- the draft BBWA report suffers from a lack of sufficient data and information to support the conclusions reached, yet the report authors in many cases overlooked the voluminous site-specific data provided by PLP as part of its ' Environmental Baseline Document'
- the draft BBWA report over-estimates both the likelihood and consequence of a range of potential systems and operational failures;
- the draft BBWA report presents inappropriate and misleading case studies;
- the 'hypothetical mining scenario' presented in the draft BBWA does not employ 'best mining practices', or the alternative engineering approaches, environmental safeguards and other mitigation strategies commonly used at modern mines to avoid environmental effects.
Peer Review Panel Confirms Serious Flaws In EPA's Draft Bristol Bay Watershed Assessment Report
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