon
                        52%  ~\
                                                                      Land Mammals
                                                                          31%
Non-Salmon
    10%
                                       I
                                  Birds and Eggs
                                      2%
                                           Vegetation
                                              3%
\ Y_Marine Invertebrates
 \        0%
                                \
                                   Marine Mammals
                                        2%
Figure 9. Distribution of Bristol Bay Subsistence Harvest
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
              Population    Per Capita Harvest   Total Annual
             (2010 census)     (raw pounds of       Harvest
                            harvest)(AKF&G
                              Subsistence
                               Surveys)
                 219             296             64,824
                 62              1210            75,020
                2,329            242            563,618
                 109             384             41,856
                                            43

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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
Total surveyed communities
Un-surveyed communities
Total including un-surveyed areas
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
797
542
469
313
680
899
527
298
264
389
692
358
306
384
133
408
268
814
246
499


343
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
44

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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
                                        45

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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.
                                                 46

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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.
                                        47

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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 estir
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
311
117
628
195
230
117
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.
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
                                          48

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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
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


                                           49

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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 re search. "(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.
                                           50

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3.0 Bristol  Bay Commercial Fisheries
3.11ntroduction

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
available for any Alaska location.8
8 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

                                           51

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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.

                                          52

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                            r
                             Egegik
                                                                        ^
                                                            --
                      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
                                          53

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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.
                                           54

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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
                                            55

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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,
processor, and freighter anchored in the Nushagak district
                                 Photograph by Gabe Dunham
                      A Bristol Bay processing worker holding a sockeye salmon
                                  Photograph^ Gabe Dunham

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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
4R _
An
QR _
"S ^n
i^
M—
o
in 9R
C
0
r= on
E 20
15 -
in
c
n







n


DDtt
in r-~ o> T-
r-~ r-~ r-~ oo
o> o> o> o>












ro in r^ o> T-
oo oo oo oo o>
o> o> o> o> o>










ro in r^ o>
o> o> o> o>
o> o> o> o>
Source: Commercial Fisheries Entry Commission; Alaska
























D Other
Species
• Sockeye


T- ro in r^ 05 T-
0 0 0 0 0 T-
000000
CM CM CM CM CM CM
Department of Fish and Game
                  Figure 11. Bristol Bay Commercial Salmon Harvests.
                                         57

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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.
           Numbers in boxes are average annual
           harvests for each district in millions of
                fish for the years 1991-2010
       —SB'ffC'N
                       Bristol Bay Area
             * ^J Alaska
                            16D-OC-W
                                                                7.9 L-^_  S9WN-
                                                             Naknek-Kvichak
                                   Nushagak15.7  |  / Kina Sa.mon

                                             Egegiki
                                                                            57-0 C-N-
           Figure 12. Bristol Bay Fishing Districts. Source: ADFG map posted at:
    www.adfg.alaska.gov/index.cfm?'adfg=CommercialByFisherySalmon.salmonmaps_districts_bristolbay
9 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).
                                           58

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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.
                                            59

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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


0Nushagak
 I Naknek-
  Kvichak
              CO Is— 00 O} ^D T— CN| CO ^~ LO CO Is— 00 O) ^D T— CN| C^) ^" LO CO Is— 00 O) ^D T—
              OOOOOOOOCJ)CJ)CJ)CJ)CJ)CJ)CJ)CJ)CJ)CJ)OOOOOOOOOOT-T-
              O5O5CJ)CJ)CJ)CJ)CJ)CJ)CJ)CJ)CJ)CJ)CJ)CJ)OOOOOOOOOOOO
              T-T-T-T-T-T-T-T-T-T-T-T-T-T-CNCNCNCNCNCNCNCNCNCNCNCN

                                          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).
                                            60

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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.
                                           61

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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.
                                               62

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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

                                Photograph by Gabe Dunham
                                           63

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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.
                                             64

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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.
                                         65

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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.
                                          66

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                                Alaska Salmon Supply
                                                                     I Total Alaska
                                                                      coho &
                                                                      Chinook

                                                                     I Total Alaska
                                                                      chum
                                                                     I Total Alaska
                                                                      pink


                                                                     I Other Alaska
                                                                      sockeye
                                                                     I Bristol Bay
                                                                      sockeye
                             Source: ADF&G, FAO, NMFS
                          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
                                        67

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World Salmon and Trout Supply
3cnn

2cnn
(/>
c
"I~J 9 nnn
1
"t; 1 c;nn -

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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.
                                      69

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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
•fl
!   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)
                                           70

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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 freezin
        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
                                         71

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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

                                        72

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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.
                                          73

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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
                                    74

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                              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
                                                       75

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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.
                                           76

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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.
                                         77

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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.
Estimated End-Markets for Alaska Frozen Sockeye Salmon (%)
1 nn% T-
80% -
fino/.
AC\Q/n
ono/.
no/, .






















































































IN
i|









o>-<-coLOh-a>-<-coLOh-a>
OOO5O5O5O5O5OOOOO
O5O5O5O5O5O5OOOOO
T-T-T-T-T-T-C\JC\JC\JC\JC\J

• USA
H 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.)
                                          78

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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.
                                              79

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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
                                            80

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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).
    $6.00
    $5.00
    $0.00
            Average Ex-Vessel and Wholesale Prices of Bristol Bay Sockeye Salmon
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
                                                                    •Frozen
                                                                    wholesale
                                                                    price


                                                                    •Canned
                                                                    wholesale
                                                                    price


                                                                    •Ex-vessel
                                                                    price
    Figure 30. Average Wholesale and Ex-Vessel Prices of Bristol Bay Sockeye Salmon

                                            81

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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.
                                            82

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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.
                                            83

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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.
                                             84

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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 sockeve 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
                                           86

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                Japanese Wholesale Prices and Bristol Bay Prices for Sockeye Salmon
     $6.00
     $5.00
          ..........
          O5O5O5O5O5O5O5O5O5O5OOOOOO
     $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
     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).
                                            87

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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
                                               88

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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.
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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
                                                                                   An
In an increasingly competitive world seafood industry, quality is of increasing importance.
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
                                           90

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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
                                            91

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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.
                                         92

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        700
        600
                  Ex-Vessel and First Wholesale Value of Bristol Bay Sockeye Salmon
                              Harvests and Production,  1984-2010
                                                         CD   OO   O
                                                         O   O   T-
                                                         O   O   O
                                                         CM   CM   CM
-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).
                                            93

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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).
                                              94

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Distribution of Value of Bristol Bay Sockeye Salmon
80% -


60% -





n%























=? CD OO O











CM •* CD OO O CM





















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











^r CD oo o
ooooooa>a>a>a>a>ooooo-*-
O5O5O5O5O5O5O5O5OOOOOO
Source: CFEC, ADFG
              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%.

The Commercial Fisheries Entry  Commission (CFEC) maintains detailed public data about
salmon permit holders, including  their names, addresses, and vessel information. It also
publishes annual data on the total number of permits fished, total pounds landed, total gross
earnings, and average prices paid for permits sold.14
14 The data may be found at the Commercial Fisheries Entry Commission website: http://www.cfec.state.ak.us/.

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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
       2000
                                                CM   CM  CM  CM   CM  CM
                         Source: CFEC Salmon Basic Information Tables
       Figure 44. Number of Limited Entry Permits Issued and Fished in Bristol Bay

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.
                                            97

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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."
15
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).
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
o
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.state.ak. us/bit/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.
15 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.
                                             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
        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
"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).
                                           99

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                      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.
                                              100

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                    Average Gross Earnings of Bristol Bay Set Gillnet Permit Holders,
                                          by Quartile
        $120,000
                 O5O5O5O5O5O5O5O5O5O5O5O5O5
                                                                             -•-First
                                                                                quartile


                                                                             ^^ Second
                                                                                quartile


                                                                             -•-Third
                                                                                quartile


                                                                             -*- Fourth
                                                                                quartile
                           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.
                                             101

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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.
                                            102

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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
   Transports Food
      6% Fuel & Oil
           4%
                        Income to Crew&
                       Permit Holders (Incl.
                        Loan Payments)
                           74%
                                                         Maintenance Nets,
                                                          Gear& Storage
                                                             10%
                                                             Insurance. Taxes,
                                                             Fees, & Services
                                                                6%
                           All Set Net Vessels
Transports Food
    5%  Fuels, Oil
         2%
                                                        Maintenance Nets,
                                                         Gears. Storage
                                                            10%
                                                            Insurance. Taxes,
                                                            Fees, & Services
                                                                3%
                        Income to Crews,
                       Permit Holders (Incl
                        Loan Payments)
                           80%
      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.
                                             104

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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://ww.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)
                                           105

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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
                                           106

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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.
                                             107

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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 brailer bags in the hold of
the fishing boat. Here, a brailer bag is being hoisted
aboard a tender, where the fish are kept in refrigerated
water during transport to the processor.
                            Fish are
                              'om tenders into processing plants
         Photograph by Gabe Dunham
                                                  Photograph by Gabe Dunham
                                       108

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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).
                                        109

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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).
                                          110

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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.16 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.
16 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.

                                          Ill

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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/BBFHVWrkrErngSpec.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

Bristol Bay region for the years  2001-2009.17  Note that these include workers in the Chignik

salmon fishery. The total estimated workforce (row 6) was estimated by multiplying the number
17 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:
                                                       112

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                                                                                   18
of individuals who fished permits (row 5) by assumed crew factors for each fishery.   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
            O   T-    CM
            O   O    O
            O   O    O
            CM   CM    CM
O
O
CM
CD
O
O
CM
O
O
CM
00    CD    O
O    O    T-
O    O    O
CM    CM    CM
                                     •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)
 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
                                                  19
in the Bristol Bay region for the years 2001-2009.    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/.
18 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.
19 The estimates are posted at http://labor.alaska.gov/research/seafood/BristolBay/BBAvgMonthlyRegSpc.pdf.
                                               113

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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.20

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.21' 22

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).23 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.
20 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."
21 The data are posted at http://labor.alaska.gov/research/seafood/BristolBay/BBSFPOver.pdf.
22 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).
23Quarterly Census of Employment and Wages Data posted at http://labor.alaska.gov/research/qcew/qcew.htm.

                                            114

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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.24

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
24 ADLWD, "Fish Harvesting Workforce and Gross Earnings by Species, 2001-2009, Bristol Bay Region,"
http://labor.alaska.gov/research/seafood/BristolBay/BBFHVWrkrErngSpec.pdf.
                                            115

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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.
                                                      116

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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.
                                          117

-------
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:25
       Bristol Bay Borough:
       raw fish tax
       Lake and Peninsula Borough:
       Pilot Point:
4% fish taxEgegik:

2% raw fish tax
3% raw fish tax
25 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.
                                            118

-------
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.
                                         119

-------
                                                               Nondaltono
                                            oKollganek

                                 New Stuyahoko
                                            OEkwok
           oTwin Hllte
                      AlcgnigikO
      igiugigo
oLovolock
                      Iliamna
                      o       o
                           Pedro Bay

                         OKoKhanok
                   Manokotak   ODUIingham
                   f-i     *P-  .o       O Portage Creek
                   Clark a Pomty_
                               OEKuk           oNaknek
                                   South NaknckO     OKJng s>rmon
                                           OEgcgik
            Bristol Bay
                               Pilot Pointo
                                         OUgashik
                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).
                                          120

-------
        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
      121

-------
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.
                                Figure 57. Permit Holders Average Earnings, by Residency
                                            122

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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.
                                             123

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           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).
                                           124

-------
           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).
                                           125

-------
                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.
                                             126

-------
     50%
     40%
     30%
              Local Bristol Bay Resident Share of the Bristol Bay Salmon Fisheries:
                                     Selected Measures
     20%
     10%
   •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 Boy processing worker from Turkey
                                             127

-------
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.
                                             128

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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
                  DLLMGHMI CENSUS AREA
                                           LAKE AND PENNSULA
                                              BOROUGH
   Dibigham Region
     Dillingham
     Aleknagik
     dark's Point
    Portage Creek
       Ekuk
                         Upper Nushagak
                           Region
                           Koliganek
                          NewSluyahok
                            Ekwok
   Togdt-Manokotak Region
        Tcgak
       Twin Hills
       Manokotak
BRISTOL BAY BOROUGH
    KiigSatnon
     Naknek
   South Naknek
              ChkjikCiy
             Qiigiik Lagowl
             Ctigiik Lake
              IvanovBay
              Penyvlte
                                          South Bristol Bay Region
                                              Egegik
                                              Riot Point
                                              Ugashik
                                             Port Heiden
We further divide the Bristol
Bay region into seven smaller
regions, consisting of the groups
of communities:

Bristol Boy 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
                                            129

-------
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
                                               130

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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
                                             131

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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
                                             132

-------
                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
    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
                                           -*- 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
                                            133

-------
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.
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.
                                 $25,000
Total Salmon Fishery Earnings, by Region
                                 $20,000
                                 $15,000
                                 $10,000
                                  $5,000
                         -»-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, Iliamna 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
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A.r\ -
Ti
"5i ^n -
M—
M—
O
/n 9^
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o
^ 9fl -
E Z(J
-\5 -
^r\
c _
n







n


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
15
5







n

...1
ml









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










ro ID i^ en
en en en en
en en en en























D Other
Species
• Sockeye

T- ro 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.
                                          145

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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.
                                           146

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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 75. 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.
                                           148

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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
o
5
i
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
                                          151

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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.
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=commercialbyfishery salmon.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/MNUSALM.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/fishery/statistics/software/fishstati/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 52.  "Annual harvests of 31 million salmon ..."  Source: ADFG Alaska Commercial
Salmon Harvests and Exvessel Values Reports.

Page 52.  "57% of world sockeye salmon harvests. " Source: See discussion below of sources
for Figure 22 (World Sockeye Supply).

Page 52.  "Annual ex-vessel" value to fishermen of $129 million." Source: ADFG Alaska
Commercial Salmon Harvests and Exvessel Values Reports.

Page 52.  "Annual first wholesale value ... of $268 million." ADFG Commercial Operator
Annual Report (COAR) Data.

Page 52.  "26% of the ex-vessel value ..." Source:  ADFG Alaska Commercial Salmon
Harvests and Exvessel Values Reports.

Page 52.  "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 57.  "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/stl/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-IN (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.
                                        166

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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 of annual 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 EVIPLAN, 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
r^iiiiu

  • -------
     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.
    
                                              180
    

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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).
                                             181
    

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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.26
    
    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).
    26  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.
    
                                               182
    

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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
    $3,053
    $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
    
                                              184
    

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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
    
                                               185
    

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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
    2,655
    1,669
    854
    132
    914
    575
    294
    45
    1,801
    2,715
    $32,093
    $19,107
    $11,279
    $1,707
    $58,672
    $90,765
    Non-local
    1,114
    735
    328
    51
    384
    253
    113
    18
    1,129
    1,513
    $12,451
    $7,823
    $4,020
    $608
    $39,380
    $51,831
    Residents
    Local
    1,184
    741
    383
    60
    408
    255
    732
    21
    672
    1,080
    $13,440
    $7,925
    $4,777
    $738
    $19,290
    $32,730
    Total
    2,298
    1,475
    712
    111
    792
    509
    245
    38
    1,801
    2,593
    $25,892
    $15,748
    $8,797
    $1,347
    $58,672
    $84,564
    Non-
    Residents
    356
    193
    142
    21
    123
    67
    49
    7
    -
    123
    $6,202
    $3,359
    $2,482
    $361
    -
    $6,202
    Note, estimates based on ISER Input-Output Model (Goldsmith, 2000). 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.
                                               186
    

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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
                                                        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
    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.
                                               188
    

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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
                                                        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
    i UlUl
    
    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
    Unrepresentative base year for
    harvest and ex-vessel value
    estimates
    Assumptions about the level
    of expenditures per harvester
    and processor
    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
    Unknown
     Moderate
    Assumptions about the
    composition of harvester and
    processor purchases	
    Unknown
     Moderate
    Assumption about the regional
    allocation of expenditures by
    Unknown
     Moderate
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    Description
    harvesters and processors
    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
    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
    significance.
    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.27 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.28 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 $55,700.29
    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
    27 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
    28 A long time series of monthly and annual permit transfer prices is continuously updated at,
    http ://www. cfec. state, ak.us/pmtvalue/mnusalm. htm
    29 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.30 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
    30 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))
    $20.90 million
    (C)Estimated Sum of Harvest and Processing Sectors Average Annual Net Income
    Total estimated annual harvester and processor net income (201 1$) 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
    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
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    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).
    
    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
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    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,31
    subsistence harvest,32 education,33 and cost of living data34 for the 90 communities included in
    both the Hausman and the Duffield models.
    
    The updated estimated wage compensating differential model shown in Table 66 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]
    31 American Community Survey 5-year averages 2006-2010 (Table B19301) www.census.gov/acs/
    32 Alaska Fish and Game Department of Subsistence ,  http://www.adfg.alaska.gov/sf/publications/
    33 American Community Survey 5-year averages 2006-2010 (Table GCT1502) www.census.gov/acs/
    34 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.35
    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.36 In 2009 dollars, this product
    value is estimated at $18.86 per pound.37
    
    Table  67 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).
    35 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).
    36 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.
    37 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
    Igiugig2005
    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
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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
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    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
    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
                                 Use vafues |
    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
    (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 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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    Walsh, R, R. Bjonback, D. Rosenthal, and R. Aiken. 1985. "Public Benefits of Programs to
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    Ward, K. and J. Duffield. 1992. Natural Resource Damages: Law and Economics John Wiley
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    Weisbrod, B. 1964. "Collective Consumption Services of Individual Consumption Goods."
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    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
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    Wolfe et al. 1984. "Subsistence-based Economies in Coastal Communities of Southwest
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    Wright, J., J. Morris, and R. Schroeder. 1985.  "Bristol Bay Regional Subsistence Profile."
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           Dillingham, Alaska.
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    AN ASSESSMENT OF POTENTIAL MINING IMPACTS ON
      SALMON ECOSYSTEMS OF BRISTOL BAY, ALASKA
    
                 VOLUME 3—APPENDICES E-J
     Appendix F: Biological Characterization: Bristol Bay Marine
         Estuarine Processes, Fish and Marine Mammal
                      Assemblages
    

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    Biological Characterization: An Overview of
    Bristol, Nushagak, and Kvichak Bays;
    Essential Fish Habitat, Processes, and
    Species Assemblages
    December 2013
    Prepared by
    National Marine Fisheries Service, Alaska Region
             National Marine Fisheries Service, Alaska Region
    

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                                          PREFACE
    The Bristol Bay watershed supports abundant populations of all five species of Pacific salmon
    found in North America (sockeye, Chinook, chum, coho, and pink), including nearly half of the
    world's commercial sockeye salmon harvest. This abundance results from and, in turn,
    contributes to the healthy condition of the watershed's habitat. In addition to these fisheries
    resources, the Bristol Bay region has been found to contain extensive deposits of low-grade
    porphyry copper, gold, and molybdenum in the Nushagak and Kvichak River watersheds.
    Exploration of these deposits suggests that the region has the potential  to become one of the
    largest mining developments in the world.
    
