Public comment on graphite one mining
A public comment period is open now to comment on the proposal to open an area outside of Brevig Mission up to mining by Graphite One. Public Comments are due by October 31.
Comments can be emailed to Gregory.j.mazer@usace.army.mil with the subject: Public Comment POA-2018-00210
Some background on the project
Graphite One, a Canadian company, proposes to build an open pit mine with a 1,176-acre footprint. Each day, this mine would deliver up to 11,000 tons of ore and handle 35,400 tons of waste. The mine also proposes to not only build a private access road from mile 30 of the Kougarok Road through Mosquito Pass to the mine site but also to build an access ramp for construction staging along the edge of Imuruk Basin.
Besides the mine pit, the proposal calls for a processing plant, a waste management facility, a water treatment facility, a power plant, fuel storage, explosive storage, a helipad and roads, administrative facilities, warehousing, a crusher and a mill, among other facilities. Graphite One proposes an open pit mine that would operate year-round.
The purpose is “to mine graphite and process the graphite into commercially viable ore concentrate for transport to the Port of Nome via a new 17.3-mile gravel access road and the existing Seward Peninsula public road system. The ore concentrate would be shipped out of Alaska for further processing and manufacturing of Coated Spherical Graphite, which would supply material needed for electric vehicle lithium-ion batteries and energy storage as well as other high-grade graphite products.”
Please Request the following Actions:
Extension of the public comment period from 30 days to at least 120 days, to ensure that all affected communities and Tribal governments have adequate time to review the project materials and provide input.
A full Environmental Impact Statement (EIS) in place of the currently proposed Environmental Assessment, due to the scale, duration, and potential risks of the project.
A public hearing conducted by the U.S. Army Corps of Engineers within the region, to allow community members, Tribal representatives, and local organizations to formally express their concerns and have them included in the public record.
Issues you can address in your public comment
Inadequate opportunity for affected communities to participate
The reduced public comment period of 30 days is not long enough for communities to meaningfully participate. Usually these public comment periods are 120 days.
No public hearings have been scheduled during the 30-day window.
People in Brevig Mission and Teller have limited access to internet. The only truly inclusive way for them to make comments is in person. However, no in-person meetings have been scheduled in their communities.
Many residents remain unaware that the public comment period is currently open and scheduled to close on October 31, 2025, which provides limited opportunity for meaningful engagement and participation.
Lack of legally required consultations with local Inupiaq communities
The Native Village of Brevig Mission, and the Traditional Councils of Teller and Mary’s Igloo requested a government-to- government consultation with the Department of Defense in October 2023 and in July 2024. During a Zoom meeting more than a year later, the department finally acknowledged that no consultation had occurred, but the tribes report they never received the promised meeting notes or any follow up.
In July 2023, Graphite One announced that the Department of Defense awarded the company a $37.5 million technology investment agreement grant to accelerate Graphite One’s project feasibility study. Therefore, the Department is directly supporting a land-disturbing project that will inevitably affect tribal interests in the area. Such a decision requires tribal consultation that happens early enough for the “tribal government provide meaningful comments that may affect the decision.” Despite that, the Department failed to fulfill its obligation to consult with the impacted tribal governments
The feasibility study mentions they do not recommend working with the local tribes, despite requests for government to government consultation.
Local communities do not support the mine
Both the Native Village of Brevig Mission and the Native Village of Teller have officially expressed opposition to this project. Their positions reflect the deep concern many residents share about potential harm to subsistence resources, water quality, and the long-term wellbeing of the land and people.
The mine could harm subsistence resources and cultural practices and resources
Imuruk basin the surrounding lands are used by the local communities for subsistence activities including fishing, hunting, and berry picking.
Many community members have fish camps around the Imuruk Basin.
The communities of Brevig Mission and Teller depend on the salmon that pass through Imuruk basin and spawn in the rivers and creeks that drain in the basin. Any leaks or spills of wastewater in the mine could harm the waters the salmon depend on. The top 5 operating hardrock mines in Alaska severely underestimated the amount of spills that occur during transport.
Blowing dust would affect the waters, as well as subsistence resources including berry bushes and fodder for moose and other species.
The access road will cross anadromous fish streams 10 times. Any spills from the ore trucks or washouts due to flooding (which are frequent on roads in the Seward Peninsula) could harm these streams and the salmon that spawn in them.
The mine activities will be loud and non-stop, as the mine will operate 365 days per year, 24 hours per day. This will affect animals in the area. Residents of Nome reported they could hear the mining activity of Graphite One all the way from Pilgrim Hot Springs.
The mine could harm an area that has significant cultural value
Brevig Mission holds a summer youth culture camp in Imuruk Basin.
Archeologists have identified twenty eight cultural sites (both prehistoric and historic) in the impacted area
Impact to public health
Graphite One plans to mill and burn the ore to concentrate it prior to shipping, releasing graphite into the wind near a lagoon many families depend on for potable water. Graphite dust makes water undrinkable.
Mining activities may also release toxic substances from the earth. Ore deposits are often associated with arsenic, lead, mercury and other toxic metals which negatively impact health.
Impact to wetlands, waters, and fish
The ground naturally contains sulfides that, when disturbed by mining, will create a significant risk of acid drainage that will require long-term management “in perpetuity.” This means that, like the Pebble Mine, waste would have to be managed farther into the future than nuclear waste.
Acid mine drainage is already expected due to the conditions of the area. As sulfuric acid is made, it dissolves rock around it, releasing metals that were previously bound up as solid ore. Elements that make up the rock and mineral ore are released in a dissolved form into groundwater or surface water. Initially when acidic water leaves a mine area, the streams or ponds it enters are impacted by low pH and anoxic kill flora and fauna in the watershed near the discharge.
Graphite One will permanently discharge fill material into waters including more than 414 acres of wetlands, permanently eliminating 381 acres of waters and wetlands
Treated wastewater will be discharged into Glacier Canyon Creek. If anything goes wrong with the treatment system, untreated wastewater will enter the creek and then flow into Imuruk Basin.
In particular danger from blowing dust and wastewater leaks are the 8 anadromous streams flowing into Windy Bay, all of which are within 3 miles of the mine.
Other environmental impacts
Tailings dams failures are not uncommon, and since they came into use in the early 1900s, tailings dams have failed at a rate that is significantly higher than the failure rate for water supply reservoir dams
There are three threatened species in the area
Polar Bears, whose critical habitat habitat includes the Imuruk Basin
Steller’s Eider which is known to use coastal habitats at and near Port Clarence, approximately 30 miles from the mine site.
Spectacled Eider, which is known to use coastal habitats at and
near Port Clarence, approximately 30 miles from the mine site.
Mine permitting has been rushed so much that the environmental review is incomplete and inadequate
Originally, it was estimated that the environmental review process would take 2 years. However the U.S. Army Corps of Engineers reduced the scope of the review, despite the company’s plans to expand the size of the mine.
“These expedited reviews, said Hal Shepherd, a consultant who works with tribes on water policy, turn consultation from a meaningful process into a bureaucratic checkbox.”
Many places in the permit state that the relevant environmental studies are “not complete.” The Army Corps of Engineers cannot make a wise decision about the permit without all the information. The incomplete information includes:
The total extent of jurisdictional waters that would be impacted by the discharge of fill from the mine
Whether or not the mine would affect the three threatened species in the area (polar bear, spectacled eider, Steller’s eider)
Whether or not the mine would affect essential fish habitat for five species of salmon
