Red Dog Port Expansion
Environmental and Community Issues
Proposed Red Dog Port Expansion, Preferred Alternative*
Components
- 1,450-foot long trestle w/ roadway, conveyor, fuel pipeline
- 90-foot by 300-foot dock with two fixed radial shiploaders
- 18,500 foot dredged channel, 53 feet deep with a turning basin
- 1.5 million gallon additional fuel storage construction
Cost
- $240,000,000 for total construction
- $75,000,000 for shipping channel and turning basin with an annual cost of $1,245,000
- $ 6,550,000 annually for operation and maintenance for the whole project
Capacity (annually)
- 1.5 million short wet tons of base metal concentrate, exported
- 52.7 million gallons fuel, imported (22.6 million gallons used by mine/port; 30.1 million gallons transshipped to villages)
source: US Army Corps of Engineers, 2003
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Background
The Delong Mountain Transportation System - more commonly known as the Red Dog Port - was completed in 1990 by the Alaska Industrial Development and Export Authority (AIDEA) to provide the means to ship ore from the Red Dog mine to market and to bring in mine supplies and fuel. Although the Red Dog Port is officially available to any entity willing to pay a user fee to AIDEA, practically speaking the only tenant is Teck Cominco, who pays $18 million per year for the privilege. Because of the size of their operation, no other entity presently can use the facility.
In 1996, AIDEA, in conjunction with Teck Cominco, began some expansion projects at the port that allowed the company to increase its concentrate storage capacity from 1.2 million tons annually to 1.4 million tons. However, storage and shipping capacities remained the largest obstacles to future mine expansion, even as additional zinc and lead resources were being discovered at Red Dog. Therefore, in the late 1990's Teck Cominco began planning a major expansion of the Red Dog Port. The project included dredging a 60-foot deep shipping channel, extending the dock approximately 2,500 feet and constructing a trestle dock structure that would accommodate full-sized, deep-water cargo ships. An airstrip and associated facilities were also included in the initial project design - these have since been dropped.
Although initially the proposed port expansion was solely Teck Cominco's project, the company soon realized that the costs of funding the Environmental Impact Statement, the expansion construction, and the maintenance dredging of the deep-water channel would be prohibitive. After a period of dormancy, when it appeared the expansion was dead, federal money and oversight - through the US Army Corps of Engineers(Corps) - was appropriated by Congress and in late 1999, the Corps launched the Environmental Impact Study with scoping meetings held throughout the Red Dog region, and simultaneously started a feasibility study of the proposed Red Dog Port expansion.
 Concentrate conveyor and barge, Red Dog Port |
The main function of the feasibility study, which is funded by Congressional appropriations, is to establish that the expansion of this far northern port - ice-free four months a year and used primarily by a single, private entity - is in the national interest. This designation would pave the way for the Red Dog Port Expansion to become a civil works project and thus partly funded by the federal government, with in-kind service provided by other entities, such as AIDEA and the NANA Regional Corporation.
As of the summer of 2003, preliminary drafts of the Environmental Impact Statement and Feasibility Study were completed, with a release date of the Draft EIS and Feasibility Study for public comment scheduled for the fall of 2003. The Draft EIS was not released until two years later, in the fall of 2005. The Corps preliminary findings identify the National Economic Development (NED) Plan - the alternative that maximizes net national economic development benefits. It includes the dredging of a 57-foot deep channel with ocean disposal of the dredged material, and construction of a 1,450-foot trestle that would carry a roadway, and initially, one covered conveyor (see table above). The conveyor would move concentrate to docked Panamax and Handy size bulk vessels, thereby eliminating the need for the smaller lightering barges. The new trestle and deep-water channel would also support the docking of fuel tankers from Asia.
Also included in the NED plan is augmentation of on-shore infrastructure to accommodate the deep-water port. These include among other things the expansion of the existing facility power generation station to house a new single 3,200 kW Wartsila generator, a 12-inch fuel pipeline from the trestle to the existing fuel tank farm, a fire protection system upgrade for the new shiploading facilities, and renovation of the old housing complex to accommodate an additional 100 workers during construction.
The Corps has also made a preliminary determination that the proposed port expansion will provide annual estimated economic benefits of $26,978,300, which are greater than the annual estimated costs (including interest during construction) of $20,048,389 - for a positive benefit to cost ratio of 1.35 to 1.0. This determination, should it remain unchanged throughout the public comment phase of the process - would advance the project as one that is in the national interest - and thus funded by federal appropriations.
