Aug. 12, 2020

S2, Ep 99: Nelli Williams of Trout Unlimited

In this episode, I catch up with Nelli Williams, Trout Unlimited’s Alaska Program Director. Nelli shares her journey from the Midwest to Alaska, discusses TU’s extensive work in the state and updates us from the front lines on recent developments with respect to the proposed Pebble Mine.

Related Content

S7, Ep 98 - The Fight for Our Future: Land Tawney on Grassroots Advocacy and Public Lands

S7, Ep 84 - Tying Tradition and Innovation: Tom Herr's Atlantic Salmon Flies and Philanthropy

S7, Ep 91 - The Chocklett Factory: I Have Been Everywhere, Man

S6, Ep 97 - Fly Fishing Wisdom and Industry Pet Peeves with Greg Senyo

Helpful Links

 

Save Bristol Bay

Save Bristol Bay on Facebook, Instagram and Twitter

Trout Unlimited

Contact Your Elected Officials About Pebble Mine

Contact the EPA About Pebble Mine

People of Bristol Bay Interviews

Kate Crump of Frigate Adventure Travel

Drew Hamilton of Friends of McNeil River

Tia Shoemaker of Grizzly Skins of Alaska

Chris Wood of Trout Unlimited

All Things Social Media

Follow us on Facebook, Instagram, Twitter and YouTube.

Subscribe to the Podcast or, Even Better, Download Our App

Download our mobile app for free from the Apple App Store, the Google Play Store or the Amazon Android Store.

Subscribe to the podcast in the podcatcher of your choice.

EPISODE SUMMARY

Guest: Nelli Williams - Alaska Program Director at Trout Unlimited (Anchorage, Alaska)

In this episode: Conservation advocate Nelli Williams shares insights on protecting Bristol Bay from the proposed Pebble Mine and Trout Unlimited's extensive conservation work across Alaska. Topics include headwater protection strategies, habitat restoration projects in Southeast Alaska, cold water conservation initiatives on the Kenai Peninsula, climate change impacts on Alaska fisheries, the cultural significance of salmon to Alaska Native communities and the critical fight to prevent Pebble Mine from threatening the world's largest sockeye salmon run.

Key fishing techniques covered: • Dry fly fishing for rainbow trout in clear mountain streams • Swinging flies for Pacific salmon • Sockeye fishing techniques • Exploring diverse Alaska fishing opportunities across multiple species

Location focus: Bristol Bay (Southwest Alaska), Southeast Alaska (Prince of Wales Island, Thorne Bay), Kenai Peninsula/Kenai River, Resurrection Creek/Resurrection Bay (Seward), Matanuska River

Target species: Sockeye salmon (Bristol Bay's primary species), rainbow trout, chum salmon, pink salmon

Equipment discussed: Limited equipment discussion; general fly fishing gear for Alaska's diverse fisheries

Key questions answered: • What is Pebble Mine and why does it threaten Bristol Bay? • How does Trout Unlimited protect Alaska's wild fisheries? • What makes Bristol Bay the world's most important salmon watershed? • How are climate change and warming waters affecting Alaska fisheries? • Why is salmon habitat critical to Alaska Native culture and subsistence?

Best for: All anglers and conservationists interested in fisheries protection, Alaska fishing destinations, conservation advocacy, understanding threats to wild salmon habitat and supporting Bristol Bay protection efforts

 

**Marvin Cash (00:04):**
Hey folks, it's Marvin Cash, the host of The Articulate Fly. On this episode, I'm joined by Nelli Williams, Trout Unlimited's Alaska Program Director. Nelli shares her journey from the Midwest to Alaska, discusses TU's extensive work in the state and updates us from the front lines on recent developments with respect to the proposed Pebble Mine.

But before we get to the interview, just a couple of housekeeping items. At the end of July, the Army Corps of Engineers released its final environmental impact statement, putting Pebble Mine one step closer to becoming a reality. No doubt you've seen many related posts on social media. If you oppose the proposed Pebble Mine, liking and sharing these posts is simply not enough. I challenge you to take five minutes today to tell a friend, a family member or a co-worker who has never heard of Pebble what is at stake, why it's important to you and how to take action. Everything you need is in this episode's show notes.

