Opposing IPOP Mining Permit Again

that have been there for thousands of years. Migratory birds will not nest in the area while there is mining commotion going on. The applicant states they will avoid sites having unique habitat including habitat of threatened or endangered species and that no threatened or endangered species habitat has been documented in the footprint of the project. This is false, Ringed Seals are in fact on the Endangered Species list as Threatened and through Kawerak’s Social Science Program; Seal and Walrus mapping project Ringed Seals have been positively identified in the proposed area during the spring, summer and fall. It is essential to Ringed Seal pups and sub-adults to hone their fishing skills on small forage fish and to weather out adverse weather conditions or large storms on the open ocean. This same information has been relayed by Kawerak to NOAA in a comment letter regarding Ringed Seal Proposed Critical Habitat; this same information has also been relayed to NOAA at the Ice Seal Committee level where there is a Co-management agreement to help protect ice seals. Stellers & Spectacled Eiders are also on the ESA list as Threatened and known to frequent the area; how are they supposed to establish a nest site if there is mining commotion going on? Another migratory bird species that has been documented by the USF&WS that is in decline is the Arctic Tern. Arctic Terns are found all throughout the Bonanza Channel area not only to nest but because of the specific foraging area and safety from adverse weather conditions that Bonanza Channel Safety Sound provide.

The applicant states if they are allowed to operate they will create more nesting opportunities for migratory waterfowl in the mud. Waterfowl do not nest in open mud flats where there is no cover or vegetation to help conceal them. This would not only make them more vulnerable to predators and would also make them more vulnerable to high tides or to flooding which can occur all throughout the spring, summer and fall. IPOP states in their amended application that they will avoid swan foraging habitat, how can this be when the entire Safety Sound Bonanza Channel area is prime habitat for swan foraging? Swans have been reported by local Traditional Knowledge holders to occupy the area in which IPOP is proposing to mine. In Alaska, Tundra Swans were once heavily depleted by outside users so much so they were closed to harvest and anyone that inadvertently harvested a swan had a hefty fine and possible confiscation of gear. Subsistence users should not have to bear the burden of conservation just so a mining outfit can take a gamble on a resource that may not even be there.

The applicant states they will enhance or maintain value of ecosystem services. How will this be accomplished when they will be destroying the sensitive ecosystem that took nature to create over thousands of years? As part of the applicant’s mitigation plan it appears they suggest to install culverts in order to help maintain salmon passage. If a culvert is installed in the Bonanza Channel this will in fact impede salmon passage by forcing migrating salmon into a bottle neck. It will also block off subsistence users who use boats to access certain areas. Many subsistence users boat to the El Dorado or Flambeau Rivers where there are Native Allotments. The area being proposed for the case study and mining does not need culverts installed; it already has natural flow where fish and wildlife are allowed to move/migrate freely in or out of the Bonanza Channel. The applicant states they will have no discharge in order to avoid the season or periods when recreational activity associated with the aquatic site is more important – not