"Additionally, the draft watershed assessment is fundamentally flawed for the following reasons:
- the EPA has undertaken to study in one year a nearly 20,000 square mile area in Southwest Alaska ‐ about the size of the states of Maryland and New Jersey combined - that would need several years of diligent effort to achieve its stated goals;
- the EPA has attempted to assess the effects of a project that has not yet been finalized or undergone the rigorous permitting process required by State and federal law;
- the EPA has prepared and distributed a report that does not live up to the agency's own standards for undertaking watershed assessments, as reflected in EPA guidance and assessment activities in other U.S. jurisdictions. Specifically, the draft report: relies on a hypothetical mining project with hypothetical environmental impacts; estimates impacts resulting from only one stressor source (i.e. mining), notwithstanding Region 10 policy to address environmental risks "in a comprehensive, holistic fashion" reflects an unprecedented narrow focus on a single mining project and single policy option; and improperly adds economic analysis, and then in a biased fashion.