And if you like the podcast, please tell a friend and please subscribe and leave us a review in the podcatcher of your choice. It would really help us out. And now, on to the interview.

Well, welcome to The Articulate Fly, Nelli.

**Nelli Williams (01:18):**
Hi, Marvin. So happy to be on.

**Marvin Cash (01:20):**
Well, I appreciate you making the time for me so early in the morning out in Alaska. And we have a tradition on The Articulate Fly - we always ask all of our guests to share their earliest fishing memory.

**Nelli Williams (01:31):**
Oh boy. I am a third generation bluegill fisherwoman. I have very early memories of fishing with my grandma and grandpa and mom on the Mississippi River for bluegills with cane poles and worms. And my sister and I were tiny when we'd go out in our little boat and find a snag and see what we could catch. And really good memories, although I didn't like eating them then, of bluegill fish fries and just really good family time. So those are my very earliest memories, really, are fishing and playing on the Mississippi.

**Marvin Cash (02:24):**
Yeah, very neat. I have to agree with you on eating bluegill. They have a ton of bones.

**Nelli Williams (02:30):**
They do, although I've got a technique that my grandma and great aunt have taught me that it's fantastic. And you can get around the bones.

**Marvin Cash (02:41):**
Oh, very neat. Well, sometime when we meet in person, you'll have to share that with me. So, you started fishing for bluegill on the upper Mississippi. When did you move to the dark side of fly fishing?

**Nelli Williams (02:50):**
Well, it was kind of a slow process. My dad got me a Cabela's fly rod sometime in high school and I played around a little bit with it without a ton of success. I grew up in Wisconsin so certainly some great places to fish, but never really got into it until in college. I worked in Alaska in the summer and I met my now husband.

And we spent a lot of early mornings before work - we worked on Prince of Wales Island in Southeast Alaska - going out and fishing and exploring a really special island down there. And that's when I started to pick up fly fishing. Super challenging. And fishing for sockeye is, you don't have to be very graceful at it, but they are picky. So lots of frustration and learning moments there.

And then where I really picked it up is I started working for Trout Unlimited after I graduated in Wyoming. And there I just had some spectacular members, two members kind of take me under their wing and show me all the nuances and beauty and details and helping me with my cast. Super grateful for that. And the dry fly fishing and clear mountain streams is really challenging and you kind of have to figure it out.

And then more recently, I've had some more instruction from some really talented anglers here in Alaska and continued tips from my husband as he's rowing the boat or we're taking the kids out.

**Marvin Cash (04:53):**
Yeah, very neat. And, as you mentioned, you have kind of been with TU since you got out of college. Tell us a little bit about your journey from being with TU in Wyoming to becoming the Alaska program director that you are today.

**Nelli Williams (05:08):**
Yeah, I've been with TU for 13 years. It doesn't seem like that long. I started out working with TU volunteers in Wyoming, both chapters and councils, and helping them to implement conservation projects in their home waters. Which was a great way to learn about TU and how we operate in local communities, but also all the way up to Washington, D.C.

I've had the Alaska bug since I've been tiny though, and always wanted to get back to Alaska after working up here in college. So when we had the chance to make the move, my husband got a job up here in Anchorage. We moved and I was lucky enough to continue to get to work for TU. And that was my first foray into learning about Bristol Bay and Alaska's trout and salmon issues.

So I've been up here for 10 years. And about five years ago, the former Alaska director left and I was asked if I was interested in applying. And we're here. Here I am five years later and get to work with a really awesome team up here.

**Marvin Cash (06:36):**
Yeah, very neat. What does a normal workday look like for you in that role?

**Nelli Williams (06:42):**
I don't know what's normal these days, Marvin. I start my days really early. I creep downstairs and try to get as much work done in the early morning hours before the kids get up.

And then I think one of the best parts of this job is the people I get to work with. So I spend a lot of my day on the phone or on video calls, either with our team of eight here in Alaska or colleagues from D.C. to the Pacific Coast, trying to figure out how we solve these really pressing conservation issues in Alaska.

And then we have this incredible network of anglers and other people that care deeply about the issues we work on in Alaska, because Alaska just is special and it captures people's attention. And I spend a lot of time talking with folks that want to give back. They want to give back to these places that they love to fish. And my job is to figure out how they can do that and what that partnership between us and our work and their interests are. So whether that's supporting financially or volunteering or spreading the word, that's a huge part of my job.