    The potential environmental impacts from large-scale mining activities in these salmon habitats
    raise concerns about the sustainability of these fisheries for Alaska Natives who maintain a
    salmon-based culture and a subsistence lifestyle. Nine federally recognized tribes in Bristol Bay
    along with other tribal organizations, groups, and individuals have petitioned the U.S.
    Environmental Protection Agency (EPA) to use its authority under the  Clean Water Act to
    restrict or prohibit the disposal of dredged or fill material from mining  activities in the Bristol
    Bay watershed. In response to these petitions and to better understand the potential  impacts of
    large-scale mining, the EPA is conducting an assessment of the biological and mineral resources
    of the Bristol Bay watershed to inform future government decisions related to protecting and
    maintaining the physical, chemical, and biological integrity of the watershed. As part of this
    process, the EPA requested assistance from National Marine Fisheries  Service (NMFS) as the
    agency responsible for the nation's living marine resources.
    
    The EPA assessment focuses on salmon populations, their habitat, and  the supporting ecosystem
    processes in the Nushagak and Kvichak watersheds. Under Section 305(b)(2) of the Magnuson-
    Stevens Fishery Conservation and Management Act (Magnuson Stevens Act), NMFS has
    designated the region's  fresh and marine waters as Essential Fish Habitat (EFH) for anadromous
    salmon, groundfish, and other invertebrate species. EFH for salmon consists of the aquatic
    habitat necessary to support a long-term sustainable salmon fishery and salmon contributions to
    healthy ecosystems. Natural wild salmon populations are currently stable and abundant, and their
    habitat at the ecosystem scale, from headwater streams through marine processes, is functionally
    intact.
    
    This report summarizes our current understanding of the region's oceanic and freshwater
    influence on the nearshore areas of Nushagak and Kvichak Bays; of the invertebrate, fish, and
    marine mammal assemblages found east of 162° West longitude; and of the range and
    distribution of Bristol Bay salmon. This report also highlights our understanding of the trophic
    contribution of Bristol Bay salmon both as smolt leaving the watersheds and as returning adults
    and our understanding of the importance of estuaries and nearshore habitat as nutrient rich
    nursery areas for numerous marine species.
                                               in
    

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                                 ACKNOWLEDGEMENTS
    
    This report was compiled and written by Douglas Limpinsel, NOAA Fisheries, Habitat
    Conservation Division, Alaska Region. Robert McConnaughey, NOAA Fisheries, Alaska
    Fisheries Science Center, and Jeanne Hanson and Jim Hale, NOAA Fisheries, Alaska Regional
    Office, provided technical and editorial reviews that improved the organization and readability of
    this report. The following people also contributed in various ways to this discussion:
    
    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, Jamal Moss, Philip Mundy, James Murphy, Daniel Nichol, Olav
    Ormseth, Elizabeth Sinclair, Thomas Wilderbuer
    
    NOAA/NMFS - Alaska Region, Habitat Conservation Division: Matthew Eagleton, 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.
                                             IV
    

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                                          ABSTRACT
    This report summarizes our current understanding of Bristol Bay as Essential Fish Habitat (EFH)
    for salmon at various life stages as well as for other species of marine invertebrates, fish, and
    marine mammals. As an ecosystem, the currently healthy habitat of the bay both supports and
    results from the interactions between natural processes and the presence and abundance of all
    five species of Pacific salmon. As a keystone species, Bristol Bay salmon facilitate energy and
    nutrient transport to and from the inner bay's terrestrial watersheds and the marine ecosystems of
    the eastern Bering Sea. Outbound migrations of billions of salmon smolts provide nutrition to
    numerous trophic levels and marine species, and salmon returning in their adult phase provide a
    valuable nutrient source to marine mammals and subsidize watersheds in the form of salmon-
    derived nutrients.
    

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    Table of Contents
    Bristol Bay - Overview	1
      Marine Influence	2
      Fresh Water Influence	2
    Bristol Bay - Fish and Invertebrate Assemblages	3
      Nushagak and Togiak Bays	3
      Nearshore	4
      Offshore	4
    Bristol Bay - Salmon	6
      Range and Distribution	6
      Salmon Contribution to Trophic Levels	8
    Bristol Bay -Marine Mammals	9
      Pinnipeds	9
      Whales: Toothed Whales	11
      Whales: Baleen Whales	12
    Discussion	13
      Habitat Condition	13
      Water	13
      Estuaries	14
      Salmon Food Habits	14
      Salmon Critical Size	15
      Trophic Contribution	15
      Summary	17
    Bibliography	19
    Tables	43
      Table 1:  Fish and Invertebrate Species List	43
      Table 2: Marine Mammals Species List	53
    
                                                 vi
    

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                                       BRISTOL BAY
    Overview
    
    Bristol Bay is a large, shallow sub-arctic bay (Buck et al. 1974, Straty 1977, Straty and Jaenicke
    1980, NOAA 1997 and 1998, Wilkinson 2009). Its benthic topography is essentially flat, with an
                                                                                           o
    average gradient of 0.02 percent and a maximum depth of approximately 70 meters at the 162
    West longitude line (Moore 1964, Buck et al.  1974). The substrate throughout the bay consists of
    silts and mud and vast aggregates of sand, gravel, cobble, and boulder (Sharma et al. 1972,
    NOAA 1987; see Smith and McConnaughey 1999 for a detailed description of benthic
    substrate).
    Figl. Bristol Bay. Waters east of the 162° West longitude line are defined by the North Pacific Fishery Management Council as the Bristol Bay
    No-Trawl-Zone Protected Area.
    
    The chemical properties of Bristol Bay waters are highly variable and constantly shift under the
    influence of dramatic currents, tide cycles, and severe weather events from the Bering Sea in the
    

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    west and the influence of terrestrial freshwater discharges from Nushagak River, Kvichak River,
    and a number of other, smaller rivers in the east.
    
    Earlier literature distinguishes the inner bay from the outer bay by physical properties such as
    salinity, temperature, and turbidity (Buck et al.  1974, Straty 1977, Straty and Jaenicke 1980).
    More recent investigations, however, distinguish different parts of the bay by depth, with an
    inner or coastal domain from the shoreline to 50 meters deep, a middle domain from 50 to 100
    meters deep, and outer domain beyond the 100-meter contour (Kinder and Coachman 1978,
    Kinder and Schumacher 1981, Coachman 1986, Schumacher and Stabeno 1998, Stabeno et al.
    2001).
    
    Inner bay processes are continuously fed large volumes of fresh water from numerous
    watersheds, with salinity increasing toward the 162 West longitude line, while currents from the
    eastern Bering Sea move through the bay in a counter-clockwise gyre under the influence of
    tides ranging from 3 to 23 feet (Buck et al. 1974, Straty 1977, Straty and Jaenicke 1980).
    
           Marine Influence
    
    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). East of Unimak Pass, the marine current flows northeast as the
    Bering Coastal Current along the Alaska Peninsula and into Bristol Bay where it turns in a
    counter-clockwise gyre (Kachel 2011, pers. comm.). The majority of this current diverts north
    near the 50-meter contour and eventually flows west and then north around Cape Newenham
    toward Nunivak and Pribilof Islands (Coachman 1986). Part of the current, however, continues
    east and delivers marine nitrates, carbon, phosphates, and silica into the inner bay. These mix
    with fresh water discharges and dissolved organic material from several river systems at the
    eastern end of the 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).
    
           Fresh Water Influence
    
    Estuarine characteristics of Nushagak and Kvichak Bays are the result of continual freshwater
    runoff from several watersheds (Straty 1977, Buck 1974, 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 discharge of these rivers
    contributes to the  estuarine character of these bays (Buck et al.  1974). Of the rivers that drain
    into the inner domain, we measure the discharge of only two, the Nushagak and Kvichak Rivers,
    which together drain 22,172 square miles (14,190,134 acres) of watershed (USGS 2011). The
    Nushagak River has a mean annual discharge of 28,468 cubic feet per second (CFS) based on
    readings from the Nushagak River gauge (USGS No. 15302500, 23,645 cfs) and the Wood River
                                               2
    

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    gauge (USGS No. 15303000, 4,823 cfs). The Kvichak River has a mean annual discharge of
    17,855 cfs based on readings from the USGS gauge (15300500) located at the outlet of Lake
    Iliamna. If these three gauges represent an accurate estimate, the total discharge is 46,323 cfs, or
    approximately 33,536,000 acre feet squared per year. This fresh water influence dominates
    Nushagak and Kvichak Bays between April and November creating the characteristic estuarine
    water chemistry. Other sources of fresh water also discharge into Bristol Bay and influence the
    water quality, but their flows are not monitored and cannot be currently included in estimates.
    
    Out-welling freshwater contributions are significantly higher in spring and summer when winter
    snow and ice melt and rains are prevalent As a result, summer ebb tide currents often
    considerably exceed the flood tides. Discharge from the watersheds keeps the waters of
    Nushagak and Kvichak Bays colder in early spring; however, by mid-summer these temperatures
    reverse with warmer terrestrial discharges (Buck et al. 1974). Furthermore, the counter-
    clockwise current pushes freshwater discharge from Kvichak Bay into Nushagak Bay which
    maintains a slightly lower salinity. Generally, lower sea surface salinity measurements are
    observed in Nushagak Bay than in Kvichak Bay (Radenbaugh 2011, pers. comm.).
    
    Because of this seasonal terrestrial freshwater influence, Nushagak and  Kvichak Bays exhibit the
    lowest salinity and greatest temperature fluctuation in Bristol Bay (Buck et al. 1974, Straty and
    Jaenicke 1980).  Similar temperature and salinity gradients have been observed in the inner
    domain (temperature 11.4 °C, salinity 28.9%) and the middle domain (temperature 7.4 °C,
    salinity 32.7%) (NOAA 1987). Marine characteristics then dominate offshore. More recent
    analyses and descriptions of oceanographic currents and nutrients generally describe shallow,
    wind-driven, well-mixed, homogenous, nutrient-laden waters (Coyle and Pinchuk 2002, Kachel
    et al. 2002, Stabeno and Hunt 2002).
    
    Bristol Bay - Fish and Invertebrate Assemblages
    
          Nushagak and Togiak Bays
    
    Recent mid-water surveys in Nushagak Bay have found the dominant species in numbers and
    biomass to include bay shrimp (Crangon alaskemis) and Gammarid amphipods and mysiids
    (Gammarus sp.) and confirm the presence of walleye pollock (Theragra chalcogramma, a
    marine pelagic species) and flatfish species (Pleuronectiformes) such as yellowfin sole (Limanda
    aspera) in this nearshore habitat (depths less than 30m), along with numerous other fish and
    invertebrate species (Radenbaugh 2010, pers. comm.). Additional surveys specific to Nushagak
    Bay shore line at low tide captured over 6,000 fish of 17 species. Two species accounted for 95%
    of the total catch: rainbow smelt and pond smelt (Hypomesus olidus) (Johnson 2012).
    
    Recent surveys conducted in both Nushagak and Togiak Bays encountered over 40 fish and
    invertebrate species (Olmseth 2009). Most captured individuals were less than 20 cm in length.
    Of these species, shrimp (Crcmgonidae) and rainbow smelt (Osmerus mordax) were the most
                                              3
    

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    abundant species encountered, occurring in almost every trawl and beach seine, and were
    especially dominant in very shallow water with mud and silt bottoms. Forage fish species
    identified by these surveys were salmon smolt (Salmonidae), capelin (Osmeridae) and Pacific
    herring (Clupeidae), as well as poachers (Agonidae), sculpin (Cottoidea), flatfish
    (Pleuronectidae and Bothidae), and greenling (Hexagraaidae).
    
           Nearshore
    
    In addition to the surveys of Nushagak and Togiak Bays, surveys of other nearshore waters of
    Bristol Bay document forage fish species such as Pacific herring, eulachon (Thaleichthys
    pacificus),  capelin, and rainbow smelt (Warner and Shafford 1981, Mecklenburg et al. 2002,
    Bernard 2010). In an evaluation of historical data, Gaichas and Aydin (2010) found that salmon
    smolts rank as one of the top ten nearshore forage fish. Pacific herring are also known to spawn
    in nearshore waters of Togiak Bay and along the northern shoreline of the Alaska Peninsula
    (Bernard 2010). Sand lance (Ammodytes hexapterus) have been found in particular abundance in
    these nearshore waters of the Alaska Peninsula (McGurk and Warburton 1992).
    
    Surveys conducted to characterize the presence and distribution of forage fish species 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 nerka)
    (Isakson et al.  1986, Houghton 1987). During one phase of these surveys, juvenile sockeye
    salmon were more abundant than any forage fish or juvenile ground fish species encountered.
    Present again,  though in  fewer numbers, were Pacific herring, capelin, pond and surf smelt, and
    eulachon. The presence,  abundance, and biodiversity of these species in Bristol Bay nearshore
    habitat support 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 areas in a variety of different habitat
    and substrate types and water conditions.
    
           Offshore
    
    Fisheries surveys of the offshore waters of Bristol Bay have been conducted since the 1930s. The
    AFSC has conducted annual surveys in the eastern Bering Sea offshore and outer Bristol Bay
    waters since 1982 using  standardized gear and repeatable methods. These surveys identify
    numerous groundfish species inhabiting the eastern Bering Sea and Bristol Bay, generally  deeper
    

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    than the 15-20m contour (Lauth 2010)1. The more common species represented in the surveys
    are cod and pollock (Gadidae); fifteen species of flatfish (Pleuronectiformes); forage fish species
    such as herring, eulachon, capelin, smelts, sand lance, and sandfish; and dozens of other species
    well represented, such as skate (Rajidae), poachers (Psychrolutidae), greenling (Hexagrammos),
    rockfish (Scorpaenidae), sculpin (Cottidae), crab (Cancer), and salmon.  In Table 1 we identify
    all species known to inhabit these waters.
    
    The hundreds offish species and invertebrate species that inhabit Bristol Bay waters contribute
    to trophic levels at various life stages; tides and currents transport and distribute larval marine
    fish and invertebrate species from offshore to nearshore nursery areas (Norcross et al. 1984,
    Lanksbury et al. 2007). The relationship between marine and nearshore processes and species
    presence in Bristol Bay has been well documented in the life histories of species such as walleye
    pollock, red king crab  (Paralithodes camtschaticus), and yellowfm and rock sole. Larval forms
    of each species  are transported and concentrated in nutrient-rich nearshore habitat. These four
    species illustrate relevant examples of recognized marine species with population segments that
    in a larval or juvenile phase rely on nearshore marine habitat (depths less than 30 m) for refuge
    and nutrition.
    
    Walleye pollock are generally recognized as a pelagic species spawning in open marine waters
    (Bailey et al. 1999). As Coyle (2002) notes, pollock in their larval and juvenile forms are known
    to be transported into nearshore nursery zones: the current carries the eggs and larvae along the
    north shore of the Alaska Peninsula and into the nearshore nursery zones of Bristol Bay (Napp et
    al. 2000). A recent investigation of trophic interactions shows that juvenile pollock feed on
    euphasiid and mysiid populations nearshore, especially mysiids, which have been shown to be
    more abundant in  the diets of pollock found in the northern nearshore zones than those found in
    deep water (Aydin 2010).
    
    Bristol Bay is also home to the second-largest population of red king crab (Dew and
    McConnaughey 2005, Chilton et al. 2010). Although red king crab of both genders and several
    stages of maturity occur throughout central Bristol Bay, immature larvae and juveniles are often
    concentrated along nearshore areas. The Aleutian North Shore and Bering Coastal currents
    transport larval  king crab from the eastern Bering Sea to inner Bristol Bay (Dew and
    McConnaughey 2005). Larval red king crab (smaller than 2 mm) settle in cobble and gravel
    substrates of Kvichak Bay2 (Armstrong et al.  1981, McMurray 1984, Loher et al.  1998);
    juveniles are present along the nearshore zone in the Togiak district (Armstrong et al. 1993,
     All species were found east of the 162 West longitude line and in waters deeper than 15m. Because the surveys represent a snap shot of species
    present at a particular time, they may not represent complete species diversity. Also, because standardized trawl gear mesh is size selective,
    juvenile and larval specimens of a species may not be well represented. It is important to note that salmon species at any life stage may not be well
    represented due to seasonality of surveys and species migration.
    
    2 Larval red king crab were present on substrates less than 70 to 80 feet (approximately 21 to 24 meters) at mean low water in Kvichak Bay.
    
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    Olmseth 2009). These juvenile phases inhabit nearshore rocks, shell hash, or a variety of
    biological cover in shallow depths (from 5 to 70 meters).
    
