Comments Needed by May 20, 2009
Forest Service Proposes Approval of New Exploration on Buckhorn

May 8, 2009

COMMENTS NEEDED by May 20, 2009

On the heels of a serious violation of the Buckhorn Mine discharge permit, the USDA Forest Service (FS) proposes to approve exploration on National Forest land to determine the feasibility of possible expansion. The FS Environmental Assessment (EA) only analyses the exploration proposal submitted by Crown Resources to have Echo Bay Exploration Inc do drilling, geophysical and soil surveys, as if it is an isolated event, having nothing to do with the existing mine. OHA believes the FS and the company should show us that they can mine in a way that protects our land and water before expansion is considered.

In the EA the FS explains that the law of the land, requires them not only to approve but also to encourage and facilitate the exploration based on laws enacted in the 1800’s. We assert that more recently laws have been enacted that set national policy for protecting the environment and ensure that information regarding decisions are available to officials and the public.

While the EA documents some of the unavoidable impacts that are associated with the proposal, they are relegated to a level of insignificance and the connection between the proposed exploration and the existing mine is ignored.

It is important that the FS hear from you!

by email:comments_pacificnorthwest_okanogan_tonasket@fs.fed.us
Send as part of email, as pdf, Microsoft Word, or rich text:
subject: 2008 Buckhorn Exploration Project

Comments should be addressed to: Forest Supervisor Rebecca Lockett Heath,
c/o District Ranger Mark Morris
1 West Winesap, Tonasket, WA 98855

Let Them hear loud and clear that:

• The EA fails to provide a realistic description of how the unadvoidable impacts of the exploration on National Forest lands would impact the amenities we value such as natural beauty, natural sounds and starry nights.
• The EA fails to inform decision makers and the public about the extent of extensive mining claims that the proponent owns or controls in the area. This is important in understanding the foreseeable future cumulative impacts.
• The EA eliminates analysis of cumulative impacts based on a conclusion that it would not be significant. The FS can not bifurcate a project so that incremental parts are not significant. The FS must look side to side, beyond what the proponent submitted and look at what is occurring and what would reasonably be foreseeable.
• The EA fails to acknowledge that the purpose of the exploration is an expansion of the mine. The EA fails to document that Crown Resources and Echo Bay Exploration are both fully owned subsidiaries of Kinross Gold Corp.
• The EA fails to describe the existing environment. If the exploration proposal is a stand alone project as expressed in the EA, then the documentation must also stand alone. The public and decision makers can not be expected to wade through the extensive files for the mine to understand the environment where exploration is proposed.
• The EA fails to be clear on where the exploration water would come from. According to the EA, one possibility is mine water. Treated mine water has higher than background concentrations of various pollutants including sulfates, nitrates, ammonia and chloride. The EA fails to document the impacts of this proposed action.
• The EA states that the geophysical survey would entail 6 lines that total 13 miles of horizontal distance. Each layout of wire and receptors is about 3,000 feet in length. A quick mathematical calculation of 6 times 3,000 equals 18,000 feet or 3.4 miles. Where does the 13 miles come from? How many receptors?
• The EA fails to contain any documentation or references to support the conclusion that the large scale Induced Polariztion is a noninvasive process.
• It is disingenuous for the FS in the EA to amend the Buckhorn Mine mitigation (WF-1) for wildlife road closure to open the road only to the invasive exploration activity while maintaining the public closure and also closing an additional 6.8 miles of the publics use of its estate as mitigation for the proponents proposal.
• The FS should require bonding for long term weed control.
• Any approval should be conditioned on full compliance with discharge permits for the mine.

Okanogan Highlands Alliance. org