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Ms. Willcox. Good afternoon, Mr. Chairman.

I am Louisa Willcox, and I am program director of the Greater Yellowstone Coalition, which is based in Bozeman, Montana. We are comprised of more than 90 local, regional, and national conservation organizations as well as 4,500 individuals committed to the long-term protection of the Greater Yellowstone Ecosystem, which is considered the largest intact temperate zone ecosystem on the face of the earth that remains today.

We and our members are deeply concerned about the legacy of environmental degradation in this land of superlatives, which is in part the product of hard rock mining activities under the direction of the 1872 Mining Law. It is a legacy that we fear will continue unless we tear down the walls-to use your expression, Congressman Rahall-unless we tear down the walls of the 1872 Mining Law and build a new system, and this new system for Yellowstone must include a clear Federal authority to deny mining activities if they don't serve the greater public interest, in our case of protecting national treasures such as Yellowstone Park. H.R. 918 begins to construct such a system.

I want to go back and give a little context on Yellowstone and Greater Yellowstone and talk about a few of our problems and then get to the question that you raised earlier, Congressman Rahall, of how and under what conditions to just say no, which you had asked previously.

The integrity of Greater Yellowstone is really measured by abundance, abundance of wildlife, such as our big herds and great bear, as well as the abundance and quality of our waters, which includes the headwaters of the three major drainages of the west. The headwaters are the lifeblood of the agricultural, industrial, and munici. pal development in the surrounding States, and they also are necessary to replenish our magnificent geysers. I will get back to water in a minute.

Indeed, the watersheds, wildlife, and the beauty of our ecosystem are really the lifeblood of the economy of the region, and it is an economy that our analysis of available State data and census figures show is responsible for 70 percent of the jobs and most of the income in the Greater Yellowstone Ecosystem. These are tied directly or indirectly to the amenity resources and ultimately to the health of Greater Yellowstone.

We show in our testimony that mining contributes presently very little to the economy of the Greater Yellowstone Ecosystem. Even in counties considered big mining counties, such as Park County, Montana, for example, mining provided 2.2 percent of the income in 1988, and yet we have cases in Park County where mining practices and abandoned mines have caused serious envi. ronmental damage which cuts right into those amenity resources that are our lifeblood for our economy and, indeed, for Greater Yellowstone ecologically.

In our testimony, we talk about 650 abandoned mines in Greater Yellowstone, which have been inventoried, which have not yet been addressed, and we also talk about poor reclamation examples where water quality, fisheries, and even human health and safety have been affected, and you yourself, Congressman, have taken a trip and seen some of the reclamation problems that we have in Yellowstone up at Noranda's site-well, Noranda's proposed site, up at the existing site northeast of Yellowstone Park on Soda Butte Creek, and we appreciate your efforts to address the problem of re claiming that watershed that is poisoning or at least still partially poisoning waters in Yellowstone Park itself.

Unfortunately, we fear that similar dramas will likely be created time and time again even on the border of Yellowstone Park if the 1872 Mining Law is not reformed, and we are also afraid that Yellowstone, in the bigger picture sense, is being ecologically nickeled and dimed to death. But unlike logging or oil and gas, not even real nickels and dimes are changing hands to compensate for the damage done.

We have often maintained that if we couldn't protect Yellowstone Park and the Greater Yellowstone Ecosystem that surrounds it, we couldn't protect any ecosystem in the lower 48 States, and yet we cannot protect Yellowstone these days without a major reform of the 1872 Mining Law.

I want to bring up one upcoming drama and give you a preview of what is being proposed in the northeastern corner of Yellowstone Park, a proposed gold mine by Noranda north of Cooke City, that may help answer your question of how and under what conditions one should just say no. I want to take you to the Beartooth, a high mountain area at the northeast corner of Yellowstone Park adjacent to the Absaroka-Beartooth Wilderness. At 10,000 feet, it is an area where reclamation has been a real problem in the past, and if mining resumes it will be impossible. It is above the tree line for the most part, the soils are very thin, and the growing season is very short. It is an area where mining activities, if they resume as proposed, will have major visual impacts on Yellowstone Park, will have major wildlife impacts, especially to the threatened grizzly bear as well as moose, will have major economic and social impacts to Cooke City, which is dependent on tourism through Yellowstone National Park, will have major impacts on water quality, as you recall the visions of the orange runoff at the Glengerry Mine adit.

That is just the beginning of acid mine drainage problems to come that could spread to three different river systems in two different States, for Noranda's proposal lies at the head of a creek that drains into Yellowstone Park, at the head of the Stillwater River that drains into the Absaroka-Beartooth, and at the head of Fisher Creek that drains into the Clark's Fork that was recently designated as a wild and scenic river.

