EARTHWORKS

Comments to the U.S. Army Corps of Engineers regarding Montanore's 404 permit application

Comments to the US Army Corps of Engineers regarding Montanore’s 404 permit application
Earthworks and Idaho Conservation League request the Army Corps to deny the permit

Published: February 14, 2012

By: Earthworks, Idaho Conservation League

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From the comments:

The Army Corps of Engineers (ACE) should deny the proposed Montanore 404 permit because it fails to meet the 404b(1) guidelines, and insufficient NEPA analysis has been completed to understand the impact of the proposed Montanore Project to waters of the U.S., threatened and endangered species, water quality, the Cabinet Mountains Wilderness, and other important resources as required by NEPA and the CWA.

The proposed project fails to comply with the 404(b)(1) guidelines because,

  1. it will contribute to violations of water quality standards,
  2. the direct, indirect and secondary impacts of the project will result in the destruction of designated critical habitat under the Endangered Species Act, and the possible extirpation of bull trout in important bull trout recovery streams,
  3. the direct, indirect and secondary impacts of the project will significantly degrade waters of the U.S., including Outstanding Resources Waters within the Cabinet Mountains Wilderness Area and 3 1⁄2 miles of headwater streams in the Libby Creek drainage,
  4. it doesn’t reflect the Least Environmentally Damaging Practicable Alternative (LEDPA), and,
  5. it fails to meet the no discharge effluent limitation guidelines for copper mines that use froth flotation mills.

The proposed permit also fails to comply with Subparts C, D, E and F because it doesn’t provide sufficient information on the potential impacts to the physical and chemical characteristics of the aquatic ecosystem, the biological characteristics of the aquatic ecosystem, special aquatic sites, and human use characteristics. The proposed permit fails to comply with Subpart H because it fails to sufficiently analyze or incorporate measures that would minimize the adverse effects, including a liner for the tailings impoundment.

Tagged with: water pollution, montanore, montana, mine waste, idaho conservation league, fill, 404c

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