    Yellowfin and rock sole are among several species of flatfish that inhabit the eastern Bering Sea
    and for which nearshore substrates (depths less than 30 meters) in Bristol Bay are optimal habitat
    (McConnaughey and Smith 2000, Lauth 2010;  Table 1). Life histories of these species and other
    flatfish take advantage of the same currents that transport larvae into nearshore nursery areas
    (Nichol 1998, Wilderbuer et al. 2002, Norcross and Holladay 2005, Lanksbury et al. 2007,
    Cooper et al. 2011).  Larval and juvenile yellowfin sole are abundant in shallow nearshore areas
    along the northern shore and Togiak Bay (Olmseth 2010, Nichol 1998, Wilderbuer et al. 2002).
    
    These findings for Pollock, red king crab, and yellowfin and rocksole substantiate our
    understanding of nearshore and estuary zones as nutrient rich fish nurseries, providing juvenile
    fish species with greater forage opportunity in the form of abundant invertebrate populations.
    
    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 estuarine and marine
    ecosystems. Each species migrates through these waters at slightly different times depending on
    life history and watershed of origin. Because of their abundance, distribution, and overall
    economic importance, Bristol Bay sockeye salmon 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
    
    The Magnuson-Stevens Act defines EFH as "waters and substrate necessary to fish for spawning,
    breeding, feeding, or growth to maturity." For salmon, EFH consists of those fresh and marine
    waters needed to support healthy stocks in order to provide long-term sustainable salmon
    fisheries. Because of the broad range and distribution of salmon in Alaskan waters, all marine
    waters over the continental shelf in the Bering Sea extending north to the Chukchi Sea and over
    the continental shelf throughout the Gulf of Alaska and in the inside waters of the Alexander
    Archipelago are defined as EFH for all juvenile salmon (Echave et al. 2011). EFH for immature
    and mature Pacific salmon (Oncorhynchus spp) includes nearshore and oceanic waters, often
    extending well beyond the shelf break (Echave et al. 2011).
    
    In their emigration phase, anadromous juvenile salmon occupy shallows of estuaries and
    nearshore zones, although timing, duration, and abundance  vary throughout the year depending
    on species, stock, and life history stage (Groot and Margolis 1991, Quinn 2005). Nearshore and
    

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    estuarine habitats act as transition zones supporting osmoregulatory changes (the physiological
    changes by which smolt adapt between fresh and salt water) (Hoar 1976 and 1988, Clarke and
    Hirano 1995, Dickhoff et al. 1997). Studies have shown that sub-yearling salmon in the Pacific
    Northwest move repeatedly between zones of low and high salinity, and although no studies
    have yet shown Bristol Bay salmon to behave similarly, the Pacific Northwest studies suggest
    that such behavior may be integral to the survival and growth of young salmon (Healey 1982,
    Levings 1994, Levings and Jamieson 2001, Simenstad et al. 1982, Simenstad 1983, Thorn 1987).
    
    The eastern Bering Sea shelf is an important nursery ground for juvenile and sub-adult Bristol
    Bay sockeye salmon (Farley et al. 2009). Early models of eastern Bering Sea 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 that
    population  migrations crossed the Aleutian Island chain into the North Pacific (Myers 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 autumn 2008 and
    winter 2009 substantiate the migration of juvenile Bristol Bay sockeye salmon from the Eastern
    Bering Sea shelf to the North Pacific, south of the Aleutian Island chain (Habicht 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 etal. 2011)
    
    More than 55% of ocean age-1 sockeye salmon  sampled during the 2009 winter survey in the
    North Pacific were 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). This extensive range and distribution suggest that Bristol Bay sockeye salmon contribute
    to the trophic dynamics in the Bering Sea as well as the North Pacific.
    

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    Salmon Contribution to Trophic Levels
    
    A recent evaluation was conducted by the AFSC Ecosystem Modeling Team to assess the
    contribution of Nushagak and Kvichak River sockeye salmon to trophic dynamics of the eastern
    Bering Sea shelf and North Pacific ecosystems (Gaichas and Aydin 2010). Using estimates of
    outbound salmon smolt survival and adult returns, researchers calculate that these two rivers
    account for nearly 70% (56,000 of 81,100 tons) of adult salmon biomass in the eastern Bering
    Sea. In the 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 Rivers compose 26% of total sockeye salmon biomass and 12% of total salmonid
    biomass in the entire eastern subarctic gyre. The Nushagak and Kvichak Rivers produce a
    significant portion of all salmon in offshore marine ecosystems and the majority of salmon on
    the eastern Bering Sea shelf, thus producing the majority of juveniles and returning adults in the
    salmon biomass (Gaichas and Aydin 2010). The AFSC's evaluation indicates sockeye salmon
    from these river systems rank among the top ten forage groups, comparable to Pacific herring or
    eulachon as a nutritional source for other marine species in the Bering Sea and North Pacific.
    One study supports this rational indicating that outbound salmon smolt export substantial levels
    of nitrogen and phosphorus seaward (Moore and Schindler 2004).
    
    Returning adult salmon enrich watersheds in the form of salmon-derived nutrients (Gende et al.
    2002, Schindler et al. 2003, Wilson et al. 2004), and these nutrients are flushed back into
    estuaries by out-welling3 river waters. Salmon-derived nutrients are transported in the form of
    partial and whole salmon  carcasses or particulates and dissolved nutrients (carbon, nitrogen and
    phosphorous) moving from watersheds back to the estuaries. Early 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 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 suggest that 60% of the total nutrient or
    biomass transported into the watershed by salmon may be transported back to the estuary
    (Johnston et al. 2004, Mitchell  and Lamberti 2005).
    3 Terrestrial freshwater runoff from large river systems and watersheds drains into marine estuaries. In referenced
    literature, this runoff is often referred to as "outflow" or "outwelling." Outwelling freshwater chemistry,
    temperature, and nutrient plumes influence marine estuary chemistry, productivity, and salinity gradients.
    

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    In Nushagak and Kvichak Bays, nutrients liberated from tens of millions of decomposing adult
    salmon likely have a significant influence on estuarine trophic interactions and biodiversity in
    the manner discussed above. Estuarine processes such as primary and secondary production and
    countless marine fish and invertebrate species benefit from this  mass transport of nutrients.
    Numerous studies indicate that marine estuarine vegetation and  larval and juvenile invertebrate
    and fish populations benefit from enrichment of nutrients flushed back into the marine estuaries.
    The influence of outwelling freshwater and nutrients from watersheds and terrestrial river
    systems on marine estuaries and processes can be substantial.
    
    Bristol Bay - Marine Mammals
    
    The eastern Bering Sea 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 represented (Otariidae, Phocidae, and
    Odobenidae) in these waters (Allen and Angliss 2011). Of marine mammals present in the
    eastern Bering Sea, twenty species occur in Bristol Bay waters in significant numbers and
    regularity (Table 2). Three species of baleen whale (fin, right and humpback whales) and one
    pinniped species (Western Distinct Population Segment Steller sea lion) found in Bristol Bay are
    listed as endangered under the Endangered Species Act. The seven species we discuss below are
    those Bristol Bay marine mammals known to feed on salmon.
    
    In Bristol Bay, the presence of marine mammals and their prey species is highly variable
    depending on the season and location within the bay. For example, the presence  and feeding
    habitats of sea lions or fur seals are difficult to identify because  of variations in their seasonal
    range, in whether they are at sea or in rookeries, and in the migratory patterns of their prey. Less
    is known about pinniped prey selection in the open ocean because scat and stomach content
    studies are only conducted while specimens are on the rookery.  Thus, the only prey species
    represented in dietary analysis are prey species near the rookeries.
    
    Some marine mammal diet data show seasonal dependence on salmon. Several studies
    demonstrate that salmon are a prominent 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  and estuary zones.
    
    Pinnipeds
    
    Steller Sea lion?,
    
    Steller Sea lion predation on salmon has been confirmed by data from scat and stomach content
    studies from which researchers have estimated the level of consumption and frequency of
    occurrence (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
    

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    patterns, salmon ranked high as a selected prey species in Steller sea lion diets (Sinclair and
    Zeppelin 2002). The endangered western stock of Steller sea lions relies on salmon during
    summer; salmon rank second in frequency of occurrence in summer diets in regions sampled
    between 1990 and 1998 (Sinclair and Zeppelin 2002). These regions include the Bering Sea shelf
    and waters surrounding the Aleutian Islands, where salmon were noted to increase in diets during
    winter due to out-migrating sub-adult Bristol Bay salmon (Sinclair and Zeppelin 2002).
    
    Fur seals
    
    Fur seals also feed on salmon throughout the Pacific range, from California to Alaska (Perez and
    Bigg 1986). One more recent investigation conducted to determine prey species of northern fur
    seals in  the Pribilof Islands indicates salmon composed part of the diet of fur seals on St. George
    and St. Paul Islands (Sinclair et al. 2008). Pacific salmon had a mean annual frequency of
    occurrence of 14.4%, and 10% in any one year on St. George and St. Paul Islands respectively.
    Similar  nutrition studies of eastern Bering Sea northern fur seals indicate salmon rank second
    among fish in frequency of occurrence for animals on both Pribilof Islands from late July
    through September, 1990-2000 (Gudmundson et al. 2006).
    
    Harbor  seals
    
    Harbor seals also are found throughout Bristol Bay and the eastern Bering Sea and prey upon
    species of Pacific salmon (Jemison et al. 2000, Small et al. 2003, Allen and Angliss 2011,
    Jemison 2011, pers. comm.). The Bristol Bay population of harbor seals numbers  approximately
    18,000 seals and is increasing (Allen and Angliss 2013). Lake Iliamna supports a year-round
    population of harbor seals, which are currently included as part of the Bristol Bay stock.  The
    number of seals residing in Lake Iliamna is relatively small; aerial surveys of hauled-out harbor
    seals count as many as 321 (which counts do not reflect absolute abundance) (Mathisen and
    Kline 1992, Small 2001, Burns et al. 2012; Migura 2013, pers. Comm.). Although this
    population has colonized Lake Iliamna from Bristol Bay via the Kvichak River, no scientific
    evidence shows that harbor seals migrate to and from Bristol Bay. However, some residents and
    Alaska Native subsistence hunters in the Iliamna Lake area say that harbor seals are seen within
    the entire expanse of the Kvichak River and migrate between the lake and Bristol Bay (Migura
    2013, pers. Comm.). Harbor seals have also been identified in the Nushagak and Wood River
    systems. In the Wood River system, harbor seals are observed in Lake Aleknagik (B. Andrew
    2011, pers. comm., D. Chythlook2011, pers. comm., Tinker 2011, pers. comm.).
    
    Spotted seals
    
    Spotted seals have also been sighted in Bristol Bay. Other spotted seals tagged in Alaskan and
    Russian sectors of the Bering Sea show clear seasonal preference for nearshore habitat and
    associated fisheries, which suggests that spotted seals sighted in Bristol Bay may have a
    
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    persistent presence there. These populations feed mostly on salmon, saffron cod (Eleginus
    gracilus\ and herring (Burkanov 1989, Lowery et al. 2000).
    
    Whales: Toothed Whales
    
    Beluga whales
    
    Beluga whales are abundant in Bristol Bay waters primarily from spring through fall near the
    mouths of the Kvichak, Nushagak, Wood, and Igushik rivers. Early studies document the
    importance and contribution of sockeye salmon for beluga nutrition (Brooks 1955). Lensink
    (1961) notes 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 their 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 beluga whales 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 regional 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.). Traditional knowledge also indicates that beluga whales have also been seen in
    Lake Uliamna (M. Migura 2013, 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
    
    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 2011, 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, flukes 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 (Oncorhynchus kisutch) salmon (D. Cythlook
    2011, pers. comm.). In late fall, in the  absence of beluga whales, killer whales pursue late-run
    and fall coho up the Nushagak River (P. Andrew 2011, pers. comm.).
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    Although they are opportunistic feeders, fish-eating killer whales outside of Bristol Bay show an
    affinity for salmon. In Prince William Sound, the results of a 14-year study of the diet and
    feeding habits of killer whales identify two non-associating groups of killer whale, termed
    resident and transient (Bigg et al. 1987). The resident groups (fish-eaters) appear 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 one species of squid that
    dominated the diet offish-eating resident-type 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 (Oncorhynchus tshawytscha) representing 65% of the
    total sample. The second most common was pink at 17% (Oncorhynchus gorbuscha), followed
    by chum (6%) (Oncorhynchus keta), coho (6%), sockeye (4%), and steelhead (2%)
    (Oncorhynchus mykiss) (Ford et al. 1998). Although a separate population, Bristol Bay killer
    whales may have similar feeding behaviors.
    
    Sperm whales
    
    Sperm whales are  also  known to prey upon salmon and  have been sighted, however infrequently,
    in Bristol Bay. Sperm whales feed primarily on mesopelagic squid in the North Pacific, but have
    also been documented  consuming salmon as well as several  other species offish (Tomilin 1967,
    Kawakami 1980).
    
    Whales: Baleen Whales: Humpback Whales
    
    Investigations of baleen whale food habits in the North Pacific and Bering Sea have documented
    species such as humpbacks targeting small schooling fish populations. Salmon were among
    numerous species  offish identified (Nemoto 1959, Tomilin  1967, Kawamura, 1980). More
    recently, humpback whales have been observed off Cape Constantine in Bristol Bay in the spring
    of year, presumably feeding  on schooling herring and possibly outmigrating salmon smolts (D.
    Cythlook 2011, pers. comm.). In southeast Alaska, humpback whales have been observed
    preying upon  both wild and hatchery outbound 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. The humpback whales
    observed off Cape Constantine may reasonably be assumed to  exhibit a similar site fidelity for
    purposes of feeding.
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    Discussion
    
    The primary purpose of this report is to identify the range, distribution, and trophic contribution
    of salmon originating from the Nushagak and Kvichak watersheds and bays. In a broader
    context, this report also presents information on known species assemblages and environmental
    influences on the estuarine and marine habitat. This report also attempts to acknowledge other
    habitat attributes that influence nearshore and estuary conditions and are important to salmon
    smolt physiology and to the trophic dynamics that support the abundance and resilience of
    current salmon populations.
    
    Habitat Condition
    
    The abundance, resilience, and stability of regional salmon populations are at once a product of
    and contribute to the currently healthy habitat, which includes the water quality. Natural
    ecosystem and hydro-geomorphic processes in the region remain functionally intact from
    headwater tributaries through marine waters. Salmon are abundant at various life history stages,
    which abundance influences and contributes to the productivity of other fisheries at multiple
    trophic levels. At their current abundance, salmon influence habitat condition in these watersheds
    by providing a rich source of nutrition to a broad range of invertebrates, fish, and marine
    mammals, as well as to countless terrestrial flora and fauna. Salmon enrich watersheds and
    influence water chemistry.
    
    Water
    
    Fish habitat includes not only structure such as hard substrate, reefs or rock, and vegetation such
    as eel grass or kelp, but also—and it seems odd to have to say so—the water itself. The success
    and abundance of a species are largely determined by the quality of the water, its temperature, its
    salinity, and its chemical composition, which includes the availability of nutrients  necessary for
    life. If nutrient sources, forage opportunities, and  prey are diminished, the habitat itself is
    changed, and all the dynamics of the food web are thus altered.
    
    Nushagak and Kvichak Bays resemble other Alaskan estuaries as  subarctic and allochthonous
    (turbid) in nature. As discussed above, these waters are dominated by seasonal freshwater runoff
    from snow melt and rains. Turbidity in the bays minimizes photosynthesis, primary production,
    and associated algal blooms; however, nutrient is  carried in outwelling discharge of detritus,
    dissolved organic material, and salmon-derived nutrients. These materials provide  the essential
    nutrients and energy for lower trophic levels supporting assemblages of minute bacteria, fungi
    and algae, through larval stages of plankton, invertebrates, juvenile fish and salmon smolt. The
    abundance and availability of nutrient sources at the lower trophic levels 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.
    
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    Estuaries
    
    Although no studies to date have been conducted specifically identifying the importance of
    estuarine habitat to salmon smolt in Nushagak and Kvichak Bays, a number of other studies
    conducted in Alaska and the Northwest document several attributes of estuaries important to
    juvenile salmon smolt (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, Koski 2009). Cited studies
    identify estuaries as an often preferred habitat choice for coho salmon, providing increased food
    and growth, expanding their nursery area, and increasing overall production from the watershed.
    
    The high productivity of some estuarine habitats in Alaska and the Northwest allows an array of
    life history patterns (Healey 1983). One such pattern involves rearing in both rivers and
    estuaries, allowing salmon to migrate and rear in 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.). Being able to move
    between estuary and river increases feeding opportunities, allows  smolt to achieve critical size
    (as discussed below), and supports osmoregulatory change in their early marine phase. The
    dominant freshwater influence of Nushagak and Kvichak Bays supports osmoregulatory
    adjustment prior to entry into the highly saline marine phase. It should also be recognized that
    smolt outmigration coincides with increased freshwater influence  in these estuaries. Similar
    studies and literature of northwest salmon substantiate the importance of estuarine habitat to
    salmon smolt survival (Rich 1920, Healey 1982, Levy 1992, Thorpe 1994, Groot and Margolis
    1998, Bottom 2005, Quinn 2005, Koski 2009).
    
    Studies focused on flatfish species in other regions further identify the importance of estuarine
    habitat as fish nurseries. Disproportionate numbers of juvenile flatfish from  estuarine habitat
    compose adult populations found in nearshore marine waters (Brown 2006). In this instance,
    although estuarine habitat composes only about 6% of the available juvenile habitat, the estuary
    appears to be the source of approximately half of the adult fish collected in the region. These
    results validate previous findings further explaining the linkage between estuarine and nearshore
    habitats for other species (Yamashita et al. 2000, Forrester and Swearer 2002, Gillanders  et al.
    2003). As noted in this review, these nearshore waters are "fish nurseries" supporting numerous
    species in their larval and juvenile life history stages.
    
    Salmon Food Habits
    
    Studies of the feeding habits of North Pacific salmon in general (that is, not specific to Bristol
    Bay salmon) show that the species' feeding habits vary by species, life stage, region, and
    seasonal prey availability. Prey species repeatedly identified were euphausiids, hyperiids,
    amphipods, copepods, pteropods, and chaetognaths. Egg, larval, and juvenile stages of numerous
    
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    forage fish, groundfish, and invertebrate species were also identified. Landingham and
    Sturdevant (1997) report 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 nearshore invertebrate prey assemblages for salmon smolt (Houghton 1987,
    Moulton 1997, summarized in USFWS 2009). Brodeur and Pearcy (1990) describe prey of all
    five North Pacific salmon and ocean-phase trout in all  regions where they occur.
    
    These studies analyzed stomach-content data and reveal that juvenile salmon ingest substantial
    quantities of food while in nearshore and estuary habitat. Salmon smolts tended to be well
    nourished and in some cases demonstrated prolonged estuarine  residence time feeding
    extensively on plentiful larval invertebrate and juvenile fish species. Although these studies are
    not specific to Bristol Bay, the salmon prey species identified in these studies are also abundant
    in the Nushagak and Kvichak Bays.
    
    Salmon Critical Size
    
    The importance of abundant prey opportunities during the transition from fresh to marine waters,
    especially in the early  marine phase, has been illustrated  in "critical size"  discussions. Earlier
    studies suggest that more slowly 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 commonly fail to survive their first winter (Mahnken et al.
    1982). Stunted smolt suffer protein-energy deficiency and are more likely to become prey for
    other marine species. 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 again suggest that reduced growth 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, Farley et al. 2011).
    
    Trophic Contribution
    
    Salmon-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 carbon and nitrogen, 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,
    marine estuaries and nearshore zones benefit from seasonal pulses of these nutrients. Terrestrial
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    and aquatic species, from invertebrates and insects to mammals, as well as aquatic and riparian
    vegetation, also receive benefit from these seasonal pulses (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-influencing estuaries and nearshore coastal zones
    (Kennish 1992, Caddy 1995 and 2000, Milliman 2010, Dade 2012). Watershed and riparian
    processes influence downstream estuaries through the transport of terrestrial and freshwater
    nutrients (Murphy 1984, Jauquet et al. 2003, Jonsson and Jonsson, 2003, Cak 2008, Von Biela
    2013). Nutrient metabolism in estuaries can be strongly influenced by freshwater river inputs of
    organic and inorganic material (Hopkinson 1995, Kennish 2002).  Some studies have
    demonstrated the importance of terrestrial-generated carbon to juvenile and adult bottom-
    dwelling marine fish species in periods of even moderate river discharge (Darnaube 2005).
    Recently, these nutrient sources have been identified as contributing to coastal estuaries and
    trophic interaction in Arctic zones as well (Dunton 2006 and 2012, Von Biela 2013).
    
    Salmon-derived nutrients influence and contribute to estuary production of seasonal larval and
    juvenile plankton, invertebrate and fish species. One early study to suggest the influence of these
    nutrients on estuary water chemistry was conducted in Port Walther, Alaska (Brickell  and
    Goering 1970). This study found that after spawning and dying in Sashin Creek, salmon
    carcasses 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)
    reports that 43% of tagged carcasses in one watershed washed into the estuary within days.
    Fujiwara (1997) presents evidence suggesting that dissolved nutrients fuel estuarine productivity
    and associated bacteria and algae, which in turn increase the numbers of harpacticoid copepods
    that serve as primary prey for outbound juvenile salmon. Estimates of recent nutrient transport
    indicate that substantial amounts of salmon-derived nutrients (46%-60%) move directly back to
    the estuary (Mitchell and Lamberti 2005). A similar study suggests that bivalves also benefit
    from these nutrients (Chow 2007).
    
    The results of this research indicate an influence of salmon-derived nutrients on trophic
    productivity in marine estuaries. These studies also suggest a positive feedback mechanism in
    salmon production, given that decomposing adult salmon subsidize lower trophic levels and
    provide prey species to their outbound offspring (Fujiwara and Highsmith 1997, Gende et al.
    2004). As Aydin (2010)  explains, "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
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    pollock inhabiting northern Bristol Bay nearshore waters. This unusually high nitrogen signal
    may result from the seasonal increase of freshwater discharge and dissolved organic matter (a
    seasonal terrestrial nutrient pulse from salmon) carried on currents along the northern shore of
    Bristol Bay. In addition, smolt emigration theoretically exports more nutrients out of the
    watersheds than previously recognized, and salmon in sub-adult and adult phases in the eastern
    Bering Sea and North Pacific also contribute to marine mammal diets.
    
    Summary
    
    Pacific salmon are a keystone species providing nutrients that influence the habitat condition of
    terrestrial, estuarine and marine ecosystems (Willson and Halupka 1995; Cedarholm et al.1999;
    Helfield and Naiman 2001; Piccolo et al. 2009). Due to their life history, anadromy, range, and
    distribution, Bristol Bay salmon represent a link between fresh water and marine systems.
    Discharges of seasonal freshwater transport dissolved organic matter to the estuary. The
    freshwater discharge facilitates osmoregulatory adaption in salmon smolts, providing a buffer to
    highly saline marine conditions. The estuary provides rich foraging opportunities and a rearing
    environment that allow smolt to achieve the size essential for survival in the early marine phase.
    At the beginning of their life cycle, emigrating smolt from rivers contribute to estuarine and
    marine productivity as a forage fish species. At the end of their life cycle, adult salmon provide
    the nutrients that influence productivity from watersheds through the estuary. These nutrient
    sources provide a feedback mechanism to their outbound offspring fueling lower trophic levels,
    from minute bacteria and fungi to a multitude  of plankton, invertebrate, fish, and marine
    mammal species.
    
    Bristol Bay provides EFH for salmon at various life stages as well as other marine species. The
    Nushagak and Kvichak estuaries provide nutrient-rich transition zones where salmon smolt can
    achieve critical size while acclimating to the marine environment. At an ecosystem level, from
    the head water tributaries through the marine environment, the healthy habitat of the bay both
    supports and results from the interactions between natural processes and the presence and
    abundance of Bristol Bay salmon.
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    Waite,  J. M., M. E. Dahlheim, R. C. Hobbs, S. A. Mizroch, O. von Ziegesar-Matkin, L. M.
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                                              41
    

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                                               42
    

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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).
                 FTSH SPECIES
                 Common Name
    Scientific Name
                 Chinook salmon
                 Chum salmon
                 Steelhead
    Salmonidae
    Oncorhynchus tshawytscha
    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
                 Pacific sandfish
     Trichodontidae
     Trichodon trichodon
                 Pacific halibut
    Pleuronectidae
    Hippoglossus stenolepis
                                                   43
    

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    Yellowfin 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.
                                          Limanda aspera
                                          Lepidopsetta polyxystra
                                          Lepidopsetta sp.
                                          Hippoglossoides elassodon
                                          Microstomus pacificus
                                          Glyptocephalus zachirus
                                          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
    Sawback poacher
    Gray starsnout
    Sturgeon poacher
    Aleutian alligatorfish
    Arctic alligatorfish
    Warty poacher
    Bering poacher
                                          Psychrolutidae
                                          Leptagonus frenatus
                                          Bathyagonus alascanus
                                          Podothecus accipenserinus
                                          Aspidophoroides bartoni
                                          Ulcina olrikii
                                          Chesnonia verrucosa
                                          Occella dodecaedron
                                         44
    

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    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
    sculpin
    Brightbelly sculpin
    Warty sculpin
    Great sculpin
    Plain sculpin
     Triglops sp. Ribbed
     Triglops pingeli
    Microcottus sellaris
    Myoxocephalus verrucosus
    Myoxocephaluspolyacanthocephalus
    Myoxocephalus jaok
    Pacific staghorn sculpin
    Antlered sculpin
    Spinyhead sculpin
    Crested sculpin
    Eyeshade sculpin
    Sailfm sculpin
    Bigmouth sculpin
    Thorny sculpin
    Spatulate sculpin
    Myoxocephalus sp.
    Leptocottus armatus
    Enophrys diceraus
    Dasycottus setiger
    Blepsias bilobus
    Nautichthys prib ilovius
    Nautichthys oculofasciatus
    Hemitripterus bolini
    Icelus spiniger
    Icelus spatula
    Variegated snailfish
    Snailfish unident.
    Liparis sp.
    Liparis gibbus
    Liparidinae
                                         45
    

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    Daubed shanny
    Snake prickleback
    Decorated warbonnet
    Bearded warbonnet
    Polar eelpout
     Stichaeidae
     Lumpenus maculatus
     Lumpenus sagitta
     Chirolophis decoratus
     Chirolophis snyderi
     Lycodes turneri
    Giant wrvmouth
     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
    Aleutian hermit
    Splendid hermit
    Knobbyhand hermit
    Fuzzy hermit crab
    Bering hermit
    Alaskan hermit
    Longfmger hermit
    Wideband hermit crab
    Hairy hermit crab
     Cancer sp.
     Cancer oregonensis
     Oregonia gracilis
     Chionoecetes bairdi
     Hyas coarctatus
     Hyas lyratus
     Chionoecetes opilio
     Chionoecetes hybrid
     Telmessus cheiragonus
     Paguridae
     Pagurus sp.
     Pagurus brandti
     Pagurus aleuticus
     Labidochirus splendescens
     Pagurus confragosus
     Pagurus trigonocheirus
     Pagurus beringanus
     Pagurus ochotensis
     Pagurus rathbuni
     Elassochirus tenuimanus
     Pagurus capillatus
    46
    

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    Purple hermit
    Wrinkled crab
    
    Fuzzy crab
    Red king crab
    Horsehair crab
     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.
     Pandalusjordani
     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
    
    mussel
    Weathervane scallop
    Arctic hiatella
    Arctic roughmya
    
    Crisscrossed yoldia
    Northern yoldia
    Discordant mussel
    Boreal astarte
     Mytilidae sp.
     Modiolus modiolus
     Mytilus sp. Blue
     Mytilus edulis
     Patinopecten caurinus
     Hiatella arctica
     Panomya norvegica
     Yoldia sp.
     Yoldia seminuda
     Yoldia hyperborea
     Musculus discors
     Astarte borealis
    47
    

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    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)
    
    Snail, snails, welk
    
    Aleutian moonsnail
    Rusty moonsnail
    Pale moonsnail
    Great slippersnail
    Moonsnail eggs unident
    
    Warped whelk
     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
     Natica clausa sp.
     Cryptonatica aleutica
     Cryptonatica russa
     Euspira pallida
     Crepidula grandis
     Naticidae eggs
     Volutopsius sp.
     Pyrulofusus deformis
     Beringius sp.
     Beringius kennicottii
    48
    

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    Pribilof whelk
    
    Lyre whelk
    Fat whelk
    
    Helmet whelk
    
    
    Oregon triton
    
    Rosy tritonia
    
    whelk
    Sinuous whelk
    Ladder whelk
    Polar whelk
    Smooth lamellaria
    
    Snail eggs
    Snail eggs unident.
    Beringius beringii
    Neptunea sp.
    Neptunea pribiloffensis
    Neptunea borealis
    Neptunea lyrata
    Neptunea ventricosa
    Neptunea hems
    Clinopegma magnum
    Plicifusus kroyeri
    Neptunea sp.
    Fusitriton oregonensis
    Tritonia sp.
    Tritonia diomedea
    Buccinum sp. Angular
    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
    Anemone
    
    Sea anemone unident.
    
    Clonal plumose anemone
    Gigantic anemone
    Mottled anemone
    Chevron-tentacled anemone
    Halipteris sp.
    Actiniaria
    Metridium sp.
    Metridium senile
    Metridium farcimen (=Metridium
    giganteum)
    Stomphia sp.
    Urticina sp.
    Urticina crassicornis
    Cribrinopsis fernaldi
                                        49
    

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    Tentacle-shedding anemone
    Stony coral unident.
     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
     Asterlas sp.
     Asterias amurensis
     Ophiuroidea
     Gorgonocephalus eucnemis
     Ophiura sarsi
    Sea urchin
    Green sea urchin
    Sand dollar
     Echinacea sp.
     Strongylocentrotusdroebachiensis
     Strongylocentrotus sp.
     Strongylocentrotus polyacanthus
     Echinarachnius parma
    Sponges
    
    Stone sponge
    Clay pipe sponge
    Barrel sponge
    
    Sponge
     Stelletta sp.
     Suberites ficus
     Aphrocallistes vastus
     Halichondria panicea
     Suberites sp.
     Porifera
    50
    

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    Jelly fish
    
    Jelly Fish
    Lion's mane
    Chrysaora j ellyfish
    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
    Eunoenodosa
    Eunoe depressa
    Notostomobdella cyclostoma
    Echiura
     Nephtyidae
     Polynoidae
    Sipuncula
    Hydroids
    
    Bryozoans
    Feathery bryozoan
    Leafy bryozoan
    
    Ribbed bryozoan
    Bryozoan unident.
    Abietinaria sp.
    
    Eucratea loricata
    Flustra serrulata
    Alcyonidium pedunculatum
    Rhamphostomella costata
    Bryozoa
    Sea Cucumbers
    
    Sea football
    Sea cucumber
    
    Foraminiferan unident.
    Cucumaria sp.
    Cucumariafallax
    Holothuroidea
    Cucumaria frondosa
    Psolus sp.
    Foraminifera
                                        51
    

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    Ascidians
    Orange sea glob                        Aplidium sp.
    Sea pork                              Aplidium californicum
                                          Molgula sp.
    Sea grape                             Molgula grifithsii
    Sea clod                              Molgula retortiformis
                                         52
    

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    Table 2: Marine Mammals Species List
    Marine mammal species listed have been identified from several sources (Allen 2011, ADFG
    2010, BBESI2001, 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
    Delphinaptems 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
    Eschrichtius robustus
    Megaptera novaeangliae
    Balaenoptera physalus
    Balaenoptera acutorostrata
    Balaena mysticetus
                 Sealion
    Pinnipeds - Otariidae
                 Steller sea lion (Eastern)
                 Northern fur seal (Eastern)
    Eumetopias ju batus
    Callorhinus ursinus
                 Seals
    
                 Harbor seal
                 Spotted seal
                 Bearded seal
                 Ringed seal
                 Ribbon seal
    Pinnipeds - Phocidae
    
    Phoca vitulina
    Phoca largha
    Erignathus barbatus
    Pusa hispida
    Histriophocafasciata
                                                Pinnipeds - Odobenidae
                 Walrus
    Odobenus rosmarus
                                                Mustelidae - Lutrinae
                 Northern Sea Otter
    Enhydra lutris kenyoni
    

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    AN ASSESSMENT OF POTENTIAL MINING IMPACTS ON
      SALMON ECOSYSTEMS OF BRISTOL BAY, ALASKA
    
                 VOLUME 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
    

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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
                           January 2014
    

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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. 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 Iliamna 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 Iliamna, 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 Iliamna 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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                                                          Koliganek
                                                                      Newhal
                                                Aleknagik
                               Togiak Twin Hills
                                      Manokotak
                                                 illingham
                                                Clark's Point
     New Stuyahok
    •Ekwok        Jgiugig
         Levelock
                                                                              Port Alsworth
    
                                                                          Nondalton
                                                                          I
                                                                          'lliamna  Pedro Bay
    
    
                                                                          Kokhanok
                                         Vl
                                                           Naknek
                                                     South Naki
    	 ADOT major roads
    	ADNR secondary roads
        Proposed infrastructure corridor
      3 Pebble deposit
    
    0  25  50     100 Kilometers
       ili
                                             Port Heiden
                                             .^
    Figure 1. Existing roads in the Bristol Bay region, and the proposed route 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 Connect!on, 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 major
    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
    
    
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    and activities on adjoining aquatic areas as follows:
    
           1) Loss of natural vegetation;
           2) Loss oftopsoil;
           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, these 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
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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, glacio-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 subsurface-to-surface 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
    
    
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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 indicate 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
    
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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.
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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
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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 corndo
                                                                       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.
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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
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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 Iliamna
    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).
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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). * 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).
    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.
    
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                                                        Anadromous Waters Catalog streams
    
                                                        National Hydrography Dalaset 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).
    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.
    
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                                                                 Sockeye spawning densities. 1955-2011
                                                                   •  60-4.200
                                                                   •  4,200 -12.200
    
                                                                     12.200-26,000
    
                                                                     26.000-72.800
    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
     Morstad (2003) with additional information on sampling locations from Harry Rich
    (2011, and University of Washington, Seattle, WA, unpublished data)
    
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                                                                  Average fry calcn 19b1-1976
                                                                   »  0-33
    
                                                                   O  34 - 128
    
                                                                      129-330
    
                                                                      331 - 564
    Figure 5. Iliamna 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).
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                                         3ter 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.8 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).
    
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                                      Freshwater Fish Inventory data points     Proposed infrastructure corridor
    
                                     1 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 by9
    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.
      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).
    
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                                   •  Freshwater Fish Inventory data points     Proposed infrastructure corridor
    
                                   ^^— Anadromous Waters Catalog streams fxxX^j Pebble deposit
    
                                      National Hydrography Dataset streams 62 streams crossed by corridor
    Figure 6c. Resident or non-anadromous streams crossed or potentially affected by11 the
    western one-third of the potential Pebble Mine transportation corridor.12  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).
    
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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.
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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
    (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).
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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 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 increase 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 (USD A 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-surface 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
    help limit the discharge of material in the event of leaks or spills, but would have the
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    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
    contaminated soils at dry, stable sites far removed from surface waters or shallow
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    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.
        4)  Likelihood of ice  flows and drives during thaws that can make water crossing
           structures problematic locations for jams and plugging.
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    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
        and fishing, use of off-highway vehicles, increased mineral prospecting, and
        others.
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    •  For the Pebble road corridor, each stream or wetland crossing has the potential for
       impacts to not just 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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                                ACKNOWLEDGEMENTS
    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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                                             41
    

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                                              42
    

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       disturbance-a narrative review of  case studies. Environmental Management 14:547-570.
                                              44
    

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                                   Attachment A
    
    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
    Coho
    
    
    
    
    Coho
    
    
    
    Chinook,
    chum, coho,
    sockeye
    
    
    
    
    
    
    
    
    Coho
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
                                      46
    

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    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
    Varden
    
    
    Yes (spp.?)
    
    Yes(spp.?)
    
    
    
    
    
    Arctic char,
    chinook,
    coho,
    sockeye
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    Arctic char,
    sockeye
    
    
    
    
    
    
                                      47
    

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    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
    34
    19030206006671
    19030206006663
    NE Eagle Bay Cr 19030206006654
    Young's Cr, 19030206006598
    mainstem
    Young's Cr, east 19030206006553
    branch
    Chekok Cr, west 19030206006533
    branch
    Chekok Cr, 19030206032854
    mainstem
    Canyon Cr 19030206006359
    19030206006336
    19030206006337
    19030206006236
    2
    2
    1
    3
    3
    2
    3
    3
    1
    1
    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]
    [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
    

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    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
    ChinkelyesCr 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
    

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    AN ASSESSMENT OF POTENTIAL MINING IMPACTS ON
      SALMON ECOSYSTEMS OF BRISTOL BAY, ALASKA
    
                 VOLUME 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
    

    -------
    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
    

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                    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
    

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                    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
    

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                                                                                                m»iK       ••-••;-.iV",   ,    /..,£•
                               lJM4! KX&iHcnlirr niJut, culnuloi
                                                                    V.it«jtjiic. ml
    
    
                                                               Kg   I~r=lmj3nu fmttii nicka
                                                                                                        TTDC
    IJM^^XC Wuk— Siio!
    
    
    TIU&JL. _Lnl&: uxjkt
    
    
    \U('' . I'LjIII- • :« i
                             Tbitivr ir rrclKimu i uk-un. n.iit
                       TKgi   Tcitivt or rr=lmoH» ^naibt. iixii
                                                               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
    

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             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
    

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             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
    
    
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                                                     30
    

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    AN ASSESSMENT OF POTENTIAL MINING IMPACTS ON
      SALMON ECOSYSTEMS OF BRISTOL BAY, ALASKA
    
                 VOLUME 3—APPENDICES E-J
    Appendix I: Conventional Water Quality Mitigation Practices
       for Mine Design, Construction, Operation, and Closure
    

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                      Appendix I
    
     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
                   Office of Research and Development
                  U.S. Environmental Protection Agency
                         Washington, DC
    

    -------
    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
    accurate characterization and 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
    

    -------
    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 and leaching of ions 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
    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
    

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    acid-generation potential). The viability of blending as a mitigation measure depends on
    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
    

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    material), with choices dependent upon site specifics (O'Kane and Wels 2003).
    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
    

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    tracers behaved differently in weathered waste rock piles versus newer piles.  Results
    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
    

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    chemicals (Mining Minerals and Sustainable Development (MMSD) 2002, U.S.
    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
    

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    a tailings dam in a valley. As tailings are placed behind the dam, a basin is formed. The
    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
    

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    would be the largest quake that could occur reasonably at any location at the mine site,
    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
    

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    et al. (2011) presents that a nonexposed HOPE liner could have a predicted lifetime ("as
    measured by its halflife") 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).
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    Monitoring groundwater quality for contaminant transport includes piezometers for
    groundwater mounding assessment.  Regular inspections/monitoring for TSF stability
    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
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    quality. The reclaimed facility should be monitored for any deformations, structural
    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 for TSFs 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
    for TSF 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
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    order of decreasing percentage contribution. Weather causes were observed to have
    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
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    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.
    
    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.
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    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
    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
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    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,
    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
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    closure to minimize potential for overtopping due to precipitation. For TSF ponds
    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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           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.
                                                                                 24
    

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    AN ASSESSMENT OF POTENTIAL MINING IMPACTS ON
      SALMON ECOSYSTEMS OF BRISTOL BAY, ALASKA
    
                 VOLUME 3—APPENDICES E-J
      Appendix J: Compensatory Mitigation and Large-Scale
          Hardrock Mining in the Bristol Bay Watershed
    

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                                                           December 2013
                           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
    
                            Joseph Ebersole
                     U.S. Environmental Protection Agency
                     Office of Research and Development
                         Western Ecology Division
    
                              Rachel Fertik
                     U.S. Environmental Protection Agency
                             Office of Water
                   Office of Wetlands, Oceans and Watersheds
    

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                                      Table of Contents
    
    1 Overview of Clean Water Act Section 404 Compensatory Mitigation Requirements	2
      1.1 Compensatory Mitigation Methods	3
      1.2 Compensatory Mitigation Mechanisms	4
      1.3 Location, Type, and Amount of Compensation	4
      1.4 Compensatory Mitigation Guidance for Alaska	6
    2 Compensatory Mitigation Considerations for the Bristol Bay Assessment	7
      2.1 Important Ecological Functions and Services Provided by Affected Streams and
      Wetlands	7
      2.2 Identifying the Appropriate Watershed Scale for Compensatory Mitigation	9
    3 Potential Compensatory Mitigation Measures in Bristol Bay	 11
      3.1 Mitigation Bank Credits	11
      3.2 In-Lieu Fee Program Credits	13
      3.3 Permittee-Responsible Compensatory Mitigation	13
       3.3.1 Opportunities within the NFK, SFK, and  UTC Watersheds	13
         3.3.1.1 Increase Habitat Connectivity	14
           3.3.1.1.1 Remove Beaver  Dams	15
           3.3.1.1.2 Connect Off-channel Habitats and Habitat Above Impassible Waterfalls	 16
         3.3.1.2 Increase Habitat Quality	19
         3.3.1.3 Increase Habitat Quantity	21
         3.3.1.4 Manage Water Quantity	23
           3.3.1.4.1 Direct Excess On-site Water	23
           3.3.1.4.2 Augment Flows	25
           3.3.1.4.3 Pump Water Upstream	26
         3.3.1.5 Manipulate Water Quality	27
           3.3.1.5.1 Increase Levels of Alkalinity, Hardness, and Total Dissolved Solids	27
           3.3.1.5.2 Increase Levels of Nitrogen and/or Phosphorus	29
         3.3.1.6 Preserve Aquatic Resources	33
       3.3.2 Other Opportunities within the Nushagak and Kvichak River Watersheds	33
         3.3.2.1 Remediate Old Mine Sites	33
         3.3.2.2 Remove Roads	34
         3.3.2.3 Retrofit Road Stream Crossings	34
         3.3.2.4 Construct Hatcheries	35
         3.3.2.5 Stock Fish	36
      3.4 Other Suggested Compensation Measures	36
    4 Effectiveness of Compensation Measures at Offsetting Impacts to Salmonids	 37
    5 Conclusions	38
    6 References	39
    

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    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 outside the scope of the assessment.
    
    1. Overview of Clean Water Act Section 404 Compensatory Mitigation
       Requirements
    
    The overall objective of the Clean Water Act is to restore and maintain the chemical,
    physical and biological integrity of the nation's waters. To help achieve that objective,
    Section 404 of the Clean Water Act establishes a program to regulate the discharge of
    dredged or fill material into waters of the United States, including wetlands. Section
    404 requires a permit before dredged or fill material may be discharged into waters of
    the United States, unless the activity is exempt from Section 404 regulation (e.g. certain
    farming and forestry activities).
    
    The U.S. Environmental Protection Agency (EPA) and the Department of the Army,
    operating through the Army Corps of Engineers (ACOE), share responsibilities for
    implementing the Section 404  program. Section 404(a) authorizes the ACOE to issue
    permits for the discharge of dredged or fill material into waters of the U.S. at specified
    disposal sites. Section 404(b) directs the ACOE to apply environmental criteria
    developed by EPA in making its permit decisions (these criteria are binding regulations
    known as the "Section 404(b)(l) Guidelines" (40 CFR Part 230)). Under EPA's Section
    404(b)(l) Guidelines, no discharge of dredged or fill material may be permitted by the
    ACOE if: (1) a practicable alternative exists that is less damaging to the aquatic
    environment so long as that alternative does not have other significant adverse
    environmental consequences or (2) the nation's waters would be significantly degraded.
    Under the Guidelines, a project must incorporate all appropriate and practicable
    measures to first avoid impacts to wetlands, streams, and other aquatic resources and
    then minimize unavoidable impacts; after avoidance and minimization measures have
    been applied, the project must include appropriate and practicable compensatory
    mitigation for the remaining unavoidable impacts.
    
    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 EPA and the ACOE
    (40 CFR §§ 230.91 - 230.98 and 33 CFR §§ 332.1 - 332.8) state that  "the fundamental
    

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    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 type of 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)).
    
    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,
    

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           and those resources are under threat of destruction or adverse modification (40
           CFRPart230.93(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 according to the
           compensation planning framework approved by ACOE. Typically specific
           compensatory mitigation projects are started only 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 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 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 appropriate and practicable" (40 CFR 230.93(c)(l)).  Under
    these 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
    

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    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
    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. 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 focus
    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)).
    

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    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,
    and 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
    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)).
    
    Although 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 does not address 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,
    

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    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
    of fish 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.
    
    In the Bristol Bay region, hydrologically-diverse  riverine and  wetland  landscapes provide
    a variety of salmon spawning and rearing habitats. Environmental conditions can be
    very different among habitats in close proximity, with ponds, lakes and streams
    expressing very different flow, temperature, and physical habitat characteristics at very
    fine spatial scales (see Chapter 7 of the assessment for additional discussion). Recent
    research has highlighted the potential for local adaptations and fine-scale population
    structuring in Bristol Bay and neighboring watersheds associated with this
    environmental template (Quinn et al. 2001, Olsen et al. 2003, Ramstad et al.  2010,
    Quinn et al. 2012). For example, sockeye salmon that use spring-fed ponds and streams
    located approximately 1 km apart exhibit differences in traits such as spawn timing,
    spawn site fidelity, and productivity consistent with discrete populations (Quinn et al.
    2012). 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
    assessment's scenarios provide important ecological functions. These headwater
    streams provide spawning habitat for coho and  sockeye salmon and  likely spawning
    habitat for anadromous and resident forms of Dolly Varden.  Headwater streams and
    associated wetlands also provide rearing habitat for chum salmon, sockeye salmon,
    Chinook salmon, coho salmon, Dolly Varden, rainbow trout,  Arctic grayling, slimy
    

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    sculpin, northern pike, and ninespine stickleback (Johnson and Blanche 2012, ADFG
    2012a). Headwater streams and associated wetlands are often exploited by fish for
    spawning and rearing because they can provide refuge from predators and competitors
    that are more abundant downstream (Quinn 2005). Off-channel wetlands with their
    unique low-velocity, depositional environments and variable thermal conditions provide
    additional options for juvenile salmon feeding and rearing. For example, ephemeral
    swamps provided important thermal and hydraulic refuge for  coho salmon in a coastal
    British Columbia stream (Brown and Hartman 1988). Off-channel ponds provided highly
    productive foraging environments and enhanced overwinter growth of coho salmon in
    an interior British Columbia stream (Swales and Levings 1989).
    
    It has long been recognized that 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, algae, bacteria and macroinvertebrates
    downstream, to higher order streams in the watershed (Vannote et al. 1980, Meyer et
    al. 2007). But only recently have specific subsidies from headwater systems been
    extensively quantified (Wipfli and Baxter 2010). 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,
    thereby determining downstream water chemistry due to relatively large organic matter
    inputs, high retention capacity, high primary productively, bacteria-induced
    decomposition, and extensive hyporheic zone interactions (Richardson et al. 2005,
    Alexander et al. 2007, Meyer et al. 2007). Because of their crucial influence on
    downstream water flow, chemistry, and biota, impacts to headwaters reverberate
    throughout entire watersheds downstream (Freeman et al. 2007, Meyer et al. 2007).
    
    The majority of streams  directly in the footprint of the mine scenarios are classified as
    small headwater streams (less than 0.15 m3/s mean annual streamflow) (see
    assessment Table 7-6). Because of their narrow width, headwater streams receive
    proportionally larger inputs of organic material than do larger stream channels (Vannote
    et al. 1980). This material is either used in the headwater environment (Tank et al.
    2010) or transported downstream as a subsidy to larger streams in the network (Wipfli
    et al. 2007). Consumers in headwater stream food webs, such as invertebrates, juvenile
    salmon, and other fishes rely heavily on the terrestrial inputs that enter the stream
    (Doucett et al. 1996, Eberle and Stanford 2010, Dekar et al. 2012).  Headwater streams
    also encompass the upper limits of anadromous fish distribution, and may receive none,
    or lower quantities of marine-derived nutrients (MDN) from spawning salmon relative
    to downstream portions of the river network, making terrestrial nutrient sources
    relatively more important (Wipfli and Baxter 2010).
    
    Both invertebrates and detritus are exported from headwaters to downstream reaches
    and provide an important energy subsidy for juvenile salmonids (Wipfli and  Gregovich
    2002, Meyer et al. 2007). Headwater wetlands and associated wetland vegetation can
    also be important sources of dissolved and particulate organic matter, and
    
                                                                                 8
    

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    macroinvertebrate diversity (King et al. 2012), contributing to the chemical, physical,
    and biological condition of downstream waters (Shaftel et al. 2011a, Shaftel et al.
    2011b, Dekar et al. 2012, Walker et al. 2012).  Thus, losses of headwater streams and
    wetlands due to the mine scenario footprints would not only eliminate important fish
    habitat but also reduce inputs of organic material, nutrients, water, primary producers,
    bacteria, and macroinvertebrates to reaches downstream of the mine scenario
    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) (see Figure 1). 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), Yocom and Bernard  2013). An important consideration is that salmon
    populations in these watersheds may possess unique adaptations to local
    environmental conditions, as suggested by recent research in the region (Quinn et al.
    2001, Olsen et al. 2003, Ramstad et al. 2010, Quinn et al. 2012). Accordingly,
    maintenance of local biocomplexity (i.e., salmon genetic, behavioral, and phenotypic
    variation) and the environmental  template upon which biocomplexity develops will be
    important for sustaining resilience of these populations (Hilborn et al. 2003, Schindler et
    al. 2010). Thus, the most appropriate spatial scale and context for compensation would
    be within the local watersheds where impacts to salmon  populations occur.
    
    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 under the mine scenarios would be
    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).
    

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                                                                  165' W
                                                                    I
                                                     r
    
                                    lliamna    . 	.  Pedro Bay
                  Approximate Pebble Deposit Location
    
                  Towns and Villages
    
                  Scale 1: Bristol Bay Watershed
    
                  Scale 2: Nushagak & Kvichak River Watersheds
    
                  Scale 3: Mine Scenario Watersheds
    
                  Scale 4: Mine Scenario Components
    
                  Scale 5: Transportation Corridor Area
                          N
                          A
                         50  100
                              ] Kilometers
                         50      100
                                3 Miles
    Figure 1. The boundaries of the Bristol Bay watershed (brown), the Nushagak and Kvichak River watersheds (green) and the
    North Fork Koktuli, South Fork Koktuli, and Upper Talarik Creek watersheds (blue).
                                                                                                                                       10
    

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    3.  Potential Compensatory Mitigation Measures in Bristol Bay
    
    As discussed in Chapter 7 of the Bristol Bay Assessment, impact avoidance and
    minimization measures do not eliminate all of the footprint impacts associated with the
    mining scenarios. Reasons impact avoidance and minimization measures fail to
    eliminate these kinds of impacts include: the large extent and wide distribution of
    wetlands and streams in the watersheds, the fact that substantial infrastructure would
    need to be built to support porphyry copper mining in this largely undeveloped area and
    the fact that ore body location constrains siting options. The mine scenarios evaluated
    in the assessment identify that the mine footprints alone would result in the
    unavoidable 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 (see Figure 2).
    
    The public and peer review comments on the draft Bristol Bay Assessment identified an
    array of compensation measures that some commenters believed could potentially
    offset these impacts to wetlands, streams, and fish. The following discussion considers
    the likely efficacy of the complete  array of compensation measures proposed by
    commenters at offsetting potential adverse effects, organized 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
    address the impacts associated with the mine scenarios, they would  likely encounter the
    same challenges described below (Section 3.3).
    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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               Bfi..  f
               *            "'
                                                              Pebble 6.5 Components
    
    
                                                              Drawdown Zone
                                                              Eliminated. Blocked, or Oewatered Streams
                                                              Eliminated, Blocked, or Dewatered
    
                                                              Lakes and Ponds
                                                              Eliminated. Blocked, or Dewatered Wetlands
    Figure 2. Streams, wetlands and other waters lost (eliminated, blocked, or dewatered)
    
    in the Pebble 6.5 scenario evaluated in the Bristol Bay Assessment.
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    3.2 In-Lieu Fee Program Credits
    
    There is currently one in-lieu fee program approved to operate in the Bristol Bay
    watershed, which has been 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. Although the majority
    of in-lieu fees collected by the TCP program have been for relatively small impacts to
    aquatic resources, TCP has accepted in-lieu fees to compensate for a few projects with
    over 50 acres of impacts statewide. 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.  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 scenarios. In addition, it is likely that any in-lieu fee sponsor seeking to
    address the impacts associated with the mine scenarios would encounter the same
    challenges described below (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. 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., on the same site as the impacts or on 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 (40 CFR 230.93(b)(6)).
    
    3.3.1 Opportunities within the NFK, SFK, and UTC Watersheds
    
    In the context of the mine scenarios, the primary challenge to both a watershed
    approach and on-site compensatory mitigation is the absence of existing degraded
    resources within the NFK, SFK and UTC watersheds. Specifically, these three watersheds
    are largely unaltered by human activities; thus, opportunities for restoration or
    enhancement are very limited, and, as discussed below, likelihood of success appears to
    be very low.
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    Here we discuss specific suggestions for potential compensation measures within the
    NFK, SFK and UTC watersheds that were provided in the public and peer review
    comments on the Bristol Bay Assessment.
    