And then also working with partners. We work with so many people to accomplish our goals, from local tribal leaders in villages in Bristol Bay to federal and state agencies on restoring other areas of Alaska that need help, to businesses that operate either here in Alaska or their products - their fishing rods - come up here to Alaska. And that community is wonderful. And I am honored to get to spend a lot of my day connecting with those folks and helping us move forward with what we want Alaska to look like in the future.

**Marvin Cash (09:07):**
Yeah, very neat. And we'll talk a lot more about Bristol Bay a little bit later on in the interview. But you mentioned you're working on other initiatives in addition to that. Can you kind of briefly outline the major kind of non-Bristol Bay things that you and your team are working on in Alaska?

**Nelli Williams (09:24):**
Sure. I'd be happy to. So we, in general, TU works to take care of the places people love to fish in Alaska. And I think some of those big places that like Bristol Bay come to mind, the Kenai Peninsula, the Susitna River drainage and then the Tongass National Forest, which is all throughout Southeast Alaska. Those are these big important salmon and trout areas. And our work varies in each place, just depending on the circumstance.

But in Southeast Alaska, for example, we are working to safeguard 77 of the most important trout and salmon watersheds in that area. And we've identified those through working with stakeholders and scientists and really kind of zoom in on where the best and most fish habitat is and getting those into better protection statuses. So better safeguards.

And then in addition to that, there are a series of mines, massive mines in British Columbia on or near rivers that flow downstream into Southeast Alaska, which for many of the reasons that we got involved with Pebble, there's similar things happening in Southeast Alaska and are working to make sure that the communities and fisheries downstream of those mines are protected and there's some safeguards put in place from these mines that together are much larger than Pebble.

So that's Southeast. We also have this great work where we help facilitate the Salmon and Trout Habitat Partnerships, which is a national program and there's many here in Alaska and we're involved in Southeast Alaska and we have chapter members involved in the Kenai Peninsula and in Bristol Bay. And then also, we're new hosts to the Mat-Su Salmon Habitat Partnership.

So and that's just great on the ground work in local communities of conducting needed science or facilitating restoration of rivers that need help, from culverts to bank stabilization, water quality issues, you name it. And are also as part of that work involved in restoring a river post dam removal.

So I think a lot of folks think that Alaska's fisheries are in really good shape, which for the most part they are. But there are some areas that need a little help. And in order to keep Alaska's fisheries thriving, we definitely have some restoration work on our hands.

And then lastly, an issue near and dear to my heart is we help run the Bristol Bay Fly Fishing and Guide Academy, which is a program that works to teach and empower and inspire local kids in Bristol Bay, primarily Alaska Native kids, and teaches them how to fly fish and what it's like to be a guide with the intention of getting more local kids as fishing guides in Bristol Bay, which will help on so many levels by bettering local employment opportunities and I think strengthening the entire social and economic system so that we can continue to say no to things like Pebble Mine.

**Marvin Cash (13:21):**
Yeah, very interesting. And I know from doing other interviews, like when I was lucky enough to talk to Chris back in April, you mentioned this earlier in the interview. TU spends a lot of time on the ground, I think, doing a lot of hard work to collaborate and build coalitions and have cooperative decisions.

And one of the interesting things, it's not unique to Alaska because we have it out kind of in the Western United States too. But obviously you've got mining, oil and gas and timber. And I thought it'd be interesting for you to speak to kind of how you think policymakers ought to look at those extractive industries and when they work with other constituencies.

**Nelli Williams (14:03):**
Yeah. Yeah. I mean, that is like a multi-day workshop we could really try to map that out. But some quick thoughts on it, Marvin.

I mean, first, let's just acknowledge we need those non-renewable resources for daily life, whether it's building houses or electronics. Those are key to how we operate. But I think we have to get a little smarter on how we responsibly develop those resources and use those resources.

And I think one piece of that is really doing some more full cost and benefit accounting and analysis around these projects. I think so often a timber sale or a mining project or oil and gas project just devolves into this environment versus jobs discussion and debate. And you hear things like, well, you care about fish more than you care about people. And I think we need to do better there and really look at what are the costs associated with resource extraction as well as what are the benefits.

