Thank you for the opportunity to submit comments for consideration on the completeness review of the permit application submitted by Tintina for the Black Butte Project on December 15, 2015.
State law and regulations outline the information that applicants must submit to the Montana Department of Environmental Quality (DEQ) in its permit application (82-4-335(5) MCA). There are sections of the mine plan, baseline data and technical review that are missing, incomplete or under revision. These gaps have significant implication for the design, construction and management of the proposed mine, and the resources at risk. The comments below include:
- a list of missing documents/information identified in the permit application,
- a summary of the primary inadequacies, and
- a section by section review of issues.
We also incorporate by reference the comments by technical experts Tom Myers, Dave Chambers, Jim Kuipers, Kendra Zamzow, and Ken Knudson, submitted by Montana Trout Unlimited. The Smith River is an unparalleled resource that deserves the most rigorous review. We appreciate DEQ’s thorough attention to this project.