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Critics also have argued that the EPA has no business making up mine scenarios when no mine plan has been advanced and the Pebble Partnership is still working on its permit applications. That argument is disingenuous at best. The EPA used Northern Dynasty’s own preliminary mine plans in its assessment, plus what is known about what it takes to mine low-grade ore on a massive scale. Experts in mining, geology, hydrology and fisheries twice vetted the agency’s work. EPA is in the ballpark, and Pebble knows it.

Yes, mitigation measures can reduce some risks and loss of habitat. But the fact is that a massive open pit mining operation doesn’t fit in some of the headwaters of the richest salmon fishery on Earth.

Pebble will kill salmon. We should clear about that, and not try to cover it with win-win happy talk about mining and fishing going together as if there are no adverse effects.

Dennis McLerran, the EPA’s regional administrator who led the assessment, said the agency will soon make policy decisions based on its report. Those could run the gamut from no mine to any number of conditions going forward.

We’ll stand by these criteria on the Pebble prospect: With the Bristol Bay fishery and all that it provides at stake, Pebble has the burden of proof to show it can mine while sustaining the fishery and the overall environment. If there’s any doubt, the answer to Pebble must be no.