But for right now, I don't think we do a very good job at looking at some of the costs and trade-offs to a resource development project. So, for example, like we need to fully understand what this land and water that would be impacted does for clean drinking water or for foods that local communities and villages depend on. We need to talk about jobs and whether it's recreation or tourism or commercial fishing or recreational fishing. Like all of that, we really have to take a look at the full picture. So I think that's one part of many.

But I think also there's those intangible things that are often kind of pushed to the side, and are really brought to light in a pandemic, right, where outside and on our public lands and waters are some of the places, the only things we can do right now safely. And there's a lot of value in having these places that aren't developed for giving back to families and nurturing our heart and soul during challenging times. And that's, I don't think we do a great job of taking those things into account.

**Marvin Cash (17:08):**
Yeah, and I know it's a challenge too, because you kind of have that kind of short-term cost and benefit and the long-term cost and benefit. I think it's a challenge to kind of get people to kind of look more than five years down the road.

**Nelli Williams (17:22):**
Yeah, absolutely. And I think that, we have, it's just part of society right now. And in Alaska, we do care a lot about the outdoors. And I think a big reason people care about that is because they want those future generations, their kids and their grandkids to have the same opportunities that we all get to enjoy today. And I think that just speaks to your point of how can we continue to look along that timeline versus how can I have a job in five years? And I don't want to discount that because jobs are important for all sorts of community benefits and we need jobs.

But I think we also can get creative on how these outdoor undeveloped places can better support communities economically. And a lot of the numbers around outdoor recreation as well as tourism are huge when you actually look at the numbers. And that's been one promising thing to me lately is the acknowledgement of a several billion dollar industry that depends on clean water and wild rivers and lands. So, huge, huge topic. I'd love to get some good thinkers in a room and detangle that.

**Marvin Cash (19:05):**
Yeah, we'll put that on the list maybe for the next time we talk. You know, and you've been lucky to live in Anchorage for about 10 years, and so you've had a front row seat for the Bristol Bay saga for a long time. What has that experience been like?

**Nelli Williams (19:21):**
Oh, boy. It has been both incredibly intense and inspiring at the same time. You know, when I can remember the first year I moved up here and jumped in on the Bristol Bay issue. I was at the Anchorage sports show and just person after person would come up to us and say, I appreciate what you're doing, but there's too much money in the ground. There's no way that mine's not going through. Like, good luck, thanks, but basically you're gonna fail. And that was tough.

But thanks to so many people that have worked tirelessly on this. And we kept educating, we kept pointing out how big this mine was, where it was located, why that was bad. And relentlessly over many, many years have finally got the message out and people understand how big a deal this is and have pushed back. And widespread opposition in Alaska, widespread opposition locally.

And that, thankfully, has gotten the attention of investors. And we've seen all the investors at this point walk away. They don't have, they're a foreign mining company that's never developed a mine before that is running out of money. So to take this project from a sure thing to a project that, while we have a serious next couple months here. But to take it from a sure thing that everybody thought was absolutely going to go through no matter what, to a project that is widely opposed in Alaska and by hundreds of anglers across the country, to a project that is questionable.

And I think that is because people have spoken up time and time again. And that has been the inspiring part. And also just knowing, getting to know and working with the folks in villages that will be most impacted by the mine is incredibly important piece of our work and I'm inspired by it daily.

**Marvin Cash (22:06):**
Yeah, it's interesting too, right? Because, I mean, the Bristol Bay, Pebble Mine concern has been going on for about 15 years. How do you keep the broad coalition that you've helped to develop and all the supporters energized over such a long term struggle?

**Nelli Williams (22:25):**
It is the thing that probably keeps me up at night the most about this campaign. You know, I think there's been a lot of strength in the growth and diversity of the coalition opposing this mine. And there's been waves of folks when there's urgency and highly involved and things get easy. And then there are times where, like things are wonky and it's hard to explain and you have to kind of muddle through and figure out how to keep people plugged in.

And I think recently, I guess, one, I think always getting back to the basics on, we are trying to safeguard the last best remaining wild salmon habitat in the world. I think 50 million salmon come back, have come back time and time again in the past couple of years. Like, there's just nowhere else on the planet like Bristol Bay.

