The U.S. Department of the Interior said the following in 2009 regarding the Draft Supplemental Environmental Impact Statement for the Montanore Project:
The mine would occur within occupied grizzly bear habitat within the Cabinet-Yaak Ecosystem. We are concerned that the proposed alternative may adversely affect grizzly bears...The Montanore project may result in the permanent conversion of suitable Canada lynx habitat to non-suitable. The proposed action...may have significant adverse effects to bull trout in both the Libby Creek and the Bull River drainages.
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Alternative One is the voice of responsible Northwest Montanans who have
a creative vision for the future. We advocate accountable leadership
in government, sustainable economic growth, and preservation of the
region's natural resources for the benefit of future generations.
BOARD OF COUNTY COMMISSIONERS
LINCOLN COUNTY
STATE OF MONTANA
December 14, 2011
RE: Montanore Project SDEIS
Dear Montanore Project Review Team:
Thank you (once again) for the opportunity to comment on your analyses of the
Montanore Project, a proposed copper and silver underground mine located south of
Libby, Lincoln County, Montana. Although the SDEIS is described as the result of 'public'
comments on the previous DEIS, it appears to us, in observing the process, that it is
more of a 'caving-in' to the entrenched and inflexible power bureaucracy known as the
EPA.
There is no question of the widespread support of this project. When we weigh the positive socio-economic impact of this project against the minimal changes wrought in current land use in the overall geographic area, we cannot but agree with this support.
In terms of water quality impacts, it seems that you are pushing the hydrology model
developed by MMC, which was considered appropriate, beyond what is considered
reasonable and prudent: )=- The SDEIS suggests that the model is a reasonably conservative analysis, but in
reality now represents a worst case scenario.
Because base flows used in the model are significantly lower than calculated
7Q10 values, there is a corresponding increase in 'impacts' that are not
supported by the data previously collected. Using model base flows that
represent a condition that most likely will never occur during the life of the
project seems unreasonable and impacts and compliance should not be based
on such extremely unlikely conditions.
Your monitoring program revisions appear to be extensive, expensive, and go beyond
what is reasonable. Why collect data just for the sake of collecting data? Particularly
given that Noranda and MMC have been collecting information and baseline data for
more than 20 years and a huge amount of information is available. Requiring MMC,
now, to collect another year of data before starting their evaluation activities is
preposterous, and would unnecessarily delay the project and the subsequent economic
activity (JOBS!!). The SDEIS predicts little or no impact during MMC's evaluation phase,
so why can't any data that is missing be collected concurrently without risking a mine
caused impact?
Further, what purpose is served by requiring the monitoring of the Wanless Lake area
when the SDEIS indicates this drainage to be very different from the project area? Very
little, it seems.
Relative to the grizzly bear issues, it appears you have simply discounted MMC's
research and efforts to provide innovative grizzly integration activities, and land
purchase, with its subsequent reduction of our tax base, continues to the primary
mitigation method. Additionally, we believe your grizzly impact assessments are
excessive, particularly where the impacts are temporary (i.e., transmission line
construction).
As chief elected officials of Lincoln County, we are highly aware of the importance of
this project with respect to its potential for providing additional economic vitality and
stability for our communities — 500 construction jobs, 350-400 permanent jobs for the
life of the mine — and at the same time, we are highly aware of the need for
environmental protection assurances and impact mitigation. This project, the most
highly scrutinized and most thoroughly analyzed in the history of the Kootenai National
Forest, needs to be relieved of some of the more innocuous requirements and move
diligently to decision.
There is no question of the widespread support of this project. When we weigh the
positive socio-economic impact of this project against the minimal changes wrought in
current land use in the overall geographic area, we cannot but agree with this support.
It is important that you not allow any further unnecessary delays. We are in the middle
of a natural resource utopia, yet have watched associated industries virtually disappear
because of excessive restrictions and regulations. We need long-term industry as
envisioned in this project; without it we cannot maintain opportunities for our citizens
and their families to continue the traditional cultural pathways so long a part of our
county's history; without it we cannot maintain the needed social institutions and
services expected of local governance; without it we cannot maintain the needed
assistance to the less fortunate among us.
