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Conservationists Urge Army Corps to Scrap Red Dog Port Project
By Ecoloy and Law Institute
Jul 23, 2002, 08:00
For Immediate Release: July 23rd, 2002
For more information please contact: John Talberth, Ecology and Law Institute,(505) 986-1163. Mara Bacsujlaky, Northern Alaska Environmental Center, (907) 452-5021 extension 28.
Fairbanks – In the context of formal comments filed today, The Ecology and Law Institute, Northern Alaska Environmental Center, and the Forest Conservation Council urged the Alaska District of the Army Corps of Engineers to scrap a major port expansion project proposed in the Northwest Arctic Borough near Kivalina. The project seeks to expand the Delong Mountain Terminal to accommodate increased shipments of lead and zinc concentrate from the Red Dog mine – the largest lead/ zinc mine in the world – and, thereby, allow that mine to significantly expand its operations. The Red Dog mine is owned by Teck Cominco, Incorporated. The groups also sent the Corps a sixty-day notice of their intent to file a citizen suit under the Endangered Species Act (“ESA”) if the project is authorized as currently planned. In the organizations’ official comments on the project and the sixty-day notice, economic infeasibility, impacts to subsistence uses, and destruction of sensitive marine ecosystems were cited as the primary concerns.
Ecology and Law Institute (“ELI”) is a non-profit research and advocacy group working for sustainable management of federal public lands, including marine resources affected by the Army Corps of Engineers. The Northern Alaska Environmental Center (“NAEC”) promotes conservation of the environment in Interior and Arctic Alaska through advocacy, education, and sustainable resource stewardship. The Forest Conservation Council’s (“FCC”) mission is to protect and restore the native biological diversity of forests and other wild terrestrial and aquatic ecosystems throughout the United States and its Territories.
According to ELI economist John Talberth, “By law, the Corps cannot subsidize navigation projects that primarily benefit land development schemes such as the Red Dog mine expansion, nor can they participate in projects that generate more economic harm than good. In this case, it is clear that Teck Cominco will be the primary beneficiary of our federal tax dollars, and that extraordinary economic damages to subsistence uses, historic and cultural resources, and marine ecosystems caused by this project will not be offset by its dubious benefits.”
According to ELI, NAEC, and FCC, the Corps is in danger of replicating the same mistakes in its benefit-cost analysis for the Red Dog port project that destroyed its credibility in the context of other ill-fated projects such as the Upper Mississippi-Illinois Waterway project, the Delaware River Deepening project, and the Chesapeake and Delaware Canal Deepening Project. Those projects earned the Corps the wrath of the Environmental Protection Agency, the General Accounting Office, the National Research Council, and National Academy of Sciences because they found that the Corps consistently overestimated of project benefits, underestimated costs, failure to recognize the uncertain nature of project benefits, and failed to rigorously explore less harmful alternatives.
ELI, NAEC, and FCC are also alarmed at the Corps attempts to circumvent its own regulations requiring that project benefits exceed costs. Last summer, after initial benefit-cost analyses turned out negative, the Corps held discussions with Senator Ted Stevens (R-AK) about a possible appropriations rider that would simply declare that project benefits exceed costs, thereby obviating the need for the Corps to complete an economic analysis at all. (Language attached). “Instead of pursuing this strategy of legislative deception, Senator Stevens and the Corps ought to let the Red Dog port project die a natural death,” Talberth continues.
Another major concern of the organizations is the detrimental effects of the port and Red Dog mine expansion on subsistence uses by Alaska Natives. According to the organizations’ comment letter, the project cannot meet statutory requirements to maintain subsistence as a priority use of the lands and waters in the area. In addition, the Corps is violating several statutes and President Clinton’s Executive Order on environmental justice by failing to grant the Native Village of Kivalina cooperating agency status.
According to NAEC Mining Director Mara Bacsujlaky, “The Corps has inadequately assessed impacts to subsistence uses of the marine and upland environment. The Red Dog port is located in an area that is very important for a number of reasons – it is in the traditional hunting grounds of the Inupiaq village of Kivalina – and they have observed that beluga – an important food source – avoid the port site area. Also, the Red Dog mine is located in an area essential for caribou. Caribou have already been harmed by the mine, and expansion will only make matters worse. Because of these threats to subsistence, the expertise of affected Alaska Natives must be included in the Corps assessment and their concerns must be addressed. So far, the Corps has failed to do either.”
Yet another major concern raised by the organizations is irreversible damage to the sensitive marine environment. According to the organizations’ letter, the Red Dog port project will increase ship traffic, noise, toxic contamination of air and water, and damage to marine ecosystems. These impacts will further harm already stressed populations of threatened and endangered species such as the spectacled and Stellar’s eider, bowhead whale, right whale, fin whale, and humpback whale. And because the Corps has not initiated formal consultation with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service over impacts to these species, ELI, NAEC, and FCC today also sent a formal notice to the Corps of their intent to sue to enforce the consultation requirements. A sixty-day notice of intent to sue is required by the Endangered Species Act.
“The port site is essential habitat for several species protected by the Endangered Species Act. A project of this magnitude in such an environmentally sensitive and important area must be carefully evaluated. So far, the Corps has failed to demonstrate that it has done so because it has ignored its duty to recruit the expertise of the U.S. Fish and Wildlife Service and National Marine Fisheries Service to help eliminate threats to these species,” Bacsujlaky continues.
For copies of the sixty day notice or formal comment letter, please contact Mara Bacsujlaky or John Talberth at the contact numbers listed above.
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