Comment submitted by J. Davis

I am writing to voice my strong opposition to the recently released draft watershed assessment for Bristol Bay Alaska because it sets a dangerous permitting precedent. It is clear that this assessment is simply a precursor for the EPA to take unprecedented action to preemptively deny permits for its targeted project-- the Pebble deposit in Alaska-- before they have even been applied for and before the project even has a plan in place. The study was rushed and did not follow standard scientific procedures and relies on "hypothetical impacts" from a "hypothetical mine" that does not account for real mitigation efforts that would be developed as part of a mine plan. Most disturbingly this premature and insufficient assessment and planned permit veto sets a dangerous precedent. Use of an preemptive 404(c) permit veto will set a dangerous precedent that will devastate an already shaky U.S. economy, and would have a chilling effect on over $200 billion in annual investment that relies on such permits-logging, manufacturing, construction, infrastructure, energy, mining and more. This watershed assessment and threatened preemptive permit denial are wholly unnecessary. The EPA will have its fair say on the Pebble project, along with other state, local, and federal agencies, through the course of the established permitting process. There is no reason for the EPA to rush to judgment before a mine plan has been submitted that will show how the company will avoid and mitigate potential impacts-that is what the permitting process is designed to do. Furthermore, there is no environmental impact made by simply allowing a project to proceed through the permitting process, but there will be devastating economic impacts from preemptively vetoing it. EPA's action in Alaska sets a dangerous job killing precedent for the entire country. Please shelve this flawed assessment- stop from issuing a first of its kind preemptive permit veto- and allow the established permit