Our organizations’ members live, work and recreate in the region, and are deeply concerned about the direct, indirect and cumulative effects of the proposed Rock Creek Mine on the Cabinet Mountains Wilderness, Outstanding Resource Waters, the lower Clark Fork River watershed, the fish and wildlife that rely on these resources, and the quality of life in the region.
The Cabinet Mountains Wilderness Area is one of the first ten areas protected by Congress. This 93,000-acre gem remains the sole wilderness area in the 2.2 million-acre Kootenai National Forest.
The Draft Supplement Environmental Impact Statement (SDEIS) for the proposed Rock Creek Mine identifies substantial impacts to the Cabinet Mountains Wilderness Area, Outstanding Resource Waters, lower Clark Fork River watershed and the fish and wildlife that rely on these resources, including:
- Dewatering of wilderness rivers, lakes and streams (Outstanding Resource Waters)
- Harm to threatened fish and wildlife species
- Risk of failure from outdated and dangerous tailings dam design along the Clark Fork River
- Subsidence of underground tunnels
- Potential for acid mine drainage or other harmful discharges
The cumulative effects of the proposed Rock Creek Mine and Montanore Mines would fundamentally and forever alter the Wilderness Area and the ecosystems it was set aside to protect.
These impacts are incompatible with maintaining and protecting the Outstanding Resource Waters, fish and wildlife habitat, recreational uses and other significant values for which the Cabinet Mountains Wilderness Area was established.
The DSEIS includes new hydrologic analysis on the effects of groundwater dewatering, yet fails to provide adequate data on the effects to wilderness rivers and streams and the aquatic life that they support.
The plan for the paste tailings storage facility is outdated and the failure modes effects analysis demonstrates that it presents an unacceptable risk of failure. This analysis presents new information that necessitates a new look at alternatives for mine waste disposal, including backfill.
We appreciate the opportunity to comment on the proposed Rock Creek Mine, and we urge the Forest Service to deny the permit, based on its failure to provide adequate data, analysis, or mitigation measures.