And I think that is what motivates all of us. And you can overlay caring about that because your culture and family and everything depends on it. You can overlay that with your love of fly fishing or salmon fishing. You can overlay that with your job and your boat and your family as commercial fish there forever. Like, all of that boils down to this core common love of a very special place. And so that's motivating and I think motivating for all of us who work on it and dedicated volunteers who have spoken up time and time again.

And then recently we've really tried some new things on social media and made sure that it's easy for people to plug in. If you're going to weigh in multiple times, like we'll make it easy as possible for you. Making sure that we have new ways of spreading the word, whether it's short videos or new voices or pictures or you name it, is trying to adapt with the changing times.

And also tell the story of inspiration, right? Like we've taken this mine from a sure thing. And now this is a single company who's financially struggling that is desperate for a permit. And if we just double down and hold the line, like we can get on to bigger and brighter conversations about how we keep Bristol Bay intact for the long haul versus fighting over a mine that should never be on the table in the first place.

**Marvin Cash (25:34):**
Yeah, it's really interesting. And we're going to talk about the final environmental impact statement in a few minutes. But I did want to talk to you because I know you're the person in the know about this because it's in your backyard.

I guess the early part of June, Trout Unlimited appealed a lower court decision that was unfavorable to the coalition that was related to the proposed 404C determination for Bristol Bay. And my understanding is in July of 2019, the EPA withdrew that determination and TU and a broader coalition of interest sued to have it reinstated. And the lower court found in favor of the EPA.

And I don't think a lot of people in the lower 48 are really familiar with this. Can you tell us a little bit about what the proposed 404C determination was supposed to do?

**Nelli Williams (26:28):**
Yeah, so there is a part of the Clean Water Act that says if a place is really important for fish or wildlife or municipal water supplies or recreation, that it can and it could be impacted. You can say that those areas are either off limits or mine waste should be restricted in those areas because of their importance.

In 2010, tribes, as well as commercial and recreational fishermen and women, petitioned the EPA to implement 404C. And that resulted in a multi-year process. And in 2014, we had a proposal. It wasn't finalized, but a proposal to restrict mine waste in the Bristol Bay region and the Pebble deposit region, restrict the disposal of mine waste in the Bristol Bay region.

And that functionally would have, unless Pebble could figure out how to mine the deposit and ship the waste to the moon or something, that functionally stopped Pebble and put some really important safeguards in place for incompatible industrial mining in Bristol Bay. But it was never finalized. So that's what has led to the lawsuits.

**Marvin Cash (28:00):**
Got it. So it kind of lived in place for about five years. And then I guess in July of last year, the EPA withdrew the determination. What was their justification for doing that?

**Nelli Williams (28:11):**
Well, they didn't have much of one. And that's the problem. And that was kind of the heart of the lawsuit is that they withdrew that for arbitrary and capricious reasons. And which basically means that they did it for frivolous reasons or reasons that aren't justifiable by law or public interest or process. And that was the heart of the lawsuit.

And I guess the behind-the-scenes story is that the Pebble Partnership and Northern Dynasty spend hundreds of thousands of dollars a quarter. They're one of, they shell out a lot of money on lobbyists, both in D.C. and in Juneau. And I think they got to whoever the decision maker was and convinced them to withdraw it.

**Marvin Cash (29:06):**
Yeah. And so was the federal district court ruling that the EPA was not arbitrary and capricious?

**Nelli Williams (29:16):**
So we had to get past the process question, and now we've appealed that to the Ninth Circuit. And we have oral arguments this next couple weeks, two weeks from now, where we hope that we'll get to talk about the merits of whether or not the decision by the EPA was arbitrary and capricious.

**Marvin Cash (29:39):**
Got it. And so if you have oral arguments in two or three weeks, which would put you into kind of maybe the second or third week of August, when would you expect a decision from the Ninth Circuit?

**Nelli Williams (29:50):**
We hope pretty quickly. The court has been, understands the importance of resolving this prior to a permit being issued. So we hope soon, soon after.

**Marvin Cash (30:05):**
Yeah. And of course, the big news for everyone that's been following Bristol Bay and the proposed Pebble Mine is literally, I think, exactly a week ago. We're recording this on July the 23rd. The Army Corps of Engineers issued its much anticipated final environmental impact statement with the determination that the proposed mine did not pose serious environmental risks. And I don't think that was unexpected from everything I've sort of seen in the press.

