Water Rights - The Fatal Flaw
As you know, this is not the first proposal to mine gold out of Buckhorn Mountain. A proposal by Battle Mountain Gold Co. (BMG) was rejected, in part, because of its impacts to the streams that originate on and surround Buckhorn Mountain. The Pollution Control Hearings Board (PCHB) found that no water is available for new uses from the streams originating on and surrounding Buckhorn Mountain. Those streams are either fully appropriated by existing water rights, or are subject to binding recommendations from the Washington Department of Fish & Wildlife which state existing stream flows must be maintained to protect fisheries.
The current mine proposal would require water and would alter the hydrology of Buckhorn Mountain (and its groundwater, springs and streams), but fails to disclose a full analysis of water availability and environmental impacts. New water use by the mine would require water permits; this, in turn, will require mitigation of impacts.
The PCHB rejected the proposed mitigation for the previous proposal, in part, because of fatal flaws in the modeling of hydrologic impacts. The current Buckhorn project relies on the same modeling that was previously rejected and has failed to develop appropriate baseline data against which impacts can be fully evaluated. They have failed to accurately explain baseflow and surface runoff into the Buckhorn stream system, and to reliably characterize the hydrogeology of the local groundwater system.
Analysis of impacts and mitigation scenarios are not explicitly and credibly addressed in the DSEIS. The PCHB rejected BMG’s water resource mitigation plan as entirely speculative--a problem compounded by putting the mitigation plan outside the normal public comment process. That strategy backfired for Ecology, but they seem to be repeating it. This project has always been controversial and, to be fair and effective, all essential components of the project should be opened up for public review.

A Rough Road Ahead
Truck Traffic
The proposal to transport the mined ore from Buckhorn Mountain to the Echo Bay mill facility represents a significant increase in truck traffic on small, rural roads between Buckhorn Mountain and Republic, Washington. The effects to life and property from vibration, noise, dust, and truck exhaust on those who live and own property along these roads would be significant. Besides sound and air quality, there is increased risk of accidents from trucks and potential spills. If health and safety aren't enough, there are decreasing property values to consider. The SEIS must fully assess these impacts as well as meaningful alternatives and mitigation.
Kinross wants to transport ore in 30 ton trucks from the proposed mine on Buckhorn Mountain down Marias Creek, then along Toroda Creek, and the Kettle River to their mill facility near Republic. The plan calls for 50 round trips per day. That's a massive ore truck every 7 minutes, with even more before and after Spring thaw when they would stockpile extra ore. Worker traffic 24/7 would be added to this.

Backfill Gravel
The Kettle River Road is quite peaceful these days since Pope and Talbot of Midway, B.C. quit hauling lumber along the river. Unfortunately for many of the landowners Kinross wants to develop a gravel pit in the vicinity to backfill mine shafts, build up the Marias Creek Road, and upgrade the Toroda and Kettle River Roads.
Of the ten ranchers or residential homeowners who live within one mile from the proposed quarry, 8 are retired, 6 have home businesses, 1 is an at-home spouse, 2 are vacation property owners, and 2 are night shift employees that sleep days. Major concerns are the noise, dust, and diesel emissions that degrade their quality of life.
The proposed new backfill gravel site is located 1.6 miles south of Toroda and the Job Corp, on the west side of Kettle River Road, just 1700 feet north of Beal Park. Its 24 acres are on the first and second glacial terraces of the Beal property, with an access road to Kettle River Road.
Noise affects people in several ways. The DSEIS model estimates 57 decibels from truck and equipment noise. Volume, duration, and repetition of noise can be unbearable. In addition to a truck passing by every 7 minutes, the quarry equipment would run continuously for 12 hours every day across from homes and farms. Kinross estimates 6 loads to fill an ore truck; the loader backs up each time. Backup alarms are required on equipment. Beeping alarms may be quieter than jake brakes, but their piercing, repetitive noise travels far.
The DSEIS mitigation measures for noise at the site only address ore haul truck mufflers, compression braking noise suppression, and vehicle noise standards. Quarry equipment, rock dumping, crushing, and backup alarms all need to be included and addressed. Sound barriers could be positioned, state of the art directional back up alarms could deflect sound waves from traveling across the valley and operating hours and days could be further limited.
The proposed backfill quarry would also degrade air quality with dust and diesel emissions, affecting recreationists in the riverbed, pedestrians traveling along the roadside, and visitors at Beal Park. Job Corps students frequently use the road for exercise in warm weather. Emission standards are more stringent for trucks than for heavy equipment such as loaders or stationary diesel engines. Winds blow up or down the valley, following the road.
Mitigation for quarry visual impacts would leave an earth berm, and native vegetation. As far as providing a visual screen or sound barrier, this natural vegetation is too sparse to be effective. A soil berm along the outer edge is proposed to hide the quarry from Kettle River Road drivers traveling 50 mph but will do little for recreationists floating the river or residents living and working across the river.

