Comment on Greens Creek Mine Expansion DEIS
The Forest Service is currently soliciting comments on a for Greens Creeks "Tailings Disposal Facility Expansion." The Draft EIS documents are available from the Forest Service, and more information is available via the Alaska Department of Natural Resources on the Greens Creek Mine in general.
SEACC's main objections to the Draft EIS are highlighted below. For more information, visit seacc.org/mining/greens-creek-mine or contact SEACC's Guy Archibald at 907-586-6942 or firstname.lastname@example.org.
Comments on the Draft EIS are due on June 4, 2012.
Send Comments to:
- Admiralty Island National Monument
Tongass National Forest
ATTN: Greens Creek Tailings Expansion
8510 Mendenhall Loop Road
Juneau, AK 99801
- Or by email: email@example.com
Use the subject line “Greens Creek Tailings Expansion”
Life of Mine Underestimated:
The Forest Service needs to take a hard look at cumulative impacts from reasonably foreseeable mine development on Monument values. When evaluating cumulative impacts from continued operation of the Greens Creek Mine to the unique ecological, cultural, geological, historical, and scientific values protected in the Admiralty Island National Monument, the Forest Service limits its analysis to a 30 to 50 year time frame. In 1995, however, Congress approved the Greens Creek Land Exchange Act, which gave Hecla “the right to explore and mine subsurface lands adjacent to the Mine within the existing non-wilderness area of the Monument, in an environmentally sound manner” for a term that could last until 2095, 84 years from now. All the action alternatives proposed in the DEIS, however, consider a life-of-mine timeline between 30 and 50 years. The DEIS does not explain why it selected this timeline or demonstrate that the expanded tailings dump can provide the predicted capacity for tailings and waste rock over the selected timeframe.
Insufficient analysis of the subsistence use of the area and Hawk Inlet:
The Forest Service relied on studies conducted before 1990 to estimate the customary and traditional use of the area by residents of Hoonah and Angoon and concluded that the use was either very limited or restricted to the mouth of Hawk Inlet. It is imperative that the forest Service conduct current community use surveys for the area and develop a compensation package for Hecla to implement in the affected communities for the loss of customary and traditional uses on lands and waters impacted by mineral development at Greens Creek. Compensation could include Hecla funding completion of the Thayer Creek hydro project for Angoon or funding the connection of Hoonah to the intertie that was extended to the Greens Creek Mine several years ago. As noted in the DEIS (at p. iv), the Forest Service has the authority to add stipulations or require additional mitigation measures in making a decision relating to Hecla’s proposal to modify its General Operating Plan.
Destruction of Salmon Habitat:
ANICLA only allows the Forest Service to issue leases and associated permits for mining purposes on Monument lands if it determines that use of the site “will not cause irreparable harm to the Monument” and requires the Forest Service to maintain the continued productivity of all salmon habitats. All the action alternatives presented in the DEIS irreversibly impact salmon streams. Alternative B calls for the destruction of 4,046 feet of Class 1 and 2 fish habitat in Tributary Creek. Alternatives C and D, call for the destruction of 1,078 feet of Class 1 and 2 habitats in Fowler Creek. Overall, these alternatives would cause permanent loss of habitat for salmon, an essential part of the local food chain for the Monument’s bald eagles and brown bears. The conclusion that this irreparable loss of salmon habitat can be mitigated by improving fish passage in Greens Creek is simply wrongheaded.
Cultural Values Underestimated:
The impacts to cultural values in the DEIS relies only on the recent past. Historically, Hawk Inlet opened up to Young’s Bay. It was an important passage way from Catham Strait to Stephens Passage. The area was utilized by clans from Juneau, Hoonah, and Angoon. The analysis did not consider any recent ground surveys that would take into account new information on isostatic rebound that shows cultural sites could be located hundreds of feet above the current sea level. We ask that the Forest Service conduct a more through ground survey of possible cultural sites. We also urge the Forest Service to consult with the Hoonah Indian Association, and recognized representatives of the Auk Kwaan.
Cost comparison of the Alternatives:
The DEIS lacks any discussion about the short- and long-term costs to HGCMC of utilizing proposed mitigation measures or the effect of these costs on the economic viability of the mining operations as required by agency regulations for mining operations within Misty Fiords and Admiralty Island National Monuments. The Forest Service needs to supplement this draft EIS to disclose and analyze these costs.
Economic Benefits Analysis Only Considers Juneau:
The Juneau-centric focus of the analysis prevents the Forest Service from fulfilling its obligation to identify and address the social, health, and environmental effects of this proposal that may be borne disproportionately by the communities of Angoon and Hoonah. We ask that the Forest Service expand the economic benefits (and impacts) analysis to include Angoon, Hoonah and Tenakee Springs.
Need for Perpetual Water Treatment:
The DEIS states that Hecla will have to actively treat the water from the tailings piles for “hundreds of years if not in perpetuity.” This need raises questions as to whether such mineral development is “environmentally sound” and protects Monument values as required by ANILCA and the Greens Creek Land Exchange Act of 1996. The present reclamation bond for the Greens Creek mine is $30,455,000 based on the 2003 Solid Waste permit and adjusted for inflation. The 2003 permit assumed water treatment would be needed for approximately 7 years after mine closure. Any lack of adequate funding could place the burden on the public should Hecla declare bankruptcy. We ask that the Forest Service require adequate financial assurances to cover perpetual water treatment.
Discharges into Hawk Inlet:
Greens Creek is allowed to discharge contaminants into Hawk Inlet under a State permit that allows for a toxic mixing zone. The DEIS does not mention that this permit was stayed by DEC pending further review and that 2005 EPA permit still governs discharges from outfall 002 into Hawk Inlet. Unfortunately, neither permit effectively monitors water quality at the edge of the mixing zone. Consequently, the agencies lack adequate monitoring data to support a finding that mining activities have not degraded water quality in Hawk Inlet and protect existing aquatic uses as required by the Clean Water Act. Furthermore, the mixing zone design relies on a physical description of Hawk Inlet over 20 years old that does not account for isostatic rebound or other recent changes to the channel. The Forest Service’s reliance on the State to protect the aquatic habitat of Hawk Inlet with a permit yet to be released is mistaken. The Forest Service needs to update its analysis in the DEIS to reflect existing conditions in Hawk Inlet and develop meaningful compensation for the long-term degradation of Hawk Inlet from the discharge and loading of toxic pollutants into this waterbody.