According to the SDEIS, “none of the action
alternatives would comply with KFP direction on threatened and endangered
species that applies to the grizzly bear” (p. 510, Vol 1). The obvious question
here is why, then, is the Kootenai Forest Service considering any of the
alternatives?
Grizzly
Bears
The authors of the document bandy about a plethora of
pseudonyms in an effort to soft-pedal some of the appallingly invasive effects
that a plan such as the Montanore proposal would wreak on a thriving ecosystem,
but those describing dangers posed to the threatened populations of the
Kootenai National Forest and Cabinet Mountains Wilderness are some of the most
insidious.
We firmly believe that if Montanore Minerals Corp. and Mines Management, Inc. are serious about obtaining the permits necessary to pull over one billion dollars in heavy metals profits from the Cabinet Mountains, these for-profit entities must pay the price of preserving the natural environment.
On page 464 of the document, the proposed decimation
of 2,054 acres of spring grizzly habitat near Howard and Miller Creeks is
described as “reduce[d] effectiveness.”
A habitat cannot by nature strictly be termed as “effective.” It simply exists, and if a Montanore earth
mover sweeps it off the face of the planet, it ceases to exist.
On page 495 of the document, the authors explain that
“new displacement effects to undisturbed grizzly bear habitat would range from
6,117 acres in Alternative 3C-R to 8,860 acres in Alternative 2B. Additional
displacement effects to currently affected grizzly bear habitat would range
from 6,385 acres in Alternative 3C-R to 9,769 acres in Alternative 4E-R. The majority of displacement effects from all
combined action alternatives would be due to helicopter activities.”
First of all, how can there be “displacement effects”
to habitat? Will the choppers pick up
squares of habitat and move them somewhere else? Obviously, the language in this section is
meant to further confuse and distract the reader from what is actually being
conveyed.
The above quote, in plain English, is saying that the
Montanore proposal would potentially degrade a total of over 18,000 acres of
National Forest where threatened grizzly bears make their homes. Helicopters employed in installing power
lines would cause the bears to flee their protected environment in the Bear
Management Units established by federal authorities as a measure to prevent
unnatural bear deaths.
We would like to know how a government agency charged
with protecting threatened and endangered species would consider such
wide-spread destruction of the grizzly bear species in the National Forest.
We call for DEQ to change its preferred power line
plan. Put the power lines underground along an established roadway – Fisher
Creek Road -- and save untold acres of established grizzly bear habitat. It is
as simple as that.
No federal official has the authorization to allow the decimation of any species, and we strenuously oppose any provisions being leveraged by KNF that would allow this to take place, for any reason, but especially not for the purpose of facilitating an environmentally destructive, for-profit mining operation.
Bull
Trout
Bull trout have been on the federal threatened species
list since 1998. In 2005, Libby,
Poorman, Ramsey, Rock and West Fisher Creeks have been designated as critical
bull trout habitats, as stated on page 131, Volume I of the SDEIS. The fatally
flawed Montanore proposal threatens the survival of this fish species in terms
of the sediment that would enter their habitat from power line corridor
run-off, water pollution from chemicals and hard-rock drainage the mine
operation would emit into the watershed, severe “dewatering” of critical trout
habitat due to Montanore’s super-consumption of this life-sustaining resource,
and blockage of pathways that allow bull trout to reach spawning grounds.
If avoiding destruction of old growth habitat, denning habitat, and other threatened species habitat along the preferred alternative D-R transmission line corridor means paying a higher price to have the power lines installed underground along the already-established Fisher Creek Road route, then MMC must do so.
The “irretrievable commitment of resources” described
on page 255, Volume I of the SDEIS would render Rock Lake 100 feet lower than
its current level in perpetuity.
Predicted levels in the base flow of upper Rock Creek and the east fork
of the Bull River, spawning grounds for threatened bull trout, would be 100%,
according to the document (p. 250).
Partial recovery of water flow in these waterways would take more than
1,000 years. Bull trout populations
would not survive, period.
“Section 7 of the Endangered Species Act requires
Federal agencies to insure that any action authorized, funded or carried out by
them is not likely to jeopardize the continued existence of listed species or
modify their critical habitat.” (http://www.fws.gov/laws/lawsdigest/ESACT.HTML)
No federal official has the authorization to allow the
decimation of any species, and we strenuously oppose any provisions being
leveraged by KNF that would allow this to take place, for any reason, but
especially not for the purpose of facilitating an environmentally destructive,
for-profit mining operation. The statement that “ESA compliance would be
assured through Section 7 Consultation” on page 511 of the SDEIS, Volume I, is
not acceptable given what is at stake.
