The Army Corps of Engineers recently released their scoping report after receiving thousands of comments from the public about the Pebble Limited Partnership's application for the proposed Pebble Mine. I provided more than 40 pages of clear, concise, relevant and specific comments regarding concerns about the potential environmental impacts from the proposed Pebble Mine. Because a computer program filtered and coded all the public comments into an electronic database it is impossible to know if my statements, which were supported with explanations, facts, and references, will be taken into consideration for the draft environmental impact statement.

Bristol Bay's wild salmon have sustained Alaska Native communities for thousands of years, providing both food and the spiritual nourishments that come from the subsistence way of life. Salmon are the linchpin of the Bristol Bay economy, supporting a $1.5 billion annual commercial fishery that employs 14,000 workers and supplies half of the world's sockeye salmon. This year, more than 60 million sockeye salmon returned to Bristol Bay.

But at the headwaters of that fishery, Pebble has proposed a 1.5 billion-ton mine with a 20-year mine life. Last winter, Pebble submitted a permit application that lacks important detail, substantive information and baseline environmental data.

Pebble has proposed a mine pit at least 6,500 feet long, 5,000 feet wide and 1,750 feet deep. The project includes an 83-mile transportation corridor with more than 200 stream crossings and eight bridges; year-round icebreaking ferry service across Lake Iliamna with two terminals; a port site in Amakdedori Bay, a site that is critical habitat for endangered beluga whales; a 270-megawatt power plant; and a 188-mile natural gas pipeline, including a 94-mile section across Cook Inlet.

Building that infrastructure and developing the Pebble Mine will industrialize a watershed of unparalleled ecological and economic value. Not only will it destroy more than 3,000 acres of wetlands, but it will also negatively impact water resources, disturb wildlife, create water, air and noise pollution, impair the commercial and recreational fisheries, and permanently alter rural lifestyles dependent on subsistence resources like salmon. More than 30 miles of salmon streams and tributaries will be destroyed.

The Amakdedori port site is adjacent to the McNeil River State Game Sanctuary and Refuge, home to the world's largest concentration of wild brown bears. Impacts on bears from the port and transportation corridor would be profound, including mortality, increased human interaction, habitat destruction, and disruption of migratory patterns.

Such significant changes to a landscape should warrant serious consideration. The U.S. Army Corps of Engineers is the federal agency tasked with reviewing Pebble's permit application. So far, their review is not robust.

The scoping report is used to develop a draft EIS that must consider the effects of this massive devastation, including: runoff, effects on groundwater, acid mine drainage, water treatment in perpetuity, spills, catastrophic failure events and releases of contaminated water. Other impacts that need to be analyzed include the loss of wetlands and salmon streams, and changes in water quality and water quantity caused by the development of the Pebble Mine.

Pebble failed to provide any information about the economic viability of the project in their application to the Army Corps. This is the largest mine ever proposed in Alaska, yet Pebble has not yet published even a preliminary feasibility study. The announcement that First Quantum Minerals will not invest in the Pebble Mine further calls into question the financial viability of this project. Without knowing the economics of the project, the Army Corps and public are unable to determine whether the project is feasible, what practicable alternatives exist, and whether Pebble will be able to meet its post-closure and reclamation financial assurance requirements.

The Army Corps must explain why thresholds of harm previously deemed "unacceptable" by the EPA are now presented in Pebble's permit application as legitimate. The lack of a detailed project description, shifting project design and lack of environmental baseline data presented a serious challenge to providing constructive scoping comments on this proposed development. Pebble's missing data — coupled with the extraordinarily short period between the close of scoping on June 29 and the expected release date for the draft EIS in January 2019 — does not provide the Army Corps with the information or the time needed to satisfy its obligations under the National Environmental Policy Act.

Given these concerns, I urge the governor, our state legislators and Sen. Lisa Murkowski to take action to suspend the NEPA process until Pebble provides the necessary economic feasibility study and environmental baseline data to inform the public and the Army Corps about the impacts, especially on the newly proposed transportation and pipeline corridor, ferry crossing on Lake Iliamna, and the Amakdedori port infrastructure.