WA Dept of Fish and Wildlife explains why an EIS should be required

Nov. 15, 2020, 3:58 p.m.

November 12, 2020 

SEPA Center P.O. Box 47015 

Olympia, Washington 98504-7015 

RE: Comments on proposed mine: File No. 20-092802, Surface Mining Reclamation  Permit #70-013279 

To whom it may concern, 

The Washington Department of Fish & Wildlife (WDFW) appreciates the opportunity to  review the State Environmental Policy Act (SEPA) Environmental Checklist and other  documents associated with the proposed Cascade Big Bear mine project. To that end,  WDFW does not feel the current level of environmental review has enough information  for making a threshold determination for a project with such a prolonged duration on the  landscape. The WDFW is responsible for overseeing the viability of the state’s fish and  wildlife resources now and into the future. The areas of concern are, but may not be  limited to: 

  • A lack of detail concerning the survey methodologies and the number and extent  of visits to document plants and animals at the proposed site. 
  • Insufficent assessment or consideration of the potential for take, as defined in the  Migratory Bird Treaty Act and the Bald and Golden Eagle Protection Act, that  may result in the destruction or abandonment of nests, eggs, and young for tree 

and cliff-nesting birds, including bald eagle and peregrine falcon, where proposed mining activities are proposed to occur.  

  • The long-term impacts caused by site activity and noise on the use of the  proposed site and adjacent areas by state endangered fishers and gray wolves. Loss of wildlife habitat. 
  • Long term effects on wildlife travel corridors and rearing and breeding habitat. Unknown impacts to threatened and endangered species. 
  • Potential water quality issues impacting aquatic species. 

In partnership with the U.S. National Park Service, the WDFW has recently reintroduced  fishers into two nearby locations, one north of the site and the other south of the site. The  goal is to recolonize the habitat between the two release areas. To date, telemetry data  shows that the fisher relocation project has been successful in reaching its goal, with at  least one individual known to have used areas near the proposed mine. Similarly, we 

State of Washington 

Department of Fish and Wildlife 

Mailing Address: PO Box 1100, La Conner WA 98257, (360) 466-4345, TDD (360) 902-2207 Main Office Location: Natural Resources Building, 1111 Washington Street SE, Olympia WA 

know from telemetry data that gray wolves, also an ESA listed species in the western  two-thirds of Washington, occupy areas within proximity of this site.  

Because of the combined potential for impacts to migratory birds and threatened and  endangered species, the duration of the proposed mine, and uncertainty of the  consequences to downstream water quality, the WDFW believes that the project has the  potential for significant impacts to fish and wildlife resources. Subsequently, the WDFW  believes an Environmental Impact Statement (EIS) should be required by the applicant before permiting progresses. 

Due to these concerns and others, WDFW urges Washington Department of Natural  Resources to make a Determination of Significance on this project and to require an EIS  to ensure a proper evaluation of the short and long term environmental impacts of this  project. 

We appreciate the opportunity to review and comment on this proposed project and look  forward to working with you as this application moves through the process.  

Sincerely, 

Robert Warinner 

Assistant Regional Habitat Program Manager 
1100 Sherman Street
La Conner, WA 98257 
(360) 466-4345  

cc: Brendan Brokes, WDFW Regional Manager 

Chuck Stambaugh-Bowey, WDFW Regional Habitat Program Manager Fenner Yarborough, WDFW Regional Wildlife Program Manager 

Edward Eleazer, WDFW Regional Fish Program Manager 

Robert Waddell, WDFW District Wildlife Biologist