Nelli, from your perspective, what are the three most significant shortcomings of the report?

**Nelli Williams (30:42):**
Yeah, so I'll try to keep it to three and I'll try to lump them into three big issues. So I think to fully understand what this document says and does not say, you kind of have to look at Pebble's plan and what they've applied for from the Army Corps of Engineers. And they've asked for a permit to build a 20-year mine with a whole bunch of infrastructure. And then their plan is to fill the hole they dig.

After only mining 13% of the ore body, they're going to dig down to the most valuable part of the ore body and then say, oh, you know what? We're good. We're going to fill the hole back in and walk away. And I think it takes a stretch of an imagination, regardless of who you are, to think that is practicable and reasonable. And that this document is based on a false assumption that that is actually what is going to happen.

So I think the number one issue with the final EIS is that it's not taking a reasonable look at how this mine will actually work. And the high likelihood that Northern Dynasty Minerals says time and again, this mine will expand. And that is the heart of why this document underestimates the impacts of the mine proposal.

**Marvin Cash (32:35):**
Yeah. And to put a finer point on that, I guess, am I correct in understanding, I mean, I've seen various things from various different groups that kind of as proposed, the mine is not profitable at all?

**Nelli Williams (32:50):**
That's right. Right. And then I guess one of the other things that the more time I've spent with this issue, I've heard several mining experts and mining industry experts say that if you remediate the mine as proposed, which I guess is to take the tailings and fill the pool back, that it's impossible to then further exploit the deposit, which means that you basically are guaranteed to have an unprofitable project.

**Nelli Williams (33:16):**
That's right. That's right. Like you have hundreds of millions of dollars, if not billions of dollars of infrastructure that have to be built to start mining, a power plant, dozens and dozens of miles of road, a water treatment plant that's never been done before, a pipeline, like a port. Like all of that has to be built before you can dig the hole. And that costs a whole bunch of money.

And it's completely asinine that you're not going to build a profitable, like you're going to stop mining until you hit profit. Right. Like, and we have the Pebble Partnership who's in Alaska and they're the marketing arm of Pebble. And then you have Northern Dynasty, the marketing arm of Pebble that's saying, you know what, like, we've adjusted this mine, it's going to run perfectly, we're responding to all these concerns we've heard over the years.

And then you have Northern Dynasty, which is the only owner of the Pebble Partnership, saying to shareholders, this is a world-class resource. This has potential generation worth of minerals. You know, they're talking out of both sides of their mouth. And unfortunately, the FEIS has chosen to listen to the marketing arm and not really peel back the covers and say, hey, actually, like, we need to take a closer look at this and evaluate what you will reasonably and practically do.

**Marvin Cash (35:02):**
Right. And you've still got two more objections. So let's hear them.

**Nelli Williams (35:08):**
Yeah, yeah. Well, I think I'll be quick with one of them. Like, there's been many major project changes since this process started and the public comment period closed back last July. I mean, and those project changes aren't just like moving the road a little bit or different material for the pipeline. This is like they've changed the preferred road route from going across Lake Iliamna to building it across the entire northern edge of Lake Iliamna. A totally different location for the port. Their plan changed meant that a 40% increase in the amount of water that would have to be treated, 30% more streams would be destroyed.

Like, we're not talking about small changes. Like, there have been massive changes to Pebble's plan with no additional comment period, no additional analysis. And that has been a real concern for especially local communities and all of us that care about this process working and not cutting corners.

So I don't understand there. Well, I do understand this process has been rushed and not thorough or robust as it should be when you're talking about a giant mine in the heart of salmon country. And the only thing that I can think of is the CEO of Pebble gets a $12 million bonus if he can get this through the process in four years. So we shouldn't be rushing for that reason. This is too important. That's my second one.

**Marvin Cash (37:11):**
And the third one.

**Nelli Williams (37:13):**
And the third one. So throughout the document, there is kind of concept level information where details are absolutely and should be required. At this point, we've been hearing about Pebble for 15 years. They've had ample time to develop a really solid plan. And we're getting bar napkin plans when we should be getting finite details about how this is going to operate and why the things they're saying will actually happen.

