"We do have concerns of course with the fact that because this is theoretical, because you don't know exactly how it's being built, you really can't evaluate with any degree of specificity what the potential effects are associated with that," said Dr. William Stubblefield, a senior professor at Oregon State University and an expert in environmental toxicology. " It doesn't contain a lot of detail about how mitigative strategies could and potentially will reduce exposures."
University of British Columbia professor of mine engineering and noted expert on sustainable mineral development Dr. Dirk van Zyl agreed: "I don't think as given that this scenario is - it's neither realistic or sufficient."
"Probably my biggest concern is the (EPA's) idea of using good practice versus best practice. I cannot see looking the people in the eye and say 'Sorry guys, I've used good practice, I don't care about best practice.' And to me that is really not the way that any mine in this scenario would be developed."
Dr. John Stednick, a watershed science professor from the University of Colorado, said the draft BBWA report does not achieve a sufficient standard of scientific credibility or completeness for the EPA to consider a regulatory action under the Clean Water Act. "The document ostensibly was used or going to be used to determine if there would be a waiver under the 404c provision of the Clean Water Act," he said. "And it does not begin to address that, nor can we make a conclusion or an inference whether it does violate the 404c provisions."Stednick also said the speed with which the EPA developed the watershed assessment is a concern: "Many comments yesterday were on the timing of the document, and I think it would be advantageous for the credibility of the report for EPA to address it." Peer reviewers took exception to the EPA's risk characterization of various 'failure' scenarios at a modern mine developed in southwest Alaska, as well as the draft BBWA report's attempt to quantify the consequences of such hypothetical failures. "I was unpersuaded by the statistical probabilities that were assigned to various scenarios, like the possibility of a TSF (tailings storage facility) failure," said Dr. Charles Slaughter, an adjunct professor at the University of Idaho and expert in watershed management. "You know that was just hogwash." Similarly, Dr. Paul Whitney, a consultant from Portland, Oregon with an expertise in wildlife ecology and ecological risk assessments, said the environmental effects EPA predicted as a result of a potential TSF failure were not credible. "How did they figure that out?" he said. "It's just beyond me. How was that conclusion reached? And if such a conclusion was possible for subsistence resources on the data available, why couldn't such a conclusion be reached for sports fisheries and commercial fisheries?" Whitney and other reviewers also expressed concern about the many errors of fact, omission, calculation and citation in the draft BBWA report . "If I'm an ecologist and I can pick this stuff up, in errors in the papers that are cited, and then the inconsistencies from the appendix into the assessment, I just wonder how many more errors have been made." Although the independent Peer Reviewers submitted preliminary comments on the draft BBWA report to EPA several weeks ago, their comments have not been publicly released. The panel of experts met behind closed doors following last week's public hearing to further discuss their recommendations for improving the quality of science and sufficiency of analysis presented in the draft watershed assessment. It is expected that a summary Peer Review report, as well as each reviewer's individual recommendations, will be made public in the fall.