Again, we challenge the agencies to explain why a
for-profit corporation would ever be given permission to further diminish a
threatened species. Nebulous plans for
mitigation and unspecified consulting activities are not acceptable
answers. Once the bull trout in the
Kootenai National Forest and the Cabinet Mountains Wilderness are further
diminished or decimated by environmentally destructive mining activities, the
damage is irretrievable. We adamantly
object to any actions the agencies might take to allow further degradation of
this fragile species.
Canada
Lynx
We believe that the data upon which the SDEIS bases its conclusions regarding endangered Canada lynx is flawed, outdated, or both.
In a blatant inaccuracy, the SDEIS contends in its
section on environmental effects expected by the high-voltage transmission line
alternative C-R, that the “impacts to lynx on other private lands would be
minimal because they do not provide suitable lynx habitat” (p. 519, SDEIS, Vol
I).
Because this transmission line alternative places
power lines only a few hundred feet from our property line, we have first-hand
observational knowledge that our property and the surrounding environs do
indeed comprise prime Canada lynx habitat and that this power line alternative
would most certainly further threaten this fragile species. In the absence of current scientific data
from the KNF, we believe that our observations are germane to the lynx
discussion.
According to the USFS Canada Lynx
Conservation Assessment and Strategy document, “Lynx occur in mesic coniferous
forests that have cold, snowy winters and provide a prey base of snowshoe hare (Quinn and Parker 1987,
Koehler and Brittell 1990, Koehler 1990, Koehler and Aubry 1994, Mowat et. al.
2000, McKelvey et. al. 2000b, Ruggiero et al. 2000b). In North
America, the distribution of lynx is nearly coincident with that of snowshoe
hares (McCord and Cardoza 1982, Bittner and Rongstad 1982).
"Snowshoe hares were also found to
be most abundant in densely stocked stands of lodgepole pine, and ground
tracking indicated that lynx activity was concentrated within areas of high
hare activity”(p. 46). “In summary,
primary vegetation that may provide lynx habitat in Montana west of the
Continental Divide is subalpine fir forest associations [habitat types],
generally between 1,220 - 2,150 m (4,000 - 7,000 feet). In extreme northwestern
Montana (Kootenai National Forest), primary vegetation may include
cedar-hemlock habitat types intermixed with subalpine fir habitat types that
receive heavy snow accumulation” (p. 47).
First of all, our property is located
within this elevation range, and contains the requisite stands of lodgepole
pines as well as subalpine fir forest, plus cedar and hemlock, often densely
stocked. Most importantly, we have a
significant population of snowshoe hares, as verified by hundreds of tracks
visible in the heavy snow accumulation and also by our actual hare sightings.
Our property and the surrounding areas, most particularly the acreage along the
proposed Miller Creek transmission line corridor, does indeed comprise prime Canada
lynx habitat that would be destroyed should construction on this power line
corridor be permitted to proceed.
We believe that the data upon which the
SDEIS bases its conclusions regarding endangered Canada lynx is flawed,
outdated, or both. Consequently, we
vehemently insist that before any permits are issued that allow Montanore
Minerals Corp. to begin construction of high-voltage power lines under
alternative C-R, verifiable, scientific
data be collected, on-site, that depicts a more accurate picture of the
existing lynx population in the affected areas and presents a plan that will
not further threaten this fragile species. DEQ must reevaluate its designation
of the preferred power line alternative in light of verifiable information that
locates Canada lynx throughout this region.
“Most of these activities affect lynx
habitat by changing or eliminating native vegetation, and may also contribute
to fragmentation. The main effects of leases and mines on lynx are probably
related to the potential for plowed roads to provide access for lynx
competitors, particularly coyotes.” (http://www.fs.fed.us/r1/wildlife/carnivore/Lynx/lcas.pdf, p. 99) Because above-ground
power lines placed along the Miller Creek corridor would require regular
maintenance and repair, and because the only way to access Miller Creek road
during the winter months would be either by helicopter or plowing the access roads,
this placement of power lines would further adversely affect the resident
Canada lynx population in the area.
(continued at right)
Written responses from the 
of Montana’s Water
Quality Act nondegradation provisions,” and the pollution projections for
pristine area streams that include toxic levels of manganese, antimony,
nitrate, metals and dissolved solids. The
SDEIS does not detail any proposed mitigation measures for this pollution.
Montanore Minerals Corporation proposes stringing
high-voltage power lines through the Kootenai National Forest in a 16 mile
long, up to 200 foot wide cleared corridor. The currently “preferred” route
starts at Highway 2 and runs along Miller Creek, traversing old growth forest
as well as threatened species and big
game habitat. 
Alternative One
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Lincoln County Funds Bear Count to "Help Montanore"