And one example, and this is a big one because clean water is important, right, to all of us. And they have proposed a water treatment plan that would have to process somewhere between 39 million gallons and 54 million gallons of water every day. And we're not just talking about kind of basic sewage treatment operations. Like we're talking about a complex water treatment plant that has to do everything from sediment filtering to pollutant and osmosis and like really challenging water treatment process.

And they have a concept-level plan that has never really been tested anywhere before and have thus far failed to provide the details and the proof that this plan will actually work. And they do it also on the tailings dam. And the tailings dam plan was designed and had a lot of input by the same folks that designed the Mount Polley Dam that failed several years ago with catastrophic impacts to the fisheries and the communities.

Like those plans are concept level at best, they're similar to a dam that has failed. And despite Pebble committing to an independent review before permitting, like that hasn't been done. And then we have information in the FEIS by the Army Corps of Engineers own contractor that is tasked with the FEIS development. And they have things in there like the tailings dam plans are incomplete and misleading. There's implications for embankment stability.

And despite these very big red flags, the Corps of Engineers did not require nor do the model of a full tailings dam failure, which clearly could have much greater impacts than what are already known and on the table.

So all that adds up to there's a couple of choice quotes from the environmental impact statement that Pebble likes to highlight. But this document describes massive impacts, like 100 miles of streams gone forever and 2,000 acres of wetlands gone forever. And those impacts are highly underestimated because of the failure to fully analyze the impacts that this project will have, both a 20-year timeline and a 100-year timeline. So the list could go much longer than that, but those are the big ones.

**Marvin Cash (41:07):**
Yeah. And so, it's interesting, right? Because I know there are kind of numerous kind of circuit breakers in the process. And my understanding is one of them is the Environmental Protection Agency. And what I understand is that they have the ability to override or challenge the Corps' determination.

I know it's relatively early on, but has there been any kind of feeling or feedback from the EPA and how they've reacted to the report?

**Nelli Williams (41:41):**
Yeah, I mean, a few months ago, weeks ago, the EPA wrote a letter that said that there's been numerous opportunities to raise concerns and that EPA will continue to do so. So they flagged a new species, genetically distinct species of sockeye salmon in the Kvichak. And they didn't indicate either way what their action might be, but certainly are in constant conversations with the Corps.

There are several levers that can be pulled at this point. Like, one, like Army Corps of Engineers, from our perspective, has plenty of information in this final environmental impact statement to not issue a Clean Water Act permit and simply say, you know what, like, we can't issue this permit for reasons X, Y or Z. And that's one way.

And then, of course, the EPA has final jurisdiction on clean water and everything that's under the Clean Water Act. And they could also say, you know what, if this permit shouldn't be issued because it violates portions of the Clean Water Act. And another option is that folks could say, like, well, there's just too much missing information here. Like, we need to go back and do a supplemental environmental impact statement because we missed stuff.

I think that the first of those options is probably the best of the three options, the most likely of the three options. But there's a lot at play right now. There's going to be a lot of this decision, I think, is going to be made at some of the highest levels of the administration. And that's our job right now is to convince the EPA, the Army Corps of Engineers and the administration that this mine makes no sense, no matter how you look at it, and the permit should be denied.

**Marvin Cash (43:59):**
Yeah, got it. And to kind of, I guess, help me and help our listeners understand, is the Army Corps of Engineers record of decision the same as issuing the Clean Water Act permit?

**Nelli Williams (44:09):**
Essentially, yes.

**Marvin Cash (44:10):**
Okay. And so, how quickly can the Army Corps potentially issue its record of decision?

**Nelli Williams (44:19):**
Well, the earliest official time is August 24th, so less than a month from now. I think practically speaking, it'll be a little bit longer than that because there are several kind of sub approvals that have to happen both at the state level and through a couple different entities before they could issue a record of decision unless they kind of went out of typical process. And then they've been saying 30 to 60 days after a final EIS is when they would make a decision. They recently adjusted that to fall. But in my mind, fall starts in August in Alaska, so hard to tell what that means.

**Marvin Cash (45:03):**
Yeah, so we're talking about anywhere from middle of August to middle of October probably.

**Nelli Williams (45:09):**
Sorry, I think I misspoke. It would be August 24th, not September.

**Marvin Cash (45:14):**
It would be the earliest. So sometime between kind of towards the end of August to the end of September. Yeah. And so another thing kind of, we've talked about the administrative kind of circuit breakers. I know in kind of following the issue that Senator Murkowski has been concerned, wants a science-based approach and has kind of deferred to the process. I'm kind of curious if you've heard from her and other kind of like-minded legislators who have responded to the report.