As an organization, we have approached each new mine in the Greater Yellowstone very carefully, and we don't have a habit of opposing mines. We have tried very hard to work with the mining companies to ensure the best environmental protection possible. But when you look at Noranda as we have done, and as I have de scribed, any rational person would conclude that this is a place where a mine simply doesn't belong because of the other paramount public values.

So, to answer your question, I consider there are five issues which could be included in an expanderile arsion MR. 918 even section 204 could be expanded in this

pinin, ni hes allowed where it would be clear that there would be irreversible impacts,

mining would not be allowed where there are direct and indirect severe impacts on parks such as Yellowstone, which is downstream from this proposal; where there is habitat necessary for the survival, maintenance, and recovery of threatened and endangered species, such as grizzly bears; where mining activities would destroy the social and economic fabric of a community, in this case Cooke City, which has a character kind of like Alaska up there, kind of remote and independent minded and very dependent on Yellowstone Park; and, fifth, where a balancing, a clear balancing and analysis, would show that the highest and best use of a certain piece of public land is in land protection rather than mining. In this case, it is a unique case, because it is right on the border practically of a wilderness area as well as Yellowstone Park.

So I think those five thoughts may provide a few ideas as to how and when the "just say no” determination could be made.

There are other upcoming issues and problems in Greater Yellowstone. You will hear about a number of them on Thursday, with other people submitting testimony, in particularly the northern tier of the Greater Yellowstone Ecosystem. I have given you photographs of the Emigrant Gulch Area in Montana in Park County as well as Caribou Mountain in Idaho, providing a few more examples of very, very difficult mine proposals in Greater Yellowstone.

We need in Greater Yellowstone full reform to ensure sound environmental mining occurs. We appreciate the provisions in your bill to eliminate patents, to establish an abandoned mine land reclamation trust fund, and to reserve certain lands such as wilderness study areas. The language, as I indicated, could be strengthened to direct analysis of the net public interest and subsequent withdrawal of areas or no mine determination where the highest public interest isn't served.

We in Yellowstone are concerned that if true reform is not achieved we may wake up one day and find that we have killed the goose that laid the golden egg, and the goose in this case is not the stuff that is under Cooke City or the mountain north of Cooke City; the egg, rather, is the stuff that makes Greater Yellowstone what it is; its wildlife, its scenery, its unmatched natural beauty.

Thank you.

[Prepared statement of Ms. Willcox, with attachments, follows:

Suat six

OF 1991." JUNE 18. 1991.

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Good morning, Mr. Chairman. My name is Louisa Willcox, and I serve as the Program Director of the Greater Yellowstone Coalition in Bozeman, Montana. The Coalition is comprised of more than 90 local, regional and national conservation groups and approximately 4,500 individuals committed to the long term protection of the integrity of the Greater Yellowstone Ecosystem, which is considered the largest remaining, intact ecosystem in the temperate zones of the Earth. We and our members are deeply concerned about the legacy of environmental degradation in this land of superlatives, which is in part the product of hard rock mining activities; it is a legacy that will continue unless the 1872 Mining Law is fully reformed, granting the federal government full authority to "say no" to mining activities if full reclamation cannot be achieved or if the public interest is not served.

We appreciate the opportunity to speak before you today on these important issues. We are also deeply grateful for the time you took from a busy schedule to visit Greater Yellowstone two weeks ago, and discuss the problems of the 1872 Mining Law and the potential of reform with our membership during GYC's Annual Meeting in West Yellowstone.

Greater Yellowstone is a land that needs no introduction: it boasts the largest geyser system remaining in the world, the largest elk herds and wild, free-roaming bison herds in the country, one of the last populations of grizzly bears in the lower 48 states, the last known refuge of the blackfooted ferret; it is also home to the whooping crane, bald eagle, trumpeter swan and countless other species -- some of which are still being discovered in Yellowstone's unique environments, such as thermal basins.

Greater Yellowstone is geographically isolated from the surrounding basin country by its high elevation -- the Yellowstone Plateau and 14 surrounding mountain ranges which reach a height of nearly of 14,000 feet. These mountains form the headwaters of the three major river systems of the West: the Green/Colorado, Snake/Columbia and Yellowstone/Missouri. These waters are the life blood of agricultural, industrial and municipal development in the surrounding states. Plentiful and pristine water is also vital to Yellowstone's world renowned game herds, fisheries and other wildlife. And, Greater Yellowstone's mountain ranges, especially the Gallatin, supply the water necessary to charge Yellowstone's magnificent geysers.

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