Protect Yellowstone National Park: Say no to Gold Mining at the Doorstep to Yellowstone

Dear  Ms. Lane,

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 impacts of both Crevice Mining Group’s proposals for mineral exploration and mining as characterized in the Crevice Mine Project Exploration Program Plan of Operations and the Small Miners Exclusion Statement (SMES). DEQ must examine the cumulative impacts of both projects, as well as potential significant impacts on federal lands.

If approved, the  Crevice Mine Project Exploration program (project) would impart industrial-scale development on the boundary of Yellowstone National Park (YNP) and in tributary watersheds of the Yellowstone River. As the history of mining projects in Montana has taught us, mining in sulfide-bearing rock poses inherent risks to water resources and may permanently scar the landscape. Aside from these long-term impacts, even temporary disturbance may have substantial impacts for the people and animals that use lands in the project area. DEQ’s analysis must examine all of these significant impacts.

The proposed project area is located within one of the most important wildlife habitat areas in Montana, the Rocky Mountains and many would argue the earth. The project area provides crucial wildlife habitat for a wide variety of endangered species, big game animals, and other wildlife species.  Impacts to elk that heavily use the project area are a near-certainty. DEQ must also consider significant impacts to federally protected species such as grizzly bear, wolverine, and lynx. In addition to habitat loss, increased human use and improved access may amplify already problematic wildlife encounters with humans in the areas and cause additional wildlife mortality.

The agency must also consider the risk of acid mine drainage from mineral in sulfide-bearing rock. Groundwater and tributaries in the Crevice Mountain area flow directly into the Yellowstone River. Road chemicals and dewatering techniques used during previous mining operations in this area negatively impacted water quality, causing wells to be poisoned and septic systems to flood. The DEQ must consider all potential impacts to local water sources.

DEQ must examine significant impacts from road improvements. DEQ must consider potential impacts to wetlands and a stream channel within the project disturbance zone and along the 7.2 miles of required road improvements. Further, DEQ must base its analysis on complete and accurate information about road access, road improvements and road use from Park County and USFS—information that is lacking from Crevice’s exploration plan. The project will require upgrades to a minimum of 5.6 miles of county road and 1.6 miles of Forest Service roads.. The company has failed to reach agreement on road access and improvements with Park County and the Forest Service, and road upgrades likely violate the USFS 2008 Travel Plan.

DEQ must consult with the Forest Service and Park Service. Mineral exploration will impair Gallatin National Forest and Yellowstone Park resources and impact federally listed species.  DEQ must ensure that the agencies with expertise on these resources are appropriately consulted.

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