IRU’s analysis & comments for Stibnite Gold Project’s FEIS & DROD
Numerous statements in the Stibnite Gold Project’s FEIS and DROD illuminate that the proposed mitigation measures may not work as designed, if even at all. Photo credit: Nick Kunath, IRU staff
At the end of October, Idaho Rivers United and our coalition partners finalized our formal objections to the Stibnite Gold Project’s Final Environmental Impact Statement (FEIS) and Draft Record of Decision (DROD) issued by the Forest Service. Through this collaborative effort, we analyzed the thousands of pages of documents and submitted objections on a myriad of issues. IRU focused on the project's impacts on fisheries and the aquatic environment. Now that the dust has settled, we are summarizing some of the critical issues we uncovered and raised within our objections.
Unfortunately, many of the issues within our objections were the same ones highlighted in previous comment periods. In particular, we are deeply concerned with the impacts on salmonids due to stream temperature increases, changes to water chemistry, alterations to critical habitat, increased sedimentation from mine traffic and associated spill risks, and a general lack of holistic analysis tying these issues together. We are also troubled by the pervasive uncertainty highlighted throughout the analysis. We understand there will always be some uncertainty in a project like this. However, numerous statements in the FEIS and DROD illuminate that the proposed mitigation measures may not work as designed, if even at all.
As a result of the project, stream temperatures are modeled to increase and remain elevated for up to 100 years or more. This estimation does not include climate change, which is expected to increase water temperatures from baseline estimates at the end of mine operations by up to 2°C. Had readily available climate change modeling been incorporated into the analysis, the timeline and feasibility for temperature reduction mitigation measures would have changed dramatically. Even omitting this critical data, Meadow Creek upstream of Blowout Creek is modeled to reach summer temperatures that meet the lethal temperature criteria issued by EPA for salmonids.
The project will dramatically alter the ground and surface hydrology of the site, negatively impacting stream flows that will ultimately decrease fish productivity during operations. Many streams will be re-routed into diversion ditches or pipes to eliminate potential contamination and reduce additional temperature increases. More than 430 acres will also contain geosynthetic liners that will inhibit natural groundwater recharge, increase surface water runoff, and potentially lower groundwater levels over time.
Throughout the FEIS, there is little to no discussion regarding potential impacts on macroinvertebrate, amphibians, or other food sources and their availability throughout the aquatic environment resulting from the relocation of streams into diversion and general habitat alterations. Considering the number of headwater streams that will be altered in this fashion, the potential impacts on the overall food web and availability from a fisheries perspective are severely lacking.
Similarly, there is no analysis regarding the potential bioaccumulation of arsenic, antimony, mercury, or other contaminants of concern that may be mobilized through the project into the food chain and potential impacts on salmonids.
Throughout the project, there will be increased project-related traffic along roads that parallel critical habitat streams, increasing fine sediment deposition. In addition to high stream temperatures, the National Marine Fisheries specifically identified sedimentation as a limiting factor impeding the recovery of Chinook salmon within the project area. In addition to sedimentation, the high volume of mine-related traffic raises concerns about the event of a fuel or chemical spill into streams that support salmonids and their habitat.
NOAA Fisheries and the U.S. Fish and Wildlife Services provided additional Endangered Species Act consultations. Both agencies determined that while there would undoubtedly be localized harm and mortality of Chinook, steelhead, and bull trout, the project would not likely jeopardize the species' continued existence. However, it is important to consider that these determinations were made in light of regional populations. For bull trout, in particular, the project impacts were analyzed in the context of the entire Upper Snake Recovery Unit population, which encompasses central Idaho, Northern Nevada, and Eastern Oregon.
While the project may not jeopardize the continued existence of bull trout in the Upper Snake Recovery Unit, it is shortsighted to assume that the local population will exist over the next 114 years of forecast impacts to repopulate the project area considering the potential thermal barriers and temporal loss of habitat that may extirpate existing populations.
We also raised the issue that the NOAA Biological Opinion, which included additional analysis, references, and recommendations absent from the FEIS, was published on October 7th, after the FEIS and ROD were published. At a minimum, the Forest Service must issue a supplemental FEIS that wholly considers the information provided in this report.
Finally, and perhaps most telling, the Stibnite Gold Project may be one of the best examples of the wrong mine in the wrong place, emphasizing the fundamental flaws within the 1872 Mining Law that governs hardrock mining on federal public lands. Despite years of engineering, mitigation measures to reduce project impacts, and promises to “restore the site,” the Forest Service determined that the no action alternative, i.e., doing nothing, would be the environmentally preferable alternative. However, even though the science is clear that there are places like the East Fork South Fork that will never make sense to construct a massive industrial gold mine, the Forest Service is bound by our archaic mining laws to move forward with a decision.
As we have said before, the fight to defend the South Fork Salmon and stop the Stibnite Gold Project is far from over. From here, the Forest Service will review the submitted objections and attempt to resolve the issue with each party before issuing a Final Record of Decision. Additionally, Perpetua must acquire many outstanding permits outside of this process before the mine becomes a reality. Many of these have already been challenged by IRU and our partners. As we continue this fight, we thank you for your support and will share ways to stay involved as the story unfolds.
