My Public Comment: Kilgore Project February 2021

To whom it may concern at Caribou-Targhee National Forest,

I am writing with concerns about the current Environmental Assessment relating to the Kilgore Project. My concerns are about both the proposed activities and the review process itself.

I grew up in Idaho Falls, where the Lemhi, Beaverhead, and Western Centennial Mountains were constantly on the horizon. Later in life, a friend and I hiked from Biscuit Basin in Yellowstone National Park to the foot of Mount Borah. Our hike took us across these ranges that had been in our minds for so long, and gave us a good overview of the Greater Yellowstone Ecosystem. 

One of the most special parts of our hike was, in fact, the Western Centennials. It was not long after our trek, at the beginning of 2018, that we discovered the plans for an open pit cyanide heap leach mine just south of West Camas Creek called the Kilgore Project. Between then and now, I have learned a great deal about the central role of the Western Centennials to the Greater Yellowstone Ecosystem. 

The current proposed action pertaining to the Kilgore Project, 3-5 years of exploratory drilling, raises multiple concerns in my mind.

• I noticed in the Environmental Assessment (EA) that the Shoshone-Bannock Tribe was consulted. I was wondering why the Nez Perce Tribe did not receive similar notification and opportunity to comment. Just south of Kilgore, Idaho, in other words, just downstream of the site of the Kilgore Project, lies Camas Meadows. It is one of 38 federally recognized sites of the Nez Perce National HIstorical Park. As a site of importance to the tribe, a site which is already recognized as important by the National Parks Service, I would ask that another Environmental Assessment be carried out that takes into account the Nez Perce’s right to protect their historical site that could very well be affected by the Kilgore Project.
• The Western Centennials are an important wildlife corridor, including for grizzly bears. The current EA states that “There have been no radio locations of grizzly bears within the analysis area from 2000 to 2019. There are no important habitats in the analysis area and overall, the analysis area is likely to be low quality habitat due to the road density and human disturbance in the project area from exploration activities.” But I am aware of a press release from June 30, 2018 from Idaho Fish and Game that reported an injured grizzly bear sighting in McGarry Canyon, which lies at the heart of the Kilgore Project. This sighting was enough to cause Caribou-Targhee National Forest to put up signs warning people of the presence of grizzlies in the area. I see that the EA only uses radio collar data to determine the absence of grizzly in the project area. I would ask that another EA be carried out, one which uses multiple kinds of evidence about grizzly presence, so that all grizzlies in this important wildlife corridor, and not just the ones that happen to be radio collared, can be protected. 
• I have taken advantage of the great birding opportunities near Camas National Wildlife Refuge, another place that lies downstream from the Kilgore Project, and therefore dependent upon the health of the upstream waters. According to the January 2014 Draft Comprehensive Conservation Plan and Environmental Assessment from Camas National Wildlife Refuge, something like 164 sensitive species (which have been designated as such by various state or federal organizations) depend on Camas NWR. The wetlands depend on the health of Camas Creek, which is already listed as 303(d) for flow alteration, sediment, and nutrients (IDEQ 2005) (again, according to Camas NWR Draft CCP). Since West Camas Creek (one of the tributaries of Camas Creek) is listed in the EA as a source of water for the exploratory drilling,  I am concerned about the prospect of the Exploratory Drilling further limiting the flow of Camas Creek, which would further endanger the species that depend on Camas NWR. I would ask that a more comprehensive Environmental Assessment be carried out, one that examines more deeply the effect of further limiting the flow of Camas Creek to the federally and state protected wetlands downstream.
• Finally, perhaps my biggest concern with the current EA is its short-sightedness. Nowhere in the EA is there any reference to an open pit cyanide heap leach mine. This mine, which is the obvious goal of the exploratory drilling, has been fully disclosed by Otis Gold and now by its parent company Excellon Resources, most recently in its February 2021 presentation for its investors, which is available on Excellon’s website. I would ask that a new EA be drafted which includes the next steps in Excellon’s plans, the open pit mine, which would give the public an opportunity to meaningfully comment on the next step, which is the destructive outcome of the exploratory drilling. While the drilling itself poses serious concerns for the wildlife and human populations in and downstream of the Kilgore Project Area, an open pit mine would pose another level of threat altogether. The last twenty years have seen massive environmental catastrophes related to the failure of earthen tailings dams as sites of open pit heap leach mines (Baia Mare, Romania and Mount Polley, British Columbia, to name just two). Such an event at the Kilgore Project would threaten the health of the Snake River Plain Aquifer, as well as the federally and state protected wetlands and historical places I have mentioned previously. Furthermore, such a mine would undermine the current provisions about road and drill site reclamation promised in the current EA. It would also make the exploratory drilling’s required sacrifice of 22 acres of whitebark pine, elk, and woodpecker habitat unnecessary, since the public will not want a cyanide heap leach mine in the Western Centennials, regardless of the outcomes of exploratory drilling. Again, my request is that a new Environmental Assessment be carried out, one which discloses the end goals of the exploratory drilling, in other words, one which discloses the future open pit cyanide heap leach mine, so that we the public can comment on the exploratory drilling in its appropriate context. 

Thank you for your time and the opportunity to comment. The Kilgore area is a very special place to me, and I know that it is to many eastern Idahoans. I appreciate your serious consideration of my concerns.