FFI Comments on Black Butte Project in Montana - Blog (Retired)
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FFI Comments on Black Butte Project in Montana

Posted on 5/13/2019 by Fly Fishers International

FFI expresses concerns that the comment period for the project is too short and that the EIS doesn't adequately address ramifications of potentials failures in the plan.

May 7, 2019

The Honorable Steve Bullock


State of Montana


Director Shaun McGrath

Montana Department of Environmental Quality


Sent via email to: tintinadrafteis@mt.gov


Dear Governor Bullock and Director McGrath:

We are writing on behalf of Fly Fishers International (FFI) to express our concerns regarding the proposal by Tintina Resources and Sandfire to develop a copper mine that could threaten the Smith River and some of its tributaries.  We are particularly concerned about deficiencies in the Draft Environmental Impact Statement (DEIS).

Fly Fishers International is a global organization dedicated to the support, enhancement and protection of the recreational opportunities and enjoyment of fishing with the artificial fly. We do this through teaching all aspects of fly fishing and most importantly through our advocacy, demonstration and voice for conservation of our natural resources.

We join with many others who are concerned about the proposal by Tintina Resources and Sandfire to develop a large copper mine in the headwaters of the iconic Smith River. The Smith River is renowned for its spectacular scenery, towering limestone canyons, and blue-ribbon trout fishery, and it’s an economic engine for the region – generating up to $10 million in annual revenue from these activities.

Our concerns about the DEIS include:

  1. Time Allotted for Review of the DEIS-The time allotted for scientific analysis of the DEIS is insufficient.FFI requests that the comment period be extended to allow a more thorough review.
  2. Dewatering the Sheep Creek Watershed-The DEIS does not include sufficient models examining the likelihood that the mine will contribute to dewatering the Sheep Creek watershed.A study by Montana Fish, Wildlife and Parks documented that the upper reaches of the Sheep Creek watershed is used as spawning habitat for mountain whitefish and rainbow trout.Should the mine contribute to dewatering, this fish population could be adversely affected.Moreover, the DEIS does not address for surface temperatures might change when withdrawn waters are replaced.
  3. Potential Pollutants- The DEIS does not sufficiently account for how pollutants might travel as water used in the mine operation is pumped back into the groundwater. The water the company plans to pump back into Smith River tributaries, so they don’t dry up due to mining activities is highly likely to contain more acidity, nitrate, and toxins than the DEIS admits. As a result, nearby wetlands could be affected to a much greater extent than models predict. Compromising these wetlands could damage critical habitat for fragile native plants and animals.
  4. The Plan for Storage is Experimental- The mine’s plan for storage and remediation is experimental. Sandfire’s plan to leave tailings and toxic waste in place are not proven to be effective. A river as valuable as the Smith River shouldn’t serve as site for a mining experiment.

In summary, the DEIS, as submitted, does not sufficiently address the potential risks this mine poses to the Smith River watershed.  We implore Governor Bullock and the DEQ to address these additional concerns.  The Smith River is too important to Montana and to our nation to do less.

Most Sincerely,

Len Zickler



Tom H. Logan


Board of Directors