**Nelli Williams (45:53):**
Yeah. So I think one of the folks that really wanted the process to play out and for an analysis to be done of this project in the traditional process, that process has happened. Like we're at the end of it, right? Like the impacts have been discussed in this document that was released last week.

The senator issued report language in the appropriations bill last year that said, you know what, if the issues raised by experts at the state and federal level and tribes cannot be addressed, then the permit should not issue. And we're to that point. I mean, I think we are all digging deep into the final EIS to see whether or not those questions have been answered. And our take is that they haven't. There's fatal flaws in this analysis that remain. And there's no way we should move forward with a mine based on a less than robust process.

So, I hope, I don't know, but I hope that those folks that have stood by the process will speak up in the coming weeks and say, look, Pebble has had their chance and they have not proven that this mine can be developed safely or responsibly in Bristol Bay. And we shouldn't move forward with it. That's my hope though. And I think that's what Alaskan decision makers and decision makers at all levels need to hear right now.

**Marvin Cash (47:57):**
Yeah, and to sort of collapse all of that down, what does that make the coalition's advocacy for Bristol Bay look like over the next, say, six months to a year?

**Nelli Williams (48:10):**
There's a couple angles. I think it's getting very loud on all fronts because we are on the verge of two future realities, right? Like we can either hold the line and convince this administration that this permit should not be issued. And then we get on to bigger and better conversations about Bristol Bay.

And I think that is both targeting the White House and Army Corps of Engineers and the EPA. And we know sportsmen and women in particular are important voices for them to hear from. So I would encourage anybody who cares about Bristol Bay to weigh in on that front.

And then I also think Congress, there are important voices and leaders on this. This is a national issue, an issue of national importance. And while there aren't super clear levers on what Congress can do, I think it's very important for people to be speaking up strongly on this issue. Because if we don't, we could see them get a major permit they need to advance a mine. And likely with that comes a new investor.

**Marvin Cash (49:32):**
Yeah, and I guess, in terms of taking action, if someone wants to get involved, how can they have the most impact? I know that Trout Unlimited makes it very easy and some other organizations do. But say if someone says, I'm interested, I don't support the mine, how should they advocate for Bristol Bay?

**Nelli Williams (49:55):**
Yeah, so Trout Unlimited has run the Save Bristol Bay dot org website for a long time. And that has oodles of information and ways you can engage, whether it's volunteering or writing a letter or sending an email, sharing on social media. All of those things are there. And that's your one stop shopping for how you can help Bristol Bay.

Also following Save Bristol Bay on Instagram and Facebook and Twitter are huge. And that's probably like the most, that's where we put out our rapid response, calls for help are those on social media. And then you can also find broader information on TU dot org.

**Marvin Cash (50:43):**
Yeah. And I'll drop links to all of that stuff in the show notes. And before I let you go, Nelli, so, we know we've got the sportsman community, even in the lower 48 really engaged. But what argument should we make to non-anglers and non-hunters about why they should oppose Pebble Mine?

**Nelli Williams (51:06):**
Bristol Bay is, like, it's everything we dream about when we dream about wild places to hunt and fish. And I guess I would just encourage folks that if you've been there, if you want to go to Bristol Bay, if it's a dream that you hope your kids get there someday, like now is the time to act because if we don't, Bristol Bay might not be there, the Bristol Bay we know and love might not be there in 10 or 15 years.

So that is what I would say to folks in the lower 48. And then I guess I would just urge folks to act, whether that is financially a contribution, whether it's volunteering, writing letters. It's very, very important right now.

**Marvin Cash (52:06):**
Yeah, absolutely. And Nelli, I really appreciate you taking some time today to chat with me. Thank you so much.

**Nelli Williams (52:13):**
My pleasure. Thank you.

**Marvin Cash (52:15):**
Well, folks, I hope you enjoyed that as much as we enjoyed bringing it to you. Please check out the show notes to learn more about the proposed Pebble Mine and how you can take action. And again, if you like the podcast, please tell a friend and please subscribe and leave us a review in the podcatcher of your choice. Tight lines, everybody.