Proposed Fording River Mine Expansion

RE:  Propose Glencore Mine Expansion of the Fording River Mine

The Panhandle Chapter of Trout Unlimited (PCTU), based in northern Idaho, is comprised of over 250 members.  PCTU is committed to the Trout Unlimited mission to protect, restore and sustain cold water fisheries and their watersheds that sustain them.  The Kootenai River watershed, headwatered in British Columbia, supports highly valued native fish populations and sport fisheries.  Fish populations in the Kootenai River in Idaho include native species that are protected under the Endangered Species Act (U.S.), and other native fishes which provide valuable sport fisheries and are the focus of other conservation efforts. Because water quality science, decisions and management in British Columbia affect cold water fisheries habitat, water quality, and populations downstream in Idaho, we offer the following comments on the proposed Fording River mine expansion:

It is our understanding the proposed mine expansion would open up nearly 5,000 acres (nearly 2000 hectares) to mine development.  Coal mining operations in the upper Kootenai River basin are already responsible for elevated selenium levels in the Kootenai River. Selenium concerns exist downstream on the Kootenai River into Idaho, where water quality studies have identified elevated levels high enough to pose concerns about negative impacts to reproductive success and health of native fishes, including federally listed (“Endangered”) Kootenai River white sturgeon.  Selenium can and will negatively impact Kootenai River salmonids (bull trout, rainbow/redband trout, westslope cutthroat trout, kokanee, and mountain whitefish) as well as their associated sport fishery.  Burbot, subject of collaborative efforts to restore a fishable population, are also at risk.

The Kootenai Tribe of Idaho, in collaboration with Idaho, Montana, and British Columbia fish and wildlife agencies, federal agencies, and the local community have put considerable emphasis on recovering sturgeon, restoring burbot, and enhancing native salmonid populations.  The river supports a popular and productive – and economically important - trout fishery in both Idaho and Montana.

Selenium levels have been assessed in mountain whitefish captured during population surveys in the Idaho reach, downstream from the Montana border.  The only meaningful source of selenium inputs to the Kootenai River are upstream, primarily, if not entirely, from Canadian coal mining operations. The U.S. Geological Survey conducted the contamination assessment, which identified selenium concentrations in mountain whitefish eggs ranging from 11.6 to 24.8 mg/kg, with 75% of the samples exceeding the 15.1 mg/kg criteria considered unsafe.  Bull trout, burbot, and white sturgeon all have life expectancies like, or in excess of, that of mountain whitefish, and generally feed further up the food chain, suggesting they are at high risk for bioaccumulation of selenium.  Rainbow and cutthroat trout also tend to feed higher on the food chain than whitefish, also suggesting they are at risk for high selenium accumulations.

The International Joint Commission (IJC) has been engaged in developing recommendations to address mining pollution in the upper Kootenai watershed.  It is our understanding these efforts have incorporated both Indigenenous knowledge and modern scientific studies in a collaborative fashion.  We strongly recommend no action be taken on permitting mine expansion until this effort is completed, and any mitigation efforts and/or necessary limits on the scope of mining can be assessed and incorporated.  We strongly recommend that current water quality standards at the international border (BC, Montana, Idaho) for selenium be met prior to permitting additional mining activity.

Fisheries restoration efforts in the Kootenai River basin have been remarkably successful, largely as a result of across boundaries and borders collaborative work in the field and in the halls of government where policies and regulations are determined.  We urge regulatory authorities to continue to work in that spirit to ensure the Kootenai River will be sufficiently protected to meet the needs of all of the sovereigns and stakeholders engaged and dependent on the Kootenai River and its fisheries before any new mining is permitted.

Thank you for considering these comments and recommendations.

Sincerely,