Protect Paradise Valley, the Yellowstone River and Yellowstone's Gateway Communities

Dear Ms. Gruber:

I am writing to urge the Montana Department of Environmental Quality (DEQ) to prepare an Environmental Impact Statement (EIS) to examine the potential significant environmental, cultural, and economic impacts of for Riverside Contracting, Inc.’s Opencut Mining Plan of Operation and Application on R.S. 1 submitted to DEQ on April 20, 2016.  

First, I respectfully request that DEQ extend the comment period to allow for meaningful comments from our community. The original notice to neighbors only reached a handful of people, despite the fact that this development is along Highway 89 in the Paradise Valley, a highly valued historic corridor to Yellowstone National Park. Development along Highway 89 impacts numerous business owners and individuals that depend on tourism in the Paradise Valley. Industrial development on Highway 89 creates significant public interest in Park County and across Montana and deserves careful consideration from local, state and federal officials.

Historic and Cultural Resources. I urge DEQ to consult with the State Historic Preservation Office and the Tribal Historic Preservation Office in order to consider potential significant impacts to cultural resources on this site. Many historians in our community regard this site as rich with cultural and historical artifacts.

Wildlife Corridors. The site is also a well-known wildlife corridor through the Paradise Valley. Many species migrate from the Gallatin Range through the valley to the Absoraka-Beartooth Mountains. Anecdotal and scientific evidence clearly establish this area as a key corridor for wildlife migration across the valley floor.

Public Health. The proposed asphalt plant and gravel pit are mere yards from residential homes and businesses. Several drinking wells exist very near the proposed asphalt plant. Industrial development in a residential area has the potential to significantly impact public health. Local air quality concerns could impact our most vulnerable populations, the elderly, children, and expectant mothers. Dust can travel long distances in the windy Paradise Valley and could have far-reaching impacts to local families and to the pristine waters of the Yellowstone River.

Public Safety. Millions of tourists travel on Highway 89 to visit Yellowstone National Park. Industrial traffic on Highway 89 could be a safety risk to visitors to our community and local residents that regularly travel on Highway 89.

Economic Impacts. The proposed project area is located within one of the most important tourism corridors to Yellowstone National Park. Travel to Yellowstone through our gateway communities drives our economy. Noise, dust, traffic, and pollution from industrial development in Yellowstone’s Gateway significantly impacts our local economy.

Water Availablity. DEQ must ensure that Riverside Contracting has a valid water right to meet the needs of the development.

Water Quality. DEQ must consider impacts from potential spills on the project site into neighboring properties and the Yellowstone River. The project site lies less than one mile from the Yellowstone River. Extreme weather events and heavy rains can cause settling ponds, like the gravel pit will create, to overflow and flood into nearby waterways, potentially impacting the Yellowstone River.

Federal Nexus. DEQ’s approval of the gravel pit and asphalt plant constitutes a state action that implicates federal review because of the direct nexus with the Gardiner Gateway Project and other improvements to Yellowstone National Park and therefore potentially implicates the National Environmental Policy Act (“NEPA”), 16 U.S.C. § 1531 et seq., the National Historic Preservation Act (“NHPA”), 16 U.S.C. § 470 et seq., the Endangered Species Act (“ESA”), 16 U.S.C. § 1531 et seq., and the Clean Water Act (“CWA”), 33 U.S.C. §1251 et seq.

It is imperative that DEQ make the most judicious review of the proposed gravel pit and asphalt plant. The wildlife, waterways, way of life and economic prosperity of this region –including the world’s first national park – are at stake.