Issues
Economic Infeasibility
From the beginning, the economic benefits of the Red Dog Port have been in serious doubt. First, and as the Corps has been rebuked for doing elsewhere, the demand for Red Dog Port usage has been significantly overstated. For example, in their preliminary economic analyses, the Corps made several unwarranted assumptions about use of the Red Dog Port by other parties, such as coal producers and other mining companies that have yet to actually commit to any such use. Also, a significant portion of the Red Dog Port's alleged economic benefits hinge on its use as a regional fuel distribution center for villages throughout northwest arctic Alaska. However, during the original permitting and construction of the Red Dog Port, AIDEA and others touted the port's potential to provide villages with lower-cost fuel - a benefit that has not materialized over the past 13 years of the port's operation. Further, the Corps did not consider the fact that in the future alternative fuels and efficiency may actually reduce fuel shipment demands. Use by Teck Cominco has also been overestimated. The Corps economic break even point for Teck Cominco's use of the Red Dog Port requires that the Red Dog mine be expanded to accommodate at least two million tons of lead/ zinc concentrate per year, a level far less than what is actually anticipated by Teck Cominco.
Secondly, the costs of the Red Dog Port have been greatly understated. Significant costs related to operation of the Red Dog Port as well as maintenance dredging of the harbor have been overlooked entirely or seriously underestimated. More importantly, a host of nonmarket costs such as damage to historic and cultural resources, damage to terrestrial and marine ecosystems, and costs to subsistence use have been completely excluded from the analyses conducted to date.
Subsistence Impacts
Subsistence foods make up a significant portion of local communities' caloric intake and several traditional subsistence grounds are present in the area affected by the proposed Red Dog Port expansion. Review of information provided by the Corps indicates that the agency has inadequately assessed impacts to subsistence uses of the marine and upland environment. Given the negative impacts associated with the existing Red Dog mine and port, it seems unlikely that subsistence can be maintained as a priority use of the Red Dog Port impact area. Thus, the Red Dog Port expansion, as currently proposed, cannot meet statutory requirements to maintain subsistence as a priority use of the lands and waters in the area.
Direct impacts attributable to the Red Dog Port expansion that will affect subsistence hunting include subsistence species habitat loss or degradation, interference with fish and wildlife cycles or migration, and increased harvest pressures. The most significant impacts would be on populations of marine and terrestrial mammals and anadromous fish that are hunted for subsistence.
 Ringed seal © W. Turnbull, Alaska Fisheries, Science Center, NOAA |
Marine mammals have been documented as the single most important subsistence food resource for area residents. Of particular importance are the ringed seal, spotted seal, bearded seal, beluga whale, and bowhead whale. The port site is within a "marine mammal harvest area" and impacts whale as well as seal movements and migration. Local subsistence hunters and Native Elders observe that since the port began operation, beluga and bearded seal avoid the port site area.
Additionally, the transportation of materials from the Red Dog mine and, potentially, other mines that will eventually use the Red Dog Port affect subsistence uses by interrupting caribou migration patterns. Roads also have significant impacts on anadromous fish spawning and rearing habitats. Species of fish both anadromous and marine that are of critical importance to subsistence users in the area are the arctic char, rainbow smelt and chum salmon, while other species of interest are coho salmon, king salmon, and sockeye salmon. Ongoing and future effects of increased road use and/ or development of new roads include loss of habitat (spawning and rearing), changes in hydrology, and increased fishing pressure from the public and mine employees. Other indirect impacts include bioaccumulation of heavy metals including cadmium, zinc, and copper, which may eventually find their way into human tissues.
Sensitive Marine Environment at Risk
Yet another major concern is irreversible damage to the sensitive marine environment. As currently planned, the Red Dog Port expansion poses a substantial risk to the viability of several species, including species important to subsistence or protected by the Endangered Species Act, such as the spectacled and Stellar's eider, bowhead whale, right whale, fin whale, and humpback whale. Impacts such as increased noise pollution, increased ship traffic, oil and gas spillage, as well as spillage of toxic waste may directly harm these species, or cause indirect harm through avoidance and changes in migration and feeding patterns.
For more detail on these and other issues, see the scoping comments submitted by Ecology and Law Institute on behalf of the Northern Alaska Environmental Center. Click here to download the comments [411kb .pdf file]
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