Scoping Comments on Proposed Black Butte Mine
DEQ has begun the process of drafting an Environmental Impact Statement (EIS) for the Black Butte Copper Project.
We recently submitted comments regarding scoping (the initial process of determining what issues should be studied in the EIS). The scoping process gives the public, you, a chance to tell DEQ what you want included in their analysis—and why it should be included.
The scoping process is an important procedural step to ensuring our public agencies do their job and correctly assess the significance, size, intensity, and duration of a proposed activity on the natural environment; here, this means submitting comments that reaffirm the proposed Black Butte Copper Project is the tip of the iceberg as regards proposed mining in the Little Belt Mountains outside White Sulfur Spring, and that copper mining as proposed inherently threatens local and downstream water quality, fisheries, and the valuable local recreational economy.
Our comment letter reiterates Upper Missouri Waterkeeper’s long-standing opposition to the proposed Black Butte Project for the following (summarized) reasons:
- Fishery Impacts to the Smith River & Main-stem Missouri: The Tintina project has the potential to dewater and contaminate both surface water and groundwater connected to the Sheep Creek tributary, and then to the main Smith River. There is clear evidence that wild trout, and potentially some native fish species, use Sheep Creek extensively for spawning and as a cold water refuge during low, warm water conditions in the Smith. There is also clear evidence that during their life-cycle, trout migrate between Sheep Creek, the Smith River, and the Missouri River.
- Water Quantity in Sheep Creek and the Smith: The Smith River and Sheep Creek already suffer from low flows during most years, putting pressure on downstream water users and preventing the fishery from reaching its potential. Tintina plans to pump large volumes of groundwater in order to keep the underground tunnels dry during mining. This could alter flows in Sheep Creek and other streams that rely on that groundwater for a portion of their flows.
- Water Quality in Sheep Creek and the Smith: There is a significant, un-addressed potential for long-term impacts to water quality in the Smith River watershed from acid mine drainage because the Tintina Project plans to mine copper in a sulfide ore deposit. When sulfide minerals are dug up and exposed to air and water, they can react to form acid mine drainage, which is toxic to fish and other aquatic life. Once acid mine drainage develops on a large scale, it is impossible to stop, and it can continue for hundreds of years – requiring expensive long-term treatment.
- Potential Massive Expansion of the Mine: While Tintina has portrayed their project to Montanans as a relatively small and underground mine, they have simultaneously been acquiring the mineral rights to a very large tract of land directly adjacent to the proposed mine. These mineral rights are located both on private and public land, and stretch from the proposed mine site to within a couple of miles from the Smith River, and cross over several other tributaries to the Smith and Sheep Creek. Tintina is on record claiming that the “upside” of the project, or the long-term opportunities, is a 50-year mining district, that would ultimately turn the western side of the Little Belt mountains into an industrialized zone. The company currently maintains over 500 mining claims on public land totaling more than 10,000 acres surrounding its Black Butte site.
- Jobs and Economic Growth in Outdoor Recreation: Tourists spend at least $350 million annually in Montana on fishing, which is at the heart of the state’s $7 billion per year outdoor recreation economy. That economy generates over 71,000 Montana jobs. Around 7,000 people float the 60-mile permitted stretch of the Smith River annually, with the hope of connecting to a part of Montana that is still wild. The fact that the Smith is the only permitted river out of Montana’s many amazing rivers makes clear how valuable it is for our recreation and tourist economy. Economists have determined that fishing on the Smith River alone contributes up to $10 million annually for Montana’s economy, and that doesn’t include other recreational, agricultural and tax benefits it generates. These are indefinitely sustainable dollars, and they benefit real people and real jobs that would be lost if the river is degraded.