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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 reclaiming 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 described, 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 expanded version of H.R. 918 even section 204 could be expanded in this regard-that mining not be allowed where it would be clear that you couldn't reclaim the area, there would be irreversible impacts, which is the case here; that

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:]

STATEMENT OF LOUISA L. WILLCOX, PROGRAM DIRECTOR OF THE GREATER YELLOWSTONE COALITION, BEFORE THE HOUSE MINING AND NATURAL RESOURCES SUBCOMMITTEE OF THE HOUSE INTERIOR AND INSULAR AFFAIRS COMMITTEE ON H.R. 918, "MINERAL EXPLORATION AND DEVELOPMENT ACT OF 1991," JUNE 18, 1991.

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.

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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.

State Lands Abandoned Mine and Reclamation Bureau data, nearly six hundred (600) unreclaimed abandoned hardrock mines exist in Montana's portion of Greater Yellowstone. In 1989, out of a total annual reclamation fund of 6.5 million dollars, only 2 million dollars were spent on reclaiming non-coal sites in the state -- a fraction of what is needed for effective reclamation according to Bureau officials.

Data from the Wyoming Department of Environmental Quality on the state's Abandoned Mine Land Program show that thirty five (35) known unreclaimed abandoned mine sites have been inventoried in Wyoming's portion of Greater Yellowstone Ecosystem. In addition, on the old Kirwin Mining District, flanked by the spectacular Washakie Wilderness on the east flank of the Absaroka Mountains on the Shoshone Forest, little has been done to address the chronic problems of water quality, such as high levels of zinc, copper, aluminum, nickel, lead, sulfate, barium, and iron in a tributary to the Wood River. Not only is this situation diminishing the quality of this portion of the Washakie Wilderness, it could pose some level of potential risk to the residents of Meeteetse who derive their drinking water from this

source.

In Idaho, which lacks coal resources and an Abandoned Mine Lands Program, abandoned mines are not being assessed and reclaimed. An abandoned mining district, consisting now mostly of old shafts and structures, and other scars of placer and lode gold mining activity, is located at the base of Caribou Mountain, in eastern Idaho. Surrounding the old Caribou Mining District, parts of the Caribou Forest have again become so wild that they are under consideration by Congress for inclusion in the National Wilderness Preservation System. Furthermore, the area drains into Gray's Lake National Wildlife Refuge, where water fowl abound, and endangered Whooping cranes are being recovered in a Sandhill crane foster parent program. It is a land of

spectacular views, and the headwaters of some of the best elk and deer habitat in this part of Idaho; but it is a land unnecessarily marred by past mining activities, and reclamation failures.

We have previously discussed before this committee the problems of reclamation in Greater Yellowstone, particularly in the alpine zones. Here, we have the benefit of twenty five (25) years of research by the USDA Forest Service Intermountain Research Station on alpine revegetation efforts in the wake of mining activity. This experience shows that, even using the most progressive techniques, reclamation of high elevation areas is at best difficult, and at worst all but impossible. Limiting factors include short, cool growing seasons, strong winds, yearround frosts, a limited pool of adapted plant species, as well as the character of the spoils material, which is often acidic, low

healthy natural environment. According to figures derived from the states of Montana, Wyoming, and Idaho. Local services, including wholesale and retail trade, health and education, outdoor recreation related employment, government jobs, real estate and other service sector employment now provides nearly seventy (70) percent of all jobs in the Ecosystem. Non-labor related income, such as retirement payments, dividend or insurance payments, have increased to the point where they are now nearly three-quarters (3/4) as large as all wage and salary income in Greater Yellowstone. In addition, recreation has increased to the extent that it now provides four out of five forest related jobs. And, in 1988 alone, tