Mark Hamilton: Don’t let Alaska get ‘Pebbled’ again



Something happened.

I’m not going to speculate exactly what happened. 

Representing Pebble mine for three years, I spent far too much time dealing with speculation by opponents with no basis in fact. 

I have no facts, no smoking gun. But something happened.

After nearly two years, and after the publication of the draft environmental impact statement and only months before the final environmental impact statement, the Army Corps of Engineers and its cooperating agencies determined that the alternative preferred by the developer was not the Least Environmentally Damaging Practical Alternative.

The developer’s preferred plan was to take the concentrate by road to the North Ferry Terminal, load it on an ice-breaking ferry, across the lake to be re-loaded on trucks to the port.  It was a unique approach that avoided by a factor of nearly half of the road crossings, bridges, and culverts of a land route.  

The Corps decided that the Northern route was the preferred route.  This is after nearly two years after having the developer’s preference.

The adjustments were significant, not the least of which was the known-to-everyone difficulty in securing rights of passage in the northern route.

There were a couple of related events that may have had an influence on this late switch.

Only a few weeks later, Environmental Protection Agency had coming due a “request for elevation.”

This seldom-used request amounted to a judgment that “this project is too difficult to handle at the regional level” so we request it is elevated to the federal level.

EPA chose not to send the request.  Instead, they published a letter explaining why they chose not to.  That letter amounts to a “bromance” letter with EPA, showering praise on the Corp of Engineers and the way the discussions were being handled.  

Almost from that day, relationships with the Corps of Engineers cooled noticeably, nowhere near unprofessional, but a bit more curt and distant. 

Something had happened.

The difficult adjustment was carried out with the project and the final EIS reflected the handling of those adjustments. 

Any project would have been thrilled to receive the final EIS that the Pebble project received. Yet, the standard requirement for a mitigation plan was presented with especially harsh rhetoric. 

Mitigation plans are always required as part of the process, and always come at the end of the process to account for adjustments in the plan needed to comply with various regulatory interpretations.

The response from our U.S. senators took no note of the excellent report, involving eight federal agencies and three state agencies, which reported that the mine was environmentally sound (with substantial call outs of innovation).  Instead, their take was essentially. “This plan cannot be permitted until the developer presents a mitigation plan.”

It sounded to me like a “Don’t give up haters, we still have another chance” message.

Mitigation plans are a reasonable and appropriate way to deal with the certainty that some environmental damage will be done by any road or any development.  Normally, the reasoning would direct, “you impacted this amount of wetlands; give us a plan you have for creating or restoring a small multiple of that.”

The mitigation plan that was required was very much a surprise. The Corp required a very high multiple of impacted wetlands: 10 times. That is way out of line with recent requirements.  The Donlin mine had a multiple of about 2.

But that only makes it harder.  It was the restrictions that came with it that makes one wonder.

Let me pause for a moment and further describe how mitigation is dealt with in the Lower 48. There, they have “mitigation banks,” which are essentially sites that have been polluted or otherwise compromised by historical developments.  The developer can select the project or projects needed to meet the requirements of mitigation. 

Some of these are quite demanding. For instance, in an old fuel storage area where leaking tanks have polluted the area, the developer may have to dig 40 or 50 feet into the ground and treat (sometimes burn) the dirt that can be cleaned, and dispose of the soil that cannot be treated.  In the end, the ground is near its original state.  They have whole companies whose job it is to respond to these requirements.

In Alaska there are few such polluted sites (although there are a few remaining from WWII fueling sites that are very polluted and very remote).

In any case, there was no option for mitigation banks at the Pebble site. There is no polluted ground there. There isn’t even a four-wheel track.  

The requirement was that all mitigation would be done “in kind,” which means impact on wetlands needed to be returned 10 times in wetlands.  That would have been doable by buying up land to be turned into a preserve.  That in itself would be a bad precedent for Alaska, which has 85% of federal wildlife area already. 

But there was more: All of the mitigation had to be done in the Koktuli river drainage.  The only possible solution was the buying up of land in the Koktuli drainage and making it a preserve. That is essentially what Pebble proposed and was rebuffed.

It was clear to all that the mitigation was made impossible on purpose.

I don’t know what exactly; but something happened. We will probably never know what it was, but we know from the final environmental impact statement what it was not: It was not a threat to salmon, it was not a threat to rupture the tailings facility, it was not an earthquake risk, it was not toxic.

It was a good mine that could have provided jobs for a very long time, brought a higher standard of living to all around the lake, and brought dollars to the state treasury.  

I don’t know what happened, but I know why. A majority of Alaskans were fooled. Once that happens, no one will wait for the science. Politicians will turn against the proposed project following the will of the people. One email from EPA had it right from the beginning:  “It’s not about science, it’s politics.” 

You were “Pebbled” Alaska. Don’t ever let them do that again.

The “Pebbled” series at Must Read Alaska is authored by Mark Hamilton. After 31 years of service to this nation, Hamilton retired as a Major General with the U. S. Army in July of 1998. He served for 12 years as President of University of Alaska, and is now President Emeritus. He worked for the Pebble Partnership for three years before retiring. 

Pebbled 1: Virtue signaling won out over science in project of the century

Pebbled 2: Environmental industry has fear-mongering down to an art

Pebbled 3: The secret history of ANWR and the hand that shaped it

Pebbled 4: When government dictates an advance prohibition

Pebbled 5: EPA ‘just didn’t have time’ to actually go to Bristol Bay

Pebbled 6: The narrative of fear

Pebbled 7: The environmentalists who cried wolf

Pebbled 8: Build your media filter based on science, not narrative

Pebbled 9: The history of hysteria

Part 10: Here we go again, with EPA power grab

Pebbled 11: Mining 101

Pebbled 12: Climate change, predictions that never came true

Pebbled 13: You can go fishing in a modern tailings pond


  1. As those with a brain suspected: this was never about science and all about virtue signaling and moving the goalposts. The anti-Pebble crowd will never listen to reason.

      • It’s just like Mr. Hamilton says. Every concern Pebble opponents had was addressed; whether it be dam leakage or mitigation. Pebble always had an answer the hypothetical problems. But its opponents aren’t interested in actual debate. They just cloud the discussion with misinformation and rhethoric.

    • There was no anti-Pebble crowd until the EnviroNazis chose it to be their next cash cow. They use fear-porn to frighten low-information persons into donating. See the big DONATE buttons on all their web sites? It’s only about the money! If there ever was a RICO crime, this is the poster child for it.

  2. Simple reason informs me that when a foreign entity spends tons of OUTSIDE money to IRREVERSIBLY affect the landscape and in so doing puts at GREAT risk and renewable food resource Centuries Old there is every reason to object to this project.

    • For the umpteenth time I’m reminding folks that Northern Dynasty is an exploration company, not a mining company.
      NDM will never be the one to actually mine the Pebble deposit. Whichever major mining company that buys Pebble will do the mining. It will most likely be a multinational, incorporated in some off-shore tax shelter.
      They will have shareholders all over the world, but the majority will be Americans, because we got the most money to buy them.
      Meanwhile, the majority (or very close to it) of NDM shareholders are American; purchased by American individuals, or American retirement funds and other American NGO’s.
      NDM’s biggest mistake was to present a plan. They had hoped to attract a major mining company with an approved prospect. Their plan was idiotic, and an abject failure. If they had simply kept doing their timely annual reports, there would still be hope for Pebble.
      I’m waiting for NDM shares to drop to 2 cents, then I want to buy controlling interest, fire everyone except the small crew performing the minimum annual labor. Then I will simply outlast the no-pebble bunch.
      Pebble will be mined someday. I want my children, and/or great great grand-children to own it then.

  3. So good to see Hamilton’s articles continuing. This is number 14 of a series of 10? Ahahahahaha!
    I’m looking forward to comments from his personal dissenters. So far they haven’t been able to counter anything Hamilton has said. Not a single thing at all. Just some nebulous gripes about how Hamilton dealt with what used to be the white redoubt U of A mining department.
    It’s full of foreigners and minorities now. It’s as woke as woke could possibly ever be. Maybe that’s it. Maybe the white colonials are disgruntled because they lost their mini version of the “Boer Wars”.

  4. What a complete sham and shame! All of these potential mine projects in AK would provide great paying jobs, offering fantastic opportunities for both individuals and local companies, as well as lifting the economic standard of living for Alaskans.
    Just think about future prospective developers and investors, what exactly they think of the reliability of resource development in the SOA.
    To the detriment of Alaska and Alaskans, I’m guessing they see better opportunities elsewhere … AND, alleviate themselves from the Sham & Shame!!!

  5. We could have had a mine right here in Juneau by reopening a long dormant mine site. Nope, city leaders thought it would ruin our water and create climate change. Think of the revenue it would have provided. Instead, they raised commercial property tax rates by 50%.

  6. Although the mine would be safe and provide great economic benefits, it would make some people feel sad. Besides, we can buy everything we want from the Chinese, who are our good friends and great stewards of the environment.

    • Couldn’t agree more. Hamilton is beating a dead dog, “pebbling” us to death with his BS. A hypocrite who snickers at all of us while counting his huge retirement income from the military, state (UA), and the Pebble Mine. Go find a new act, and quit “Hamiltoning” us. Everyone is on to you. Happy New Year.

      • Whew! For a moment I feared that you guys wouldn’t show up. I would have been embarrassed talking to myself. Glad to see ya. I’d rather see ya, than be ya. Ahahahahaha!

      January 1974

      “The fluctuating inflow of sea waters from the North Pacific into the Bering Sea strongly influences the estuarine character of Bristol Bay. Tidal effects are quite important in the shallow basin of Bristol Bay, and a significant fraction of
      the waters of the Bay is exchanged on a semidiurnal schedule.
      Bristol Bay waters are also affected by major storm tracks and its regime tends to respond rapidly to these transitory influences.
      All these factors result in tremendous seasonal, annual,mand long-term variations in the critical environmental characteristics of water temperature, salinity, dissolved oxygen, and nutrients. These variations have been studied most carefully in relation to the sockeye salmon. Populations of this prime resource have varied more than two orders of magnitude decreasing within a decade from more than 60 million to less than 600,000”
      This is the actual science. It’s a lot different than what the EnviroNazis claimed.

      Little has changed for BB in 47 years. This old study pretty much matches up with present data. Reliance on this single resource is a crap shoot. Remember the bad years when locals had to sell their permits? Few ever managed to do well enough buy them back.

      Pebble could have been year around steady income, for 150 to 200 years. The fish would still be there, following the cycle of good years and bad. Pebble could have been a vital economic anchor, if you hadn’t fallen for the binary choice the EnviroNazis gave you.

    • “Joining his field and academic experience, Cook wrote several books about gold mining and processing. His most difficult academic job, however, was guiding UA’s mineral programs though administrative reorganizations in the 1970’s and 1980’s. The mining programs passed from the School of Mineral Engineering to the College of Earth Sciences and Mineral Industries and finally to the School of Mining, Petroleum, and Geological Engineering … One of Dean Cook’s outreach programs administered a Bureau of Indian Affairs program to train mineral processing technicians from rural areas. A profound benefit to Alaska and its mining industry derived from changes Dean Cook initiated in the curriculum and, especially, outreach programs. Because of changes in mineral economics and environmental laws, Dean Cook saw the need for reorganizing the curriculum and the UA mining outreach to emphasize environmentally responsible mining.”

      From what I can gather from Hamilton’s dissenters, from the previous 13 article’s comments, is that it seems like Hamilton is getting blamed for what Cook did.

      I remember some of the engineers from those days. Augenbaugh, Skudrik, Metz, and Toul, of U of A,F and Gallagher of DMEM. (or was it BLM?) It had an M in it. Maybe Metz and Toul were name places in my memory, from when I was stationed in France, back in 65?
      Don’t get me started on the civil war. I was there. Ahahahahaha!

  7. Let’s not forget the value of the ore alone would equal the economic output of all of the salmon in all of the Bay for somewhere around 1,000 years. Oh, let’s also not forget that most of the value of the salmon is shipped out of the region each and every year.

Comments are closed.