Coeur d'Alene Chamber of Commerce opposes EPA plan

Editor's Note: The Coeur d'Alene Area Chamber of Commerce issued the following statement Friday on the Environmental Protection Agency's proposed amendment to the existing Record of Decision for the Upper Coeur d'Alene River Basin Cleanup

It is our position that the proposed plan is undesirable for a number of reasons, these include the following:

1. The proposed ROD Amendment endangers existing and future mining, which in turn has dramatic negative impact on the strength of the local economy.

2. The proposal's length of implementation and costs are too long and too expensive, and does not fully consider the recommendation made by the National Academy of Science, and alternatives are available to achieve clean up which is both viable and affordable.

3. The proposal does not address water right adjudication of Basin 94.

1. It threatens the local and regional economy

The Silver Valley has great potential for economic growth. The area's existing mining and supporting services together with tourism, real estate, and other business sectors need to be viable today and into the future. The proposal does not guarantee future mining and the plan extends the "Superfund stigma". This stigma already threatens the economic health and growth in the Silver Valley, and the greater Coeur d'Alene area. The proposal will undoubtedly threaten the area for decades to come.

2. The proposal is too long and too costly

The proposed plan for cleanup in the Upper Coeur d'Alene River Basin would cost at least $1.3 billion in today's dollars and could mean that the EPA will be a dominant presence in the Valley for at least the next 50-90 years. With today's current economic challenges and uncertainty of the future this is untenable. EPA's proposed plan is simply too big, too costly and takes the wrong approach to completing the Upper Basin cleanup.

The EPA's proposal gives the agency far too much control over the future of the Silver Valley. This will disadvantage and complicate any future development in the region, particularly in regards to mining and mineral exploration. This is unacceptable to those who live and work in the Silver Valley and the larger region that rely on the many economic and other benefits that mining and related industries provide. A viable proposal must ensure a healthy community and a strong local economy.

Additionally, a fundamental flaw of the EPA proposed amendment is that it ignores many of the key recommendations from the 2005 National Academy of Sciences review. The NAS recommended that any cleanup plan for the Upper Coeur d'Alene River Basin should do the following:

• Address the high priority historic mine site areas first , including Canyon and Nine Mile Creeks and the Box,

• Be data-driven, instead of relying on EPA's flawed predictive model,

• Focus on the achievement of actual data-driven measures of success, rather than on numerical standards, and

• Use an adaptive management approach which would address the cleanup in stages, evaluate progress and allow for the revision of goals and strategies based on effectiveness of actions taken over time.

Our review of EPA's proposed ROD amendment does not achieve any of these critical factors.

Furthermore, the EPA's proposed plan is being touted as a way to improve the health of the residents of the Silver Valley. In reality, only $3 million of the plan's $1.3 billion projected costs will be spent on new projects designed to protect human health. In fact, EPA's 2002 Record of Decision and the nearly-completed soil cleanup that EPA mandated as the "final" human health remedy were focused specifically on resolving the human health issues in the Silver Valley. A new, massive, multi-decade plan is not necessary.

With diligence to our policy to review different perspectives and viewpoints, it has come to our attention that an alternative ten-year plan is being proposed. We ask that this alternative 10-year plan be compared, contrasted and then carefully considered and a reasonable compromised be reached as a viable option to achieve meaningful cleanup in the Silver Valley. It is our opinion that this ten-year plan outlines a sensible, data-driven approach to addressing the remaining cleanup needs in the Silver Valley. The cost of this plan ($150-175 million) can be funded by existing EPA resources. Most importantly, it will address historic mining sources in the Box and Upper Basin using proven technologies, provides for remedy protection, improves the fishery in the Upper Basin and provides for an important flood control study.

3. Basin 94 water adjudication

Water and water rights are critical to Idaho and each local community, including those in the Coeur d'Alene River Basin. The proposed plan ignores existing water rights now being adjudicated in Basin 94. The plan's lack of attention to this key issue will injure water rights and have an undetermined hydrological impact. The proposal must address water rights and their adjudication.

We believe that EPA's currently proposed course of action will 1) endanger existing and future mining, which in turn has dramatic negative impact on the strength of the local economy; 2)The proposal's length of implementation and costs are too long and too expensive, and does not fully consider the recommendation made by the National Academy of Science, and alternatives are available to achieve clean up which is both viable and affordable; and 3) The proposal does not address water right adjudication of Basin 94. As such, we urge the Environmental Protection Agency to withdraw the needlessly expensive, non-predictive, not science/results based, multi-decade plan, and instead adopt a focused and efficient 10-year plan.