Outline for the Development of EPA's
Bristol Bay Watershed Assessment
February 7, 2011
The U.S. Environmental Protection Agency (EPA) has received requests from nine tribal
governments, and a number of other interests, to take action to protect the Bristol Bay
watershed from the adverse impacts of potential large-scale hard rock mining projects
utilizing EPA's statutory authority, including Section 404(c) of the Clean Water Act
(CWA). This authority allows EPA to prohibit or restrict discharges of dredged or fill
material into waters of the United States, including wetlands, when it determines that
such discharges would have an unacceptable adverse effect on municipal water
supplies, shellfish beds and fishery areas (including spawning and breeding areas),
wildlife, or recreational areas. We have also received requests from two tribes and
several other interests to refrain from taking advance action and to wait for specific
permit applications for these projects to be reviewed by the U.S. Army Corps of
Engineers pursuant to Section 404 of the CWA and the National Environmental Policy
Act (NEPA). While the Bristol Bay watershed is comprised of 7 drainages, the Kvichak
and Nushagak watersheds are the principle drainages with lands open to large scale
development. EPA's analysis, therefore, will focus primarily on those two watersheds.
The purpose of this outline is to describe a process for EPA, in coordination with Federal,
State and Tribal organizations to collect and evaluate information necessary to
determine whether to initiate an advanced 404(c) action, or take other appropriate
action at this time.
Details of the Watershed Assessment Process
The purpose of this process is to build a common understanding of potential impacts to
Bristol Bay's salmon fishery and to identify possible options for protecting these
resources. The following three questions are central to this analysis:
•	Is the Bristol Bay salmon fishery the one of a kind, world class fishery that it is
depicted to be?
•	What are the existing and potential risks to Bristol Bay's salmon fishery
associated with large-scale development activities such as hard rock mining?
•	Are there technologies or practices that will mitigate these risks?

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Scientific/Technical Information Gathering
EPA will prepare a watershed assessment for Bristol Bay's salmon fishery using existing
scientific and agency produced information. This document will describe the Bristol Bay
salmon fishery, the potential risks posed to this fishery associated with large-scale
human development in Bristol Bay, and available measures to mitigate these risks. The
tasks for completing this watershed assessment include:
•	Review and document relevant literature, interview relevant agency staff and
other experts on the ecological and economic significance of the salmon
resources in the Bristol Bay watershed. The goal of this review and
documentation process is to describe the current status of salmon resources of
Bristol Bay, and to answer the question "What is the ecological and economic
significance of Bristol Bay salmon resources locally and around the North Pacific
Ocean?" Compare the Bristol Bay salmon resource to others in North America in
terms of importance to the greater ecosystem it supports.
•	Review and document relevant literature, interview relevant agency staff and
other experts on the risks, threats and stressors associated with current and
foreseeable human activity on the health of salmon resources of Bristol Bay.
•	Review and document mitigation practices used to abate threats and risks
identified in Task 2 to answer the questions "What are commonly used
mitigation measures and what are available but uncommonly used mitigation
measures?" and "What are their success and failure rates when applied to
protecting water quality, quantity and fishery resources?"
•	Develop a synthesis of the cumulative impacts of all risks, threats and stressors
identified on the long term ecological integrity of the Bristol Bay salmon resource
and factor in the perpetual efficacy of any mitigation measures identified. Final
conclusions will also include the long-term impacts of identified threats and
stresses on the economic values of fishery resources.
Federal, State, Tribal Involvement and Public Input
EPA will seek participation from federal, state and tribal agencies to:
•	Pool relevant information at their disposal and determine appropriate sources of
missing information;
•	Review EPA's watershed assessment; and
•	Participate in public meetings organized by EPA (below).
EPA plans to hold two sets of public meetings in Anchorage and the Bristol Bay
Watershed. Written and oral comments will be accepted.
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Outline for the Development of EPA's Bristol Bay Watershed Assessment

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•	The first set of meetings will be to present the preliminary findings of the
scientific analysis and solicit public input to address questions one and two (is it
a world class fishery? and are there existing or potential risks to that fishery?)
o We anticipate being ready for these meetings in 6 to 9 months but will
coordinate with Tribes and stakeholders to ensure their availability.
•	The second set of meetings will take place after peer review of the watershed
assessment. They will be developed to discuss the issue of available
technologies and practices to mitigate any potential unacceptable effects and
how to incorporate these protective actions into development of the watershed
using either 404(c) or other federal authorities.
o We anticipate being ready for these meetings in 9 to 12 months but will
coordinate with Tribes and stakeholders to ensure their availability.
A summary of each public meeting will be developed and made available via the web. In
addition, EPA will create fact sheets and mailings as work progresses to keep the public
informed.
EPA will consult with Tribes in the watershed that request consultation and will meet
with prospective resource developers within the watershed, relevant federal and Alaska
state agencies and other interests as requested and appropriate.
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Outline for the Development of EPA's Bristol Bay Watershed Assessment

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