In September 2012, Pebble Watch interviewed Todd Bryan, senior associate with the Keystone Center, about its role organizing science panel reviews of Pebble Limited Partnership's Environmental Baseline Document (EBD). This Q&A provides detailed answers from Bryan regarding the panels. A companion story is in the October 2012 issue of the Pebble Watch newsletter.
Has Keystone ever taken on a dialogue of this type/size?
This (type of dialogue) has never been done, as far as I know, any place in the world. We’ve done a lot of dialogues, but there are several ways this is different. One is the sheer scale of it. This is probably the largest resource development project currently anywhere in the world. In terms of the amount of information/data, it’s fairly significant in size. What is really unique also is that the industry was willing to do it. That’s very rare. When I talk to people at EPA who are interested in mining issues, who study mining projects in the U.S. and other parts of the world, they are blown away by the willingness of the mining company to do it. They say, “They are really letting you do this?”
Why does Keystone think this process is important? What is it trying to accomplish?
The state and federal permitting and regulatory process is all about the baseline studies and evaluation of the mine plan. That’s what the regulatory authorities are required to look at. What we’re trying to do is help inform people about that process, not through political spin or polarized spinning of information to try to influence people in any way about the mine or the permitting process or the regulatory approach, but to help them hear thorough, objective, impartial science that they need to make those decisions.
The state, the congressional delegation, the governor and people in the state Legislature want to let this thing go through the permitting process so that it can be evaluated by state and federal agencies. If they do that, it seems this Keystone dialogue is important.
What will the panelists be evaluating?
We’re looking at pure science – not looking for public opinion. We’re asking “What do you know about the baseline conditions? Knowing what Pebble has released, did they do a good job of assessing it or not?” From a scientific perspective, no one knows whether that (EBD) is credible. The reason we started there is because all the decisions Pebble will make about whether or where to build the mine come from the baseline studies and the drilling exploration. That all goes into the mine plan. Baseline data is also used to determine risk factors, seismology, whether the rock composition is producing a lot of acid mine drainage. They have to really understand that in order to decide to go forward or not.
How do you ensure panelists are independent?
We’re not trying to put together a science panel that’s going to lead anyone in a particular direction. Panelists’ reputations and the reputations of their research institutions are all they have. They are doing good, sound science in order to preserve their professional reputations. They don’t have a stake in (the mine development).
Scientists need to be impartial. The reason the scientific method is so important is because it’s sort of a check and balance against your values and personal feelings getting too close or too involved in your science. Scientists aren’t sort of naturally objective, but they are comfortable with this scientific method, and the scientific method helps them remain objective.
We went to the National Research Council and talked to them a lot about how they would go about doing this. Keystone Center had done it before, but not in a situation where it would be scrutinized as carefully. We basically followed the NRC guidelines. We created a peer review method, we don’t pay scientists, we make sure process is transparent, and we build in these steps so that people can feel fairly confident that it’s being done in a credible way.
When we selected our Science Advisory Committee, on the geology, geochemistry, and water quality side, we wanted scientists who really understood mining issues. For other topics, we wanted people who really understood Alaska. This committee has been working for three years. The committee members know the specialization we’re looking for. We created a pool of candidates and then decided we would eliminate any scientists who worked for a regulatory agency or agency that would be commenting during the permitting process, or an agency that was actually a stakeholder.
We don’t want scientists to have any record at all of having taken a position on the mine. That would call into question their objectivity.
What tips do you have for participants on how to get the most out of the session in terms of questions to ask?
The question on my mind would be “Have you considered x or have you considered y… For example, I think there’s a big gap in baseline analysis of public health questions. They have not looked at existing cancer rates within the region. If they built the mine and then 10 years later there were greater incidences of some kind of cancer, they would have nothing to go back and measure it against. So examples of questions could be: Do you really know how many fish are here? Do you really know enough about the seismology - to take the next step - to plan a mine, monitor a mine and determine the risk to a certain population?
There’s another panel you’re planning that will address the mine plan. Tell us about that.
The mine plan should be made public well in advance of our final panel so that people will have a chance to review it. The panel would be six weeks or so after that. We aren’t sure exactly how the third panel will look, but there will be three parts to it:
How can the Keystone dialogue really be legitimate if the science panelists weren’t given the data to do any reanalysis of it?
Pebble wanted to give us the raw data, but we only wanted information that was publicly available. Pebble didn’t want to release the data publicly, so that was an issue. We figured out how to unencrypt the password and extract the data so the scientists could look at it and see if they come up with the same results.
How has Keystone incorporated traditional knowledge into the panel process?
We’re trying to figure out how to best do this, and haven’t come up with a very good answer. There’s a chapter on traditional knowledge in the baseline studies. We want to find a scientist to review the chapter who can evaluate the chapter like the other scientists are evaluating the other chapters. We were hoping to find an Alaska Native familiar with traditional knowledge, but have had a really hard time finding someone. Not because it’s Pebble, but we haven’t found anyone with the time to do it. We have asked a number of people, have gotten lots of great advice, great recommendations, but haven’t been able to find someone who can actually do it … to review the sufficiency and credibility of that chapter.
What will ultimately come out of these panel discussions?
We will end the panel discussions by asking if they have any recommendations for further study. For example, if there’s a discrepancy between Nature Conservation science and Pebble science, a panel member might say, “You guys have to reconcile that.” If there’s a gap in the data, then they might say, “We don’t think you did enough field samples, or we think you jumped to conclusions.” They may say, “We don’t think the science is rigorous… enough to use for the purpose for which it’s intended.”
If panelists make recommendations, I don’t know if they will be consensus/majority or individual recommendations. The baseline chapters are very discipline-focused. Usually in peer review you would have a double-blind review, where reviewers/authors don’t know who each other are. In this case, we can’t do that. There is some overlap where we will get some discussion of more than one scientist. But typically one person is reviewing a body of work.
It’s up to Pebble whether they follow any recommendations. Pebble has decided what they think is relevant to the permitting process (NEPA). Pebble has said they are entirely open to starting recommended research, but also don’t want that to impede their ability to go forward through the permitting process.
About Pebble Watch
Pebble Watch is an impartial, educational and fact-based initiative of the BBNC Land Department to disseminate information regarding the proposed Pebble Mine project to BBNC shareholders and interested parties.