Comment on Thompson Creek Mine Final Environmental Impact Statement

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NEPA Serial Number: DOIBLM-ID-I030-2011-0001-EIS

Thank you for receiving our comments on the Thompson Creek Mine Final Environmental Impact Statement, submitted by the Idaho Conservation League and the Mineral Policy Center.

Since 1973, the Idaho Conservation League has worked to protect and Idaho’s clean water, wilderness, and quality of life through citizen action, public education, and professional advocacy. The Idaho Conservation League has a long history of involvement with mining and water quality issues. As Idaho's largest statewide conservation organization, ICL represents over 20,000 supporters who have a deep personal interest in ensuring that mining operations and reclamation are protective of our land, water, fish, and wildlife.

We have a long history of involvement in the Thompson Creek Mine and submitted extensive comments on the FEIS. Our members use the surrounding and downstream areas for hiking, hunting, fishing, camping, boating, botanizing and enjoy touring the area. We have toured the project site several times on the ground, flown over it, and toured the Broken Wing Ranch as well. We appreciate the Thompson Creek Mine Company and the BLM for having hosted us on the site visits. We have three main concerns regarding the FEIS and have specific recommendations to address these should the project proceed.

Earthworks is a national non-profit organization dedicated to protecting communities and the environment against the adverse impacts of mineral development. Earthworks has a long history of engaging in hardrock mining issues in Idaho and on federal public lands nation-wide, and we seek to promote responsible mining practices that protect public health, fish, wildlife, and clean water.

As stated in our comments on the DEIS, our primary concerns with these proposals relate to the longterm protection of water quality. We want to ensure that the water treatment plant and related infrastructure are properly engineered, that funding is available to cover costs as long as treatment is needed, and that the entities in charge of the financial mechanism have the necessary regulatory authority. We believe that the bonding calculations need to be part of the NEPA analysis and that a broader discussion of the regulatory framework is still needed.

As stated in our comments on the DEIS, we are also concerned about the lack of alternatives in the FEIS with respect to primary issues. Additional alternatives are required because the modeling provided in the EIS predicts potential spikes of a variety of Contaminants of Concern (COCs) in Thompson Creek, Squaw Creek or the Salmon River under a range of flow conditions and for prolonged periods of time that would result in numerous violations of Idaho’s antidegradation and/or federal Clean Water Act regulations (CWA Section 313 and 228). In our own scoping comments, we had suggested that the BLM develop additional alternatives that are more protective of water quality in both near and long term and that will further minimize the need for post-closure water treatment.

Lastly, the long-term stability of the Tailings Storage Facility is of tremendous concern to us and we believe that additional clarification and analysis is needed here. The FEIS should be amended to include the lessons learned from the Mount Polley tailings failure as outlined in the investigative panel’s final report1 and to prescribe any additional design features to address this information. We would particularly like to emphasize the need for an independent tailings pond review panel to assess the final design and long-term management of the facility. We feel that the Mount Polley situation represents a changed condition and warrants additional consideration. We are attaching the official analysis of the Mount Polley tailings failure with these comments.

Our specific comments are below. We would also appreciate the opportunity to discuss our comments with the BLM and Forest Service at your convenience. Please keep us on the mailing list for all public notices regarding this proposal.