What is a healthy Economy?
A vital and healthy environment is the basis of a healthy economy. We do not need to harm our forests and pollute our waters in order to have economic prosperity. We are not poor and desperate people who need to sacrifice the quality of our lives for money. The quality of our environment is closely tied to the quality of our economy and society. Creative individual activity in the context of a supportive community is the basis of a truly vital, thriving economy.
The growing populations Okanogan and Ferry counties are partially due to people migrating to preferred living environments. The retired middle class is one group drawn to our area. They are often looking for a safe and naturally beautiful area in which to live. Environmental factors definitely affect this choice. This retirement income group has become a very valuable part of our tax and trade base, contributing more than farming, mining and manufacturing combined. Those of working age who relocate here also contribute to our economy.
Besides providing economic stability, both groups are a very important part of our county's society. If you talk to these neighbors you will find that they often came here for the natural beauty and wildlife. The quality of our environment is an important part of our economic base and a source of our ongoing economic vitality.
The DSEIS does not take into account the negative impacts associated with degraded environment. The economic analysis is grossly incomplete because it fails to take this into account, is biased, and should not be used to guide decision making.
The unstable nature of mining's boom/bust economy is tied to international commodity prices, and is a highly speculative venture over which we have no control. Our environment is sacrificed for the wealth of a few, and our economy and society come out the worse.
We have been asked to believe that we need this mine for the prosperity of our area . We should insist that a full analysis of the public costs versus the public benefits of the proposed mine be included in the SEIS.

Public Costs Versus Public Benefits
The DSEIS states that the regulatory agencies have no responsibility to do a cost-benefit analysis of the proposal because the economic viability of the project is the responsibility of the company. OHA contends that a quantitative analysis of the public costs versus the public benefits should be included in the SEIS. It is necessary for determining the public interest test for water right decisions, and is also needed by local regulators determine the cost to public resources so they can assess impact fees under Chapter 78.56 RCW Metals Mining and Milling Operations, Section 78.56.130.

Noise Sounds Like a Big Issue
Next to the impacts to water, the amount of noise potentially generated by the Buckhorn Proposal is deafening. Guidelines and limitations on noise from the EPA, DOE, and WADOT identify the maximum allowable limits, and then exempt those limits during the construction phase and along the roads. This is not fair to landowners nor residents.
Ecology anticipates increases of noise to be precariously close to the limits allowed by state law (often within one or two decibels), as if to say, “Don’t worry folks, your eardrums will survive because we are one decibel under the allowable limit of noise.” Interestingly this scenario was anticipated with the “Crown Jewel” EIS; always just under the limit of the law.
This noise document states that baseline ambient sound levels INCLUDE the traffic from the K2 mine (although that mine is now closed and little traffic noise is generated by it). This is unacceptable. Truck noise is not the “natural sound” of this community and should not be considered as a baseline. These “ambient sounds” of K2 mine traffic, when taken out of the equation, would make the increased sound of traffic on and off the proposed mine site a “very serious impact” to the quality of life in the community. Landowners need to be justly compensated for these noise impacts.
An independent, local citizens group of those who that would be impacted by the noise should be formed. This committee would monitor noise and be empowered to force the company to make changes regarding noise in their community. These actions could include requiring heavy duty brake mufflers, further limiting of the hours of operation, and monetary compensation to landowners seriously impacted by noise.