    3.3.1.1 Increase Habitat Connectivity
    
    Connectivity among aquatic habitats within stream networks is an important attribute
    influencing the ability of mobile aquatic taxa to utilize the diversity and extent of
    habitats within those networks.  Within riverine floodplain systems, a complex array of
    habitats can develop that express varying degrees of surface and sub-surface water
    connectivity to main channels (Stanford and Ward 1993). In the study area, off-channel
    floodplain habitats can include side channels (both inlet and outlet connections to main
    channel), various types of single-connection habitats including alcoves and percolation
    channels, and pools and ponds with no surface connection to the main channel during
    certain flow conditions (PLP 2011 Appendix 15.ID).  Beaver can be very important
    modifiers and creators of habitat in these off-channel systems (Pollock et al. 2003,
    Resell et al. 2005). As a result of their morphology and variable hydrology, the degree of
    surface-water connectivity and the ability offish to move among floodplain habitats
    changes with surface water levels. Connectivity for fish movement at larger spatial
    scales within watersheds is influenced by barriers to longitudinal movements and
    migrations. Examples include dams and waterfalls.
    
    Efforts to manage or enhance connectivity within aquatic systems have primarily
    focused on watersheds altered by human activities, where land uses and water
    utilization have lead to aquatic habitat fragmentation.  Specific activities to increase
    habitat connectivity within human-dominated stream-wetland systems may include: 1)
    improving access around real or perceived barriers to migration (including dams
    constructed by humans or beaver); 2) removing or retrofitting of road culverts; and 3)
    excavating and engineering of channels to connect isolated wetlands and ponds to main
    channels. Within watersheds minimally impacted by human activity, efforts may include
    creation of passage around barrier waterfalls to expand the availability of habitat for
    species like Pacific salmon. Human-created dams do not offer any opportunities for
    habitat improvement or expansion in the Nushagak or Kvichak River watersheds
    because they are absent, so they are  not discussed further. Since road stream crossing
    retrofits presently offer no opportunities for habitat improvement or expansion within
    the NFK, SFK, and UTC watersheds, but exist elsewhere in the  larger  Nushagak and
    Kvichak River watersheds, they are discussed in Section 3.3.2.3. Here, we focus on
    beaver dam removal and engineered  connections to variably-connected floodplain
    habitats, and habitats upstream of barrier waterfalls.  For each of these measures, the
    potential applicability, suitability, and effectiveness as mitigation tools within the study
    area watersheds are addressed.
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    3.3.1.1.1 Remove Beaver Dams
    
    Two commenters suggested the removal of beaver dams as a potential compensation
    measure. Presumably, the rationale for this recommendation is that beaver dams can
    block fish passage, limiting fish access to otherwise suitable habitat, thus, 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 to protect certain fish populations like trout (Sayler 1934, Reid 1952, in
    Pollock et al. 2004). However, more recent research has documented numerous
    benefits of beaver ponds to fish populations and habitat (Murphy et al. 1989, Pollock et
    al. 2003). 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. Pollock et al. (2004) estimated
    a 61% reduction in summer habitat capacity relative to historical levels, for coho salmon
    in one Washington watershed, largely due to 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 cited, 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).  DeVries et al (2012) describe a stream
    restoration approach that attempts to mimic and facilitate beaver dam creation and the
    numerous positive benefits for stream habitat and riparian enhancement. 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. During winter, beaver ponds typically retain liquid water below the frozen
    surface, providing refugia for species that overwinter in streams and off-channel
    habitats (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 (Rupp 1954, Card 1961, Bryant 1984, Pollock et al. 2003).  Even when
    beaver dams impede fish movements, 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
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    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, including above beaver dams in the study area
    (PLP 2011; Appendix 15.ID). 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).
    
    Beavers preferentially colonize headwater streams, such as those found near the Pebble
    deposit, because of their shallow depths and narrow widths (Collen and Gibson 2001,
    Pollock et al. 2003). An October 2005 aerial survey of active  beaver dams in the mine
    scenarios area mapped a total of 113 active beaver colonies (PLP 2011). The Pebble
    Limited  Partnership's (PLP) Environmental Baseline Document (EBD) highlights the
    significant role that beaver ponds are currently providing for Pacific salmon in this area
    when it states:
    
          "[W]hile beaver ponds were relatively scarce in the mainstem UT
          [UTC], the off-channel habitat study revealed a preponderance of
          beaver ponds in the off-channel habitats. As in the SFK watershed,
          beaver ponds accounted for more than 90 percent of the off-
          channel habitat surveyed. Beaver ponds in the UT provided habitat
          for adult spawning and juvenile overwintering for Pacific salmon.
          The water temperature in beaver ponds in the UT was slightly
          warmer than in other habitat types and thus, beaver ponds may
          represent a  more productive habitat as compared to other
          mainstem channel habitat types" (PLP 2011).
    
    The current body of literature describing the effects of beaver dams on salmonid species
    reports  more positive associations between beaver dam activity and salmonids 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.
    
    3.3.1.1.2 Connect Off-channel Habitats and Habitat Above Impassible Waterfalls
    
    Off-channel habitats can provide important low-velocity rearing habitats for juvenile
    salmon and other native fishes.  Floodplain-complex habitats including beaver ponds,
    side channels, oxbow channels, and alcoves can contribute significantly to juvenile
    salmonid rearing capacity (e.g., Beechie et al. 1994). Such habitats are a common
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    feature of unmodified alluvial river corridors. These habitats may express varying
    degrees of surface-water connectivity to main channels that in unmodified rivers is
    dependent upon streamflow stage and natural channel dynamics. Off-channel habitats
    may become isolated from the main channel during certain streamflow conditions due
    to channel migration or avulsion, and  in highly dynamic channels, connectivity may
    change frequently during bed-mobilizing events (Stanford and Ward 1993). This shifting
    mosaic of depositional and erosional habitats within the floodplain creates a diverse
    hydraulic and geomorphic setting, contributing to biocomplexity (Amoros and Bornette
    2002). In  river systems modified by human activity, isolation or elimination of off-
    channel habitats has had severe impacts on salmon productivity (e.g., Beechie et al.
    1994), and re-connection and re-creation of off-channel habitats are now common tools
    for increasing juvenile salmonid  habitat capacity in those systems (Morley et al. 2005,
    Ronietal. 2006).
    
    Waterfalls or high-gradient stream reaches can prevent mobile fish species from
    accessing  upstream habitats, due to velocity barriers or drops that exceed passage
    capabilities of fish (Reiser et al. 2006).  Waters upstream of barriers may be devoid of all
    fish life, or may contain resident fish species including genetically-distinct populations
    (e.g., Whiteley et al. 2010). Engineered passageways for fish around waterfalls have
    been used to create access to upstream lakes or stream systems for fish such as salmon.
    However,  the response of resident fish species to barrier removal and the colonization
    success of species from downstream habitats may be difficult to predict (Kiffney et al.
    2009). Salmon population responses to a fishway in southeast Alaska  depended on the
    species, and the ecological effects offish passage on the upstream lake system and
    watershed are not fully understood (Bryant et al. 1999). Burger et al.  (2000) provide a
    well-documented history of colonization of sockeye salmon in Frazer Lake, Alaska above
    a historically-impassible waterfall following passage installation and planting of salmon
    eggs, fry, and adults above the barrier. Their study documents how differing donor
    populations, each with different life-history characteristics, contributed differently
    toward the establishment of populations in the  newly accessible habitats (Burger et al.
    2000). This study highlights the  importance of genetics and  life history adaptations of
    source populations to colonization success.
    
    Creating connectivity between parts of the river network that are naturally
    disconnected can have adverse ecological  effects, including impacts to resident
    vertebrate and invertebrate communities, as well as disruptions to ecosystem
    processes. Introduction offish to fish-less areas can lead to  altered predator-prey
    interactions, food web changes,  changes in algal production, nutrient  cycling and meta-
    population dynamics of other vertebrate species (see Section 3.3.2.5). For example,
    previous studies on the introduction of trout species to montane, wilderness lakes have
    shown that introducing fish to fish-less lakes can have substantial impacts to nutrient
    cycles (Knapp et al. 2001). The risk of disruption to the functions of naturally fish-less
    aquatic ecosystems should be fully evaluated before these approaches are used for the
    sole  purpose of creating new fish habitat area.
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    Rosenfeld and co-authors (Rosenfeld et al. 2008, Rosenfeld et al. 2009) conducted a
    variety of experiments and monitoring activities within a re-connected river meander in
    coastal British Columbia to explore the relationship of salmon productivity to habitat
    features. Their work highlights the importance of habitat configuration. In their study,
    spacing of pools (foraging habitats for fish) and riffles (source areas for invertebrate
    prey) was an important factor influencing growth rates of juvenile coho salmon. Given
    the high diversity of channel conditions within floodplain habitats in the project area
    (PLP 2011), it is likely that fish responses to increased connectivity would be highly
    variable.
    
    Rosenfeld et al. (2008) point out the importance of considering the full suite of factors
    that influence habitat capacity and productivity when designing restoration or
    enhancement projects. For instance, 'optimising' habitat structure for one species may
    adversely impact species with differing habitat preferences, as demonstrated by Morley
    et al. (2005) who found differential responses of juvenile steelhead and juvenile coho
    salmon to conditions in constructed and natural off-channel habitats. Predator-prey
    relationships also need to be considered. Increased connectivity of off-channel  habitats
    has been proposed as a strategy for enhancing northern pike production in northern
    Canada (Cott, 2004). How increased connectivity in the project area  would influence
    trophic relationships among northern pike and salmon, trout and char is unknown,
    although introduced northern pike in other areas of Alaska have the  potential to reduce
    local abundances of salmonids via predation (Sepulveda et al. 2013). Bryant et al.
    (1999) in their study of the effects of improved passage at a waterfall concluded that
    the effects on food webs, trophic relationships, and genetics among resident and newly-
    colonizing species were largely unknown. Rosenfeld and co-authors  (2009) emphasize
    the high degree of uncertainty associated with channel design for enhanced fish
    productivity, stating:
    
           "...despite the enormous quantity of research on stream rearing
           salmonids and their  habitat associations, stream ecologists still lack
           a  definitive understanding of the relationship between channel
           structure, prey production and habitat capacity for drift-feeding
           fishes" (Rosenfeld et al. 2009, page 581).
    
    Several commenters proposed that enhanced or increased connectivity of off-channel
    habitats or habitats  above waterfalls could provide fish access to habitat currently
    underutilized or inaccessible.  This comment presumes that  currently disconnected
    habitats would provide suitable mitigation sites.  Based on the above, there are  multiple
    criteria that would have to be met, and numerous assumptions that would have to be
    validated in order for these  sites to qualify as valid mitigation sites.  For such measures
    to succeed, the following conditions would  need to be considered:
              a.   Are currently inaccessible habitats suitable for salmon and other target
                  fish species?
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              b.  Does improved access to habitat address a currently limiting factor or
                 condition?
    
              c.  Can the habitat be effectively connected in a way that enhances
                 productivity?
    
              d.  Will enhanced connectivity be sustainable over the long term (e.g., be
                 maintained despite sediment dynamics or channel adjustments)?
    
              e.  If enhanced connectivity is not self-sustainable, can a feasible monitoring
                 and maintenance plan ensure continued connectivity and effectiveness?
    
              f.  What is the risk that changes to  the hydrology, chemistry, temperature
                 and morphology of the habitat complex associated with the construction
                 of hydrologic connectivity will fundamentally alter the habitat suitability
                 of the site such that it is no longer addressing a habitat need?
    
              g.  Would predators/competitors present within the existing disconnected
                 habitat overwhelm the benefit to target species?
    
              h.  Are fish populations present in isolated habitats (e.g., above impassible
                 waterfalls) genetically distinct or otherwise of special value, and
                 potentially lost if connections to downstream fish populations are
                 enabled?
    
              i.  How would potential adverse ecosystem changes in fish-less isolated
                 habitats (e.g., above impassible  waterfalls) due to fish introductions be
                 evaluated and addressed?
    
    Given the above considerations and examples of the challenges of connectivity
    management, use of fishways at waterfalls and engineered connections to off-channel
    habitats have many unanswered questions for  the project area  streams and wetlands.
    Such approaches would be effectively an "adaptive management experiment"
    (Rosenfeld et al. 2008); requiring careful monitoring and evaluation of alterations within
    an experimental context.
    
    3.3.1.2 Increase Habitat Quality
    
    Addition of large structural elements such as wood and boulders to streams has been a
    common stream habitat rehabilitation approach in locations where stream habitats
    have been extensively simplified by mining, logging and associated timber
    transportation,  or other disturbances (Roni et al. 2008). The goals of large structure
    additions are typically to create increased hydraulic and structural complexity and
    improve local-scale habitat conditions for fish in streams that are otherwise lacking in
    rearing or spawning microhabitats. Properly engineered structural additions to
    channels can increase hydraulic diversity, habitat complexity, and retention of
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    substrates and organic materials in channels, but benefits for aquatic life have been
    difficult to quantify (see review by Palmer et al. 2010). The paucity of demonstrated
    beneficial biotic responses to stream structural enhancements is at odds with
    perceptions by managers whose evaluations tend to be overtly positive - but usually
    based on qualitative opinion rather than scientific observation (Ja'hnig et al. 2011).  In
    addition, improperly sited or engineered structural additions can fail to achieve desired
    effects or have adverse, unanticipated consequences (e.g., via structural failure or scour
    and fill of sensitive non-target habitats (Frissell and Nawa 1992)), highlighting the need
    for appropriate design.
    
    Commenters proposed that quality of stream habitats in the project area could be
    enhanced by increasing habitat complexity through the addition of boulders or large
    wood to existing off-channel habitats. Off-channel  habitats can provide important low-
    velocity rearing habitats for juvenile salmon and other native fishes. Floodplain-
    complex  habitats including beaver ponds, side  channels, oxbow channels, and alcoves
    provide hydraulic diversity that can be important for fish in variable flows (Amoros and
    Bornette 2002, Rosenfeld et al. 2008). Beaver  are a major player in the creation and
    maintenance of these habitats in the study area (PLP  2011, Appendix 15.ID), as has
    been noted elsewhere (Pollock et al. 2003, Resell et al. 2005).  Off-channel habitats also
    provide important foraging environments, and can  be thermally-diverse, offering
    opportunities for thermoregulation or enhanced  bioenergetic efficiency (Giannico and
    Hinch 2003). Off-channel habitats are relatively frequent and locally-abundant in area
    streams and rivers, particularly in lower-gradient, unconstrained valley settings and at
    tributary confluences (e.g., PLP 2011 Figure 15.1-15, cover photo of this assessment).
    PLP's EBD, Appendix 15.ID (PLP 2011) contains an assessment of the natural fluvial
    processes creating and maintaining off-channel habitats, and their quality and quantity
    and function in the study area, including mechanisms of connectivity to the mainstem
    channels. This background information provides very useful information for evaluating
    the potential effectiveness of off-channel habitat modification.
    
    Commenters proposed that off-channel habitats could also be improved by engineered
    modifications to  the depth, shoreline development ratio, and configuration of off-
    channel habitats to create  better overwintering habitat for juvenile salmon.  The degree
    to which  existing habitats could be enhanced to improve survival of juvenile salmon as
    proposed by commenters will  be dependent upon several considerations, including an
    evaluation of factors known to influence the utilization, survival, and growth within
    these habitats. These considerations are discussed below.
    
    Off-channel habitats surveyed by PLP and other investigators reveal that patterns of
    occupancy and density are high but variable among off-channel habitats (PLP 2011,
    Appendix 15.ID). Some of the highest densities observed were within off-channel
    habitats such as side channels and alcoves, but even some 'isolated' pools held fish (PLP
    2011, Appendix 15.ID). This variability could reflect variation in suitability, access, or
    other characteristics of individual off-channel habitats.  Juvenile salmonids require a
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    diverse suite of resources to meet habitat requirements - cover and visual isolation
    provided by habitat complexity is one such resource, but other critical resources include
    food, space, and suitable temperatures and water chemistry (Quinn 2005).  Habitat
    configuration within constructed side-channel habitats can also strongly influence
    density, size and growth of juvenile salmonids (Rosenfeld and Raeburn 2009). Giannico
    and Hinch (2003) in experimental treatments in side channels in British Columbia, found
    that wood additions were beneficial to coho salmon growth and survival in surface-
    water fed side channels, but not  in groundwater-fed channels. They attributed this
    effect to differences in foraging strategy and bioenergetics of the juvenile coho salmon
    overwintering in the channels. Additions of wood had no effect, or even possibly a
    detrimental effect, on coho salmon survival in groundwater-fed side channels. These
    findings highlight the importance of understanding the ecology, bioenergetics, and
    behavior of the species and life histories present within habitats that may be quite
    diverse with regard to hydrology and geomorphology.
    
    It is not clear from current data that adding complexity would address any limiting
    factor within existing off-channel habitats, or that additions of boulders and wood
    would enhance salmonid abundance or survival. Placement of structures (e.g.,
    boulders, large wood) within stream channels should also be guided by careful
    consideration of potential adverse consequences, including unanticipated shifts in
    hydraulic conditions that lead to  bank erosion or loss of other desirable habitat features.
    Sustainability of off-channel habitat modifications is also in question. As stated  in the
    EBD, off-channel habitats are a product of a dynamic floodplain environment and "..are
    continually being created and destroyed"  (PLP 2011; Appendix 15.ID; page 2).
    Maintenance  of engineered structures or altered morphologies of such habitats over the
    long term would be a challenging task.  Observations from the EBD  suggest that beaver
    are already providing desired complexity;  to quote, "..habitat mapping from this off-
    channel study shows that the beaver ponds contain extensive and diverse habitats and
    dominate the active valley floor." And, "...these off-channel habitats provide a critical
    habitat component of freshwater rearing of coho salmon, and to a lesser extent, other
    anadromous and resident species." (PLP 2011, Appendix 15.ID page 14).
    
    3.3.1.3 Increase Habitat Quantity
    
    The creation of spawning channels and  off-channel habitats has been proposed  as a
    means to compensate for lost salmon spawning and rearing 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). Off-channel habitats may be enlarged
    or modified to alter habitat conditions and capacities for rearing juvenile salmonids.
    Examples include the many spawning channels (Bonnell 1991) and off-channel habitats
    (Cooperman 2006) enhanced or created in British Columbia and off-channel ponds
    rehabilitated by the City of Seattle (Hall and Wissmar 2004).
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    Off-channel spawning and rearing habitats can be advantageous to salmon populations
    by providing diverse hydraulic and habitat characteristics. Redds constructed in these
    habitats may be less susceptible to scour compared to main channel habitats due to
    flow stability provided by their hyporheic or groundwater sources (Hall and Wissmar
    2004). Moderated thermal regimes can provide benefits for growth and survival for
    overwintering juveniles (Giannico and Hinch 2003). Morley et al. (2005) compared 11
    constructed off-channel habitats to  naturally-occurring paired reference side channels
    and found that both natural and constructed off-channel habitats supported high
    densities of juvenile salmonids in both winter and summer. Although numerous studies
    have documented short-term or localized benefits of constructed off-channel habitats,
    ascertaining population-level effects is much more difficult. Any additional fry produced
    by spawning channels (if successful) would require additional suitable habitat for
    juvenile rearing and subsequent life stages in order to have a net positive effect on
    populations. Hilborn (1992) indicates that success, measured by increased production
    of adult fish from such channels, is unpredictable and generally unmonitored. A notable
    exception is the study by Sheng et al. (1990), which documented 2- to 8-fold increases in
    recruitment of coho spawner production from groundwater-fed off-channel habitats.
    Sheng et al. (1990) stated that effectiveness would be greatest in systems which
    currently lack adequate overwinter  refuges. As with any rehabilitation strategy,
    population responses will be dependent upon whether factors actually limiting
    production are addressed.  As stated elsewhere in this assessment, additional research
    and monitoring is  required  to quantify factors currently limiting production within
    project area  watersheds.
    
    Replacing destroyed salmon habitats with new constructed channels is not a simple
    task.  Factors for consideration in designing and implementing off-channel habitat
    development are outlined in Lister and Finnigan (1997), and include evaluation of
    species and life stages present, current habitat conditions, and factors limiting capacity
    or productivity (Roni et al. 2008). Research indicates that channels fed by hyporheic
    flow or groundwater may be most effective for creating suitable spawning and  rearing
    habitats (Lister and Finnigan 1997).  Near-stream excavation and compaction associated
    with channel construction can alter groundwater flowpaths, so designing projects to
    protect current function and groundwater connectivity is very important.
    
    Numerous researchers have emphasized that replacing lost habitats is not merely a
    process of providing habitat structure (Lake et al. 2007).  Effective replacement of
    function also requires establishment of appropriate food web structure and productivity
    to support the  food supply for fish - in essence, an entire ecosystem, including all full
    suite of organisms such as  bacteria, algae, and invertebrates - needs to be in place in
    order for a constructed channel to begin to perform some of the same functions of a
    destroyed stream  (Palmer et al. 2010).  Quigley and Harper (2006b), in a review of
    stream rehabilitation projects, concluded "the ability to replicate ecosystem function is
    clearly limited."
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    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
    provide additional spawning habitat and produce more fry, which would presumably
    result in more adult fish returning (Hilborn 1992). Off-channel rearing habitats have
    also been used to create additional overwintering habitats in Pacific Northwest rivers
    (Roni et al. 2006), and spawning channels have also been shown to provide suitable
    overwintering habitats for juvenile coho salmon (Sheng et al. 1990). However, there are
    very few studies regarding the efficacy of such channels at enhancing adult salmon
    recruitment in the published literature. Constructed spawning channels, particularly
    those dependent upon surface flow, may also require annual maintenance and cleaning
    (Hilborn 1992), 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)). Off-
    channel habitats to mainstems are also extremely difficult to engineer in a way that can
    self-sustain in the face of a dynamic fluvial environment. Alluvial channels frequently
    shift (Amoros and Bornette 2002), and beaver are highly effective ecosystem engineers
    whose activities are constantly re-arranging floodplain channels and creating new dams
    (Pollock et al. 2003) - including within engineered channels and culverts (Cooperman
    2006).
    
    In light of their uncertain track record, it does not appear that constructed spawning
    channels and engineered connections of off-channel habitats would provide reliable and
    sustainable fish habitat in the Bristol Bay region.
    
    3.3.1.4 Manage Water Quantity
    
    Two commenters suggested a variety of techniques to manipulate water quantities
    within the NFK, SFK and UTC watersheds to improve fish productivity.  Possible
    techniques for accomplishing this include: flow management, flow augmentation, and
    flow pump-back.
    
    3.3.1.4.1 Direct Excess On-site Water
    
    Commenters 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 to maintain or enhance flow and/or
    thermal regimes in the receiving streams. Delivering such flows via groundwater (i.e.,
    by using wastewater treatment plant (WWTP) discharges to "recharge and surcharge
    groundwater aquifers") was identified as a preferred approach; commenters argued
    doing so would both render the measure less prone to operational anomalies at the
    WWTP and better mimic current natural flow patterns, thereby attenuating potential
    adverse effects related to discharge volume and temperature. Ideally, flow,
    temperature, and habitat modeling would inform the design and operation of flow
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    management to optimize species and habitat benefits by, for example providing water
    at specific times to locations where low flow currently limits fish productivity.
    
    Manipulation of surface flows at another mine in Alaska—Red  Dog, in the northwest
    part of the state—has resulted in an increase in fish (Arctic grayling and Dolly Varden)
    use of the downstream creek (Scannell 2005, Ott 2004).  The circumstances at Red Dog,
    however, differ from those in the NFK, SFK, and UTC area. As described in Scannell
    (2005), the near complete absence of fish in Red Dog Creek prior to implementation of
    the water management techniques was the direct result of water quality, not quantity,
    as the stream periodically experienced toxic levels of metals that occurred naturally as it
    flowed through and downslope of the exposed ore body. Furthermore, the Red Dog
    water management system primarily involves point-to-point diversion or transfer of
    surface, rather than groundwater, both around the ore body and from tributaries
    upstream of the mine.  We have been unable to locate any documentation of successful
    attempts to manage flow volume or temperature from mine sites (or other industrial
    developments), via groundwater, for the  benefit of fish and/or fish habitat.
    
    Given that most streams in the area  support multiple salmonid species and life stages,
    with differing habitat needs at  different times, designing and managing a water delivery
    system to overcome limiting factors for one or more species without  adversely
    impacting others would be a significant challenge. Given the complexity of the surface-
    groundwater connectivity in the area, ensuring that discharges to groundwater actually
    reached the target habitat at the intended time would, perhaps, be the most difficult
    task. Quigley and Harper (2006b), in a review of stream rehabilitation projects,
    concluded "the ability to replicate ecosystem function is clearly limited."
    
    This challenge could potentially be easier to overcome where habitat limitations
    occurred only as a result of mine development, assuming pre-project modeling and
    verification accurately identified groundwater flow paths to those areas. It is important
    to note, however, that even if such actions appeared to be feasible, they likely would be
    required to avoid or minimize the adverse impacts of flow reduction due to mine
    development, rather than to compensate for unavoidable habitat losses.
    
    If it were an overall enhancement to pre-existing habitat, using WWTP discharges to
    groundwater to address natural limitation factors could be a form of compensatory
    mitigation.  For example, PLP (2011) points out that productivity may be limited by the
    existence of "losing" reaches along the SFK mainstem and intermittent or ephemeral
    tributaries to both the SFK and NFK.  Altering the natural flow regimes at such sites,
    however, could have unintended consequences on the local ecosystem and species
    assemblages (Poff et al. 1997).  Moreover, "enhancing" these habitats through a WWTP-
    sourced groundwater flow delivery system would be even more challenging than
    managing flow to avoid or minimize  impacts to already productive habitat, because it
    would require "improving" the natural flow delivery system that currently results  in the
    periodic drying/low flows. We have not located any documented successful application
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    of this technique, making it a highly experimental approach to enhancing fish
    productivity, particularly in a natural stream system.  Highly experimental and
    unpredictable activities are generally discouraged as compensatory mitigation (40 CFR
    230.93(a)(l); see also 73 FR 19633).  The regulations also strongly discourage
    compensatory mitigation projects that require the long-term use of active engineering
    features (40 CFR 230.97(b)).
    
    3.3.1.4.2 Augment Flows
    
    Another means suggested for maintaining or increasing habitat productivity
    downstream of the mine site is to increase flow volume into certain streams by creating
    new sources of surface flow and/or groundwater recharge, specifically, from
    impoundments and/or ice fields. We are unaware of any documented successful efforts
    to create impoundments or ice fields for the benefit of salmonids.  As described in the
    previous section, actions to maintain or reestablish pre-mine flow in streams likely
    would be required as avoidance or minimization measures, and would not constitute
    compensatory mitigation for unavoidable impacts.
    
    Only if it were an overall enhancement to existing habitat would creating
    impoundments and/or ice fields have the potential for offsetting unavoidable adverse
    impacts. Thus, the objective would be to target stream reaches where flow-habitat
    modeling indicated opportunities for enhancement.
    
    PLP's EBD notes that a portion of the SFK mainstem, as well as some Koktuli River
    tributaries,  exhibit either intermittent or ephemeral flow that appears to be a limiting
    factor for salmonid productivity (PLP 2011).  However, two of the tributaries are in the
    uppermost  reaches of the SFK and would be eliminated by the mine scenarios.
    
    Although there are potential locations for impoundments to manage flow in the stream
    reaches identified  as having "sub-optimal" flow,  logistical and environmental issues
    decrease the likely efficacy and sustainability of such an approach. Manipulating
    streamflows in particular watersheds would require diverting water from other basins
    or capturing water during  peak flows for subsequent release  at other times, with the
    concomitant engineering,  construction, and  maintenance challenges. Doing so would
    create additional adverse impacts from the construction of infrastructure and would be
    subject to modeling and perpetual management sufficient to ensure that water
    withdrawals from the "donor" watershed or from other times of the year would not
    adversely impact fish habitat and populations in  its downstream waters. These
    concerns are in addition to those commonly associated with impoundments, such as
    alteration of flow,  thermal, and sediment transport regimes.
    
    Creating ice fields to increase the total volume of water available to a stream would also
    require water diversion, with the same challenges and concerns related to building and
    maintaining system infrastructure and reducing water volumes in the source watershed.
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    Using ice fields to change the timing of water availability would encounter issues related
    to managing the melt to produce stream flow at the intended time (i.e., late summer or
    late winter low-flow periods).  Moreover, since aquatic organisms supported by a
    particular water body typically have evolved specific life history, behavioral, and
    morphological traits consistent with the characteristics of that water body's natural flow
    regime, local populations are inherently vulnerable to flow modification (Lytle and Poff
    2004). Any use of ice fields would face the potentially substantial challenges of the
    effects of climate change on ice production and preservation. Besides requiring active
    management in perpetuity, ice field creation for flow augmentation would be decidedly
    experimental, with high uncertainty regarding the likelihood of success. Flow
    augmentation techniques would also be inconsistent with the regulation's provision that
    "[c]ompensatory mitigation projects shall be designed, to the maximum extent
    practicable, to be self-sustaining once performance standards have been achieved. This
    includes minimization of active engineering features..." (40 CFR 230.97(b)).
    
    3.3.1.4.3 Pump Water Upstream
    
    Another option suggested for making flow  in some stream reaches more persistent is to
    pump groundwater or surface water from a down-gradient site upstream to either a
    direct release point or a recharge area. This technique has been used for fish habitat
    restoration at sites in the continental U.S. (e.g., the Umatilla River, OR (Bronson and
    Duke 2005), the Lower Owens River, CA (LADWP 2013), and Muddy Creek, CO (AECOM
    et al. 2010 and GrandRiver Consulting 2008)), although we are unaware of any
    documentation addressing its efficacy in  increasing salmonid productivity. As with flow
    management and augmentation, using this technique to offset flow reductions from
    mine operations would not be compensatory mitigation, limiting its potential use as
    such to reaches that already have sub-optimal flow. One such stream is NFK 1.190.10, a
    tributary that enters NFK 1.190 downstream of the tailings storage facility location.
    Flow modeling, however, indicates that mine development would diminish flow in that
    stream even further (see Figures 7-15 through 7-17 of the assessment).
    
    For the periodically intermittent or ephemeral reaches identified in the EBD, potential
    source sites presumably would be in or along the lower reaches of the NFK or SFK,
    downstream of the mine, waste rock, and tailings storage facilities.  Flow modeling
    indicates that the NFK would experience  a  decrease in flow  under the Pebble 6.5
    scenario (see Figure 7-17 of the assessment), increasing the possibility that withdrawing
    additional water from the system to pump  back upstream either would not be possible
    or would have adverse downstream impacts. Extensive modeling would be necessary to
    assess downstream effects in either watershed.
    
    Even with sufficient downstream water, this technique would require substantial
    disturbance associated with the construction of tens of kilometers of water pipeline,
    power infrastructure, and access, along with maintenance of those facilities in
    perpetuity. It would also entail active management to ensure that releases occur at
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    appropriate times, to increase the persistence of flow in target streams without
    otherwise adversely impacting their hydrographs or habitat.  Such management would
    be another aspect of the approach that would be perpetual.  In total, this technique
    would involve a great deal of uncertainty with regard to both efficacy and sustainability,
    making it a questionable mechanism for providing compensatory mitigation. This
    technique would also be inconsistent with the regulation's provision that
    "[c]ompensatory mitigation projects shall be designed, to the maximum extent
    practicable, to be self-sustaining once performance standards have been achieved. This
    includes minimization of active engineering features (e.g., pumps) and appropriate siting
    to ensure that natural hydrology and landscape context will support long-term
    sustainability" (40 CFR 230.97(b)).
    
    3.3.1.5 Manipulate Water Quality
    
    Two commenters suggested that alteration of stream water chemistry would improve
    fish production in the NFK,  SFK and UTC. They suggest increasing two groups of water
    chemistry parameters: basic parameters such  as alkalinity, hardness, and total dissolved
    solids, and nutrients such as nitrogen (N) and phosphorous (P). This argument suggests
    that low concentrations of  basic parameters and/or nutrients limit the production of
    algae, which limits aquatic  macroinvertebrate production and habitat complexity. This
    in turn can reduce overall fish production, reduce individual fish growth rates, or result
    in fish movements away from low production areas.
    
    3.3.1.5.1 Increase Levels of Alkalinity, Hardness, and Total Dissolved Solids
    
    Commenters propose that altering stream water chemistry to increase levels of
    alkalinity,  hardness, and total dissolved solids would improve the buffering capacity,
    primary productivity, secondary productivity, and reduce the potential toxicity of metals
    at waters downstream of these altered locations. Commenters suggest two
    mechanisms to achieve these improvements:  1) the addition of limestone in some form
    at "appropriate"  locations or 2) the discharge of higher alkalinity water into fish-
    producing streams through a water  management program. Commenters argue that
    current levels of alkalinity, hardness, and total dissolved solids in the NFK, SFK and UTC
    are suboptimal for fish production and could be  manipulated to improve fish
    production.  However, the majority of the literature relating to alkalinity and limestone
    management, including every published study cited by commenters, evaluates these
    approaches in streams and lakes in northern Europe, eastern U.S., or eastern Canada
    whose fisheries have been  heavily impacted by acid mine drainage, acid deposition or
    other mechanisms of acidification and even in these degraded water bodies,
    alkalinity/limestone treatment results were variable (Gunn and Keller 1984, Hasselrot
    and Hultberg 1984, Rosseland and Skogheim 1984, Zurbuch 1984, Gagen et al. 1989,
    Lacroix 1992, Clayton et al. 1998, McClurg et al. 2007).  It is not clear from any of the
    published  studies cited by commenters what effect the addition of limestome or higher
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    alkalinity water would have on the kinds of unaltered stream systems and fishery
    resources found in the Bristol Bay region of Alaska.
    
    Alkalinity has two potential roles. First, it is a measure of the ability of water to
    neutralize acids.  If the intent is to neutralize acid rock drainage from the potential mine,
    that use constitutes impact minimization or remediation, not compensation. Second,
    alkalinity is primarily due to carbonate and bicarbonate, which is the source of carbon
    used by aquatic algae so increasing alkalinity is potentially fertilization.  However, given
    that the streams at the site are relatively shallow and rapidly flowing, it is very unlikely
    that they are carbon limited.  Therefore, it is unlikely that increasing alkalinity would
    increase algal production unless it is neutralizing acids from a mine.
    
    Similar considerations apply to increasing hardness.  Aqueous hardness is due to calcium
    and magnesium, which reduce the toxicity of divalent metals such as copper by
    competing for uptake sites. Increasing hardness would be a  potential means of
    remediating the effects of high  metal levels drainage from mine waste leachate into
    streams.  Alternatively, calcium and magnesium are  nutrient elements and
    hypothetically could be limiting production.  However, the commenters produce no
    evidence that such limitations are occurring, and it is less credible than the potential N
    and P limitations discussed in the next section.
    
    Manipulating water chemistry could have a deleterious effect on salmon populations. A
    key characteristic of Pacific salmon is their homing migrations from oceanic feeding
    grounds, through diverse habitats, to their natal river to spawn.  Homing is generally
    precise and has resulted in reproductively isolated spawning populations with
    specialized  adaptations for their natal habitat. (Wisby and Hasler 1954, Hasler and
    Scholz 1983, Quinn and Dittman 1992, Dittman et al. 1995, Dittman and Quinn 1996).
    Olfactory systems of salmon are acutely sensitive to  changes in water chemistry
    (Mclntyre et al. 2012). Physiological and behavioral  experiments demonstrate that
    calcium is an important odorant enabling salmon to  recognize individual waters and that
    sockeye salmon olfactory systems are acutely sensitive to calcium ions (Bodznik 1978).
    This would suggest that manipulating stream chemistry through the addition of
    limestone or higher alkalinity water could impede salmon from recognizing and homing
    to their natal streams. Some commenters who raised concerns about manipulating
    stream chemistry through these approaches point out that homing failure could reduce
    productivity if salmon die without spawning or stray to non-natal habitats to which they
    are poorly adapted and experience higher mortality.
    
    We are not aware of any published studies describing projects where the chemistry of
    unaltered/un-degraded salmon streams in Alaska or elsewhere has been manipulated
    through the addition of limestone or higher alkalinity water to achieve improvements in
    buffering capacity against natural acidity, increase primary or secondary productivity, or
    reduce toxicity to naturally occurring metals. Rather, the scientific literature suggests
    that such chemical alterations could result in deleterious effects on salmon in
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    unaltered/un-degraded stream systems. Manipulating stream chemistry in the NFK, SFK
    and UTC through the addition of limestone or higher alkalinity water would be a
    challenging and difficult experiment with an unknown outcome.
    
    3.3.1.5.2 Increase Levels of Nitrogen and/or Phosphorus
    
    The same two commenters suggest altering stream water chemistry to increase levels of
    N and P where they are individually or co-limiting. They provide four categories of
    considerations for determining how to increase stream or lake nutrients:
       1)  The spatial and temporal distribution of the limiting nutrients,
       2)  The timing and duration of nutrient application(s),
       3)  The desired concentrations of each nutrient and the ratio between N and P for
           each application location, and
       4)  The need for detailed pre-project information including the biological species
           composition of the waterbody and a low level nutrient analysis.
    
    The commenters make a few general recommendations about how to consider these
    factors when developing mitigation in the NFK, SFK and UTC.  They suggest that the
    spatial distribution could focus on existing or newly created side channels, sloughs,
    beaver ponds, alcoves, or, if necessary, the main channels at 10 km intervals.  They
    suggest several possible temporal distribution options; of adding the nutrients only
    during the growing season, potentially earlier, or all winter in open water locations
    where biological production continues year round. They further indicate that the key
    considerations are access cost and maintenance requirements.  The commenters note
    several types of nutrient delivery methods: liquid fertilizer, slow-release fertilizer, and
    nutrient analogs (which are essentially slow-release pellets of processed fish).
    
    As support for their conclusion that lake and stream fertilization represent
    "demonstrably successful mitigation techniques" for the NFK, SFK and UTC, the
    commenters cite a  number of papers summarizing experiments and case studies, as well
    as references to several management programs in the U.S., Canada, and northern
    Europe. These studies have examined the use of increased  levels of N and P, or fish
    carcasses, to improve ecosystem productivity and/or fish production.
    
    The two commenters argue that current levels of N and P in the NFK, SFK and UTC are
    suboptimal for fish production stating that benefits of fertilizing oligotrophic waters to
    stimulate fish production have been demonstrated in many venues. Although
    numerous studies show an effect at one or more trophic levels in response to
    fertilization, these studies are insufficient for drawing conclusions regarding the long-
    term effectiveness of nutrient application to streams in the NFK, SFK and UTC
    watersheds because they lack scientific controls or have not been replicated, do  not
    account for potential confounding factors, were conducted  in very different ecosystems,
    and/or only evaluated short-term effects. These differences are pointed out in the
    following paragraphs.
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    Commenters provided examples of experiments and studies aimed at increasing primary
    productivity and theoretically salmon productivity.  These studies assume that nutrients
    are the limiting factor preventing increased salmon productivity, but that is not
    necessarily the case.  Paleolimnetic studies in Alaska indicate nutrient inputs are not
    always tied to higher primary productivity or salmon productivity (Chen et al 2011).
    Wipfli and Baxter (2010) found that most fish consume food from external or very
    distant sources, including from marine systems borne by adult salmon, from fishless
    headwaters that transport prey to  downstream fish, and from  riparian vegetation and
    associated habitats. An increase in food via nutrients may not overcome other limiting
    factors such as habitat availability or interspecies competition.
    
    Most studies on stream and lake fertilization to increase productivity are short-term in
    duration and conducted in ecosystems with important differences from Bristol Bay (e.g.
    Perrin et al. 1987, Raastad et al. 1993, Wipfli et al. 1998, Slaney et al. 2003). For
    example, studies conducted at the Keogh and Salmon Rivers (Ward et al. 2003, Slaney et
    al. 2003) examined the effect of nutrient supplement in the form of salmon carcasses
    and inorganic N and P, respectively, in two coastal river systems for a period of three
    years. A spike in productivity has been seen in a number of these studies, but long term
    studies call into question whether the trend will be  sustained over longer periods as is
    described in the following two long-term studies.
    
    Results from the longest running study on stream fertilization raise concerns about
    using fertilization other than as an  interim restorative measure. Slavik et al (2004)
    found that persistent increased levels of N and P can result in dramatic ecosystem shifts.
    This long term ecological research on the North Slope of Alaska examined the effect of P
    input into P-limited streams, finding an increase in production  for some species at all
    trophic levels over the first few years. However, starting at seven or eight years,
    nutrient enrichment caused a dramatic rise in moss (photos A and B) that changed
    ecosystem structure. Despite higher insect biomass in the fertilized area during this
    period, the growth of fish was no longer significantly greater than in the reference area
    (Slavik et al. 2004). The resulting decrease in fish productivity was thought to result
    from the effects of moss on preferred insect prey. Following cessation of nutrient
    enrichment, it took eight years of recovery to approach reference levels, after storms
    had scoured most remnant moss in the recovering reach. These results demonstrate
    that even at low concentrations, sustained nutrient enrichment can have "dramatic and
    persistent consequences" (Benstead et al. 2007).
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    Photos showing the difference in bottom coverage between the diatom state (Photo A,
    left) and the fertilized moss state (Photo B, right). Used with permission (Slavik et al.).
    
    In another study, long-term nutrient enrichment produced an unanticipated trophic
    decoupling whereby enrichment continued to stimulate primary consumer production
    without a similar increase in predator fish. The majority of the increased ecosystem
    productivity was confined to lower trophic levels because the long-term enrichment
    primarily stimulated primary consumers that were relatively resistant to predation.
    Based on these results, the authors concluded that "even in ecosystems where energy
    flow is predicted to be relatively efficient, nutrient enrichment may still increase the
    production of non-target taxa  (e.g. predator or grazer resistant prey), decrease the
    production of higher trophic levels, or lead to unintended consequences that  may
    compromise the productivity of freshwater ecosystems" (Davis et al. 2010 p 124).
    
    These unanticipated results raise important questions about the potential consequences
    of long-term nutrient supplementations. They also underscore the unpredictability of
    nutrient additions on the food web, and the greater likelihood of unintended
    consequences as the effects ripple through complex interactions  between species.
    These implications are especially relevant considerations for potential long-term
    mitigation that would be necessary in the NFK, SFK and UTC. If long-term nutrient
    addition were to cause an ecosystem shift at lower trophic levels in the NFK, SFK and
    UTC, effects on higher trophic  levels including the productivity of salmon and  other
    target fish species are unknown.
    
    Studies examining the relationship between salmon carcasses and productivity at
    various trophic levels are another active area of investigation. Some research provides
    evidence that carcasses are superior to inorganic nutrient amendments for sustaining
    and restoring stream productivity, including fish production, potentially because
    inorganic nutrients lack biochemicals and macromolecules that are utilized directly by
    consumers (Wipfli et al. 2010,  Martin et al. 2010, Heintz et al. 2010).  Others have found
    the effects of carcasses can be transient, localized, and variable with no increase in fish
    growth (Cram et al. 2011).  Few studies have documented the long-term impacts of
    carcass addition, and there are many remaining gaps in understanding the efficacy of
    this method of potentially improving salmon productivity.  In addition, a number of
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    authors express concern about the potential for the spread of toxins and pathogens
    when carcasses are used as the supplemental  nutrient source (Compton et al. 2006).
    
    Setting aside questions of scientific efficacy and applicability, there are numerous
    practical challenges inherent in nutrient addition as a  potential mitigation method.
    Conducting a long-term management protocol in remote waterways subject to extreme
    weather changes necessarily requires careful monitoring of water chemistry and precise
    application of nutrients, which calls into question the  sustainability of altering stream
    water chemistry to improve the fish production.
    
    Authors of many of these studies state that the application of their results are relevant
    and appropriate for salmonid restoration in streams or lakes with depressed numbers
    (Larkin and Slaney 2011).  The authors do not describe their results as informing
    methods to manipulate existing unaltered wild systems to further augment salmon
    production. Although the commenters draw heavily from Ashley and Stockner (2003),
    the authors of that study actually state:
    
        "The goal of stream and lake enrichment is to rebuild salmonid escapement
        to historical levels via temporary supplementations of limiting nutrients
        using organic and/or inorganic formulations.  Stream and lake enrichment
        should not be used as a 'techno-fix' to perpetuate the existing
        mismanagement of salmonids when there is any possibility of re-
        establishing self-sustaining wild populations through harvest reductions and
        restoration of salmonid habitat. Therefore, fertilization should be viewed as
        an interim restorative measure that is  most effective if all components of
        ecosystem recovery and key external factors (e.g. overfishing) are
        cooperatively achieved and coordinated.  This paper reviews some of the
        technical and more applied aspects of stream, river, and lake enrichment as
        currently practiced in British Columbia and elsewhere. As a caveat, the
        discussion assumes that salmonid stock status of  candidate lakes and
        streams has been quantified and classified as significantly depressed and
        that additional limiting factors (e.g. habitat/water quality and quantity) have
        been addressed and/or incorporated into an integrated basin or lake
        restoration plan."  (Ashley and Stockner 2003 p. 246)
    
    There are  still many gaps in understanding the role of nutrients in fish productivity, so
    there is a great deal we do not know about whether nutrient addition can be a
    successful method to increase fish productivity. At this time there are no scientific
    studies showing how an increase in nutrients resulting in increase salmon productivity
    can be reliably achieved on a long-term basis in the NFK, SFK and UTC watersheds or the
    larger Bristol Bay ecosystem without risk to the region's existing robust populations.
    Just as for the addition of  non-nutrients such as limestone, manipulating stream
    chemistry in this largely unaltered ecosystem through the addition of N and P would be
    a challenging and difficult  experiment with many negative outcomes possible.
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    3.3.1.6 Preserve Aquatic Resources
    
    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 scenarios 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 loss.
    
    3.3.2 Other Opportunities within the Nushagak and Kvichak River Watersheds
    
    As noted above, if practicable or appropriate opportunities to provide compensation
    within the NFK, SFK or UTC watersheds are non-existent or limited, it may be
    appropriate to explore options in adjoining watersheds. For example, 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.
    
    Here we discuss specific suggestions for other potential compensation measures within
    the Nushagak and Kvichak River watersheds that were provided in the public and peer
    review comments on the Bristol  Bay Assessment.
    
    3.3.2.1 Remediate Old Mine Sites
    
    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 or Scynneva 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 under the assessment mine scenarios. 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
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    would be necessary before they could serve as compensatory mitigation sites for other
    projects.
    
    3.3.2.2 Remove Roads
    
    Another potential type of restoration within the Nushagak and Kvichak River watersheds
    is the removal of existing or abandoned roads.  As described in detail in Appendix G of
    the assessment, 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
    groundwater flow; 3)  channelization or structural simplification of streams and
    hydrologic connectivity; 4) persistent changes in the chemical composition of water and
    soil 5) disruption of movements of animals, including fishes and other freshwater
    species; 6) aerial transport of pollutants via road dust; and 7) disruption of near-surface
    groundwater processes, including interception or re-routing of hyporheic flows, and
    conversion of subsurface slope groundwater to surface flows (Darnell et al. 1976,
    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 of the assessment highlights, the Nushagak and Kvichak River watersheds
    are almost entirely  roadless areas (see Figure 1 of Appendix G). 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.
    
    3.3.2.3 Retrofit Road  Stream Crossings
    
    Another potential type of enhancement within the Nushagak and Kvichak River
    watersheds 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). Blockage or inhibition offish passage is a well-documented
    problem commonly associated with declines in  salmon and other fish  populations in
    many regions of the U.S. (Nehlsen et al. 1991, Bates et al. 2003), including Alaska (ADFG
    2012b).
    
    Removing and replacing 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
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    benefits necessary to offset the magnitude of impacts associated with the mine
    scenarios 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 offish passage at those stream crossings (e.g., through the terms or
    conditions of a Section 404 permit that authorized the crossing).
    
    3.3.2.4 Construct Hatcheries
    
    One commenter  referenced the potential use of hatcheries as a compensation measure.
    Such a proposal could 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
           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 Araki et al. (2008), a
    review of 14 studies 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 wild, local fish spawned and reared in hatcheries.
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    Hatchery fish can also compete directly for food and resources with wild salmon
    populations in both freshwater and marine environments (Rand et al. 2012a).
    Ruggerone et al. (2012) examined the effect that Asian hatchery chum salmon have had
    on wild chum salmon in Norton Sound, Alaska since the early 1980s. 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 prey 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 would appear to pose greater ecological risks than
    benefits to this unique and valuable wild salmon population.
    
    3.3.2.5 Stock Fish
    
    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 for the  Bristol Bay region. 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 adverse impacts of such
    management decisions. Fish stocking throughout western North America and
    worldwide has impacted other fish (Knapp et al. 2001, Townsend 2003), nutrient cycling
    (Schindler et al. 2001, Eby et al. 2006, Johnson et al. 2010), primary production
    (Townsend 2003, Cucherousset and Olden 2011), aquatic macroinvertebrates (Dunham
    et al. 2004,  Pope et al.  2009 Cucherousset and Olden 2011), amphibians (Pilliod and
    Peterson  2001, Finlay and Vredenberg 2007), and terrestrial species (Epanchin et al.
    2010). Although 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.
    
    3.4 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
    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
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    conducting permittee-responsible compensatory mitigation projects (40 CFR 230.92).
    One commenter also suggested reducing commercial fishery harvests to compensate for
    fish losses due to large-scale mining; however, such a measure would also be
    inconsistent with the definition of compensatory mitigation (40 CFR 230.92).
    
    4.  Effectiveness of Compensation Measures at Offsetting Impacts to
        Salmonids
    
    In North America, 73% of fish extinctions are linked to habitat alterations (Miller et al.
    1989). Although extensive efforts have been undertaken to create or improve salmon
    habitat and prevent losses to fisheries, the current status of U.S. salmon is a sobering
    testament to the billions spent on mitigation efforts given that all U.S. Atlantic salmon
    populations are endangered (NOAA 2013), 40% of Pacific salmon in the Lower 48 are
    extirpated from historic habitats (NRC 1996), and one third of remaining populations are
    threatened or endangered with extinction (Nehlsen et al. 1991, Slaney et al. 1996,
    Gustafson et al. 2007). Approximately one third of sockeye salmon population diversity
    is considered endangered  or extinct (Rand et al. 2012b), and Bristol Bay sockeye salmon
    likely represent the most abundant diverse sockeye salmon populations left in the U.S.
    
    Since 1990, a billion dollars has been spent annually in the  U.S. on stream and
    watershed  restoration (Bernhardt et al. 2005) and  more than 60% of the projects
    completed during this period were associated with salmon and trout habitat restoration
    efforts in the Pacific Northwest and California (Katz et al. 2007).  Despite the
    proliferation of projects and the significant funds being expended on these efforts,
    debate continues over the effectiveness of various fish habitat restoration techniques
    and the cumulative impact of multiple, poorly coordinated restoration actions at a
    watershed or regional scale (Reeves et al. 1991, Chapman 1996, Roni et al. 2002,
    Kondolf et al. 2008). Further, independent evaluations of the effectiveness of fish
    habitat compensation projects are rare (Harper and Quigley 2005b, Quigley and Harper
    2006a, Quigley and Harper 2006b), and consequently the long-term success rates and
    efficacy of such projects are not well known (DFO 1997, Lister and Bengeyfield 1998,
    Lange et al. 2001, Quigley  and Harper 2006a).  A recent study by Roni et al. (2010)
    clearly questions the efficacy of mitigation to specifically offset salmon  losses.
    
    The most comprehensive investigation, to date, of the efficacy of fish habitat mitigation
    measures was conducted by the Department of Fisheries and Oceans, Environment
    Canada (Harper and Quigley 2005a, Harper and Quigley 2005b, Quigley and Harper
    2006a, Quigley and Harper 2006b). Quigley and Harper (2006a) showed that 67% of
    compensation projects resulted in net losses to fish habitat and only 2% resulted in no
    net loss, whereas only 31% achieved a net gain in habitat area.  Quigley and Harper
    (2006a) concluded that habitat compensation in Canada was, at best, only slowing the
    rate offish habitat loss. Quigley and Harper (2006b) showed that 63% of projects
    resulted in net losses to aquatic habitat productivity and only 25% achieved no net loss,
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    whereas only 12% provided net gains in aquatic habitat productivity. Quigley and
    Harper (2006b) concluded "the ability to replicate ecosystem function is clearly limited."
    
    Quigley and Harper (2006b) highlight the need for improvements in compensation
    science as well as institutional approaches such as better project planning, monitoring,
    and maintenance. However, they also recognize that, based on decades of experience
    in wetland replacement projects, simply achieving compliance with all regulatory
    requirements does not ensure that ecological functions are replaced (NRC 2001, Sudol
    and Ambrose 2002, Ambrose and  Lee 2006, Kihslinger 2008). Although there are clearly
    opportunities to improve the performance offish habitat compensation projects,
    Quigley and Harper (2006b) caution:
    
           "it is important to acknowledge that it is simply not possible to compensate for
           some habitats. Therefore, the option to compensate for HADDs [harmful
           alteration, disruption or destruction to fish habitat] may not be viable for some
           development proposals demanding careful exploration of alternative options
           including redesign, relocation, or rejection."
    
    5. Conclusions
    
    There are significant challenges regarding the potential efficacy, applicability and
    sustainability 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 the type and magnitude described in the Bristol Bay
    Assessment. The mine scenarios evaluated in the assessment show that the mine
    footprint alone would 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, eroding the
    genetic diversity essential to the stability of the overall Bristol Bay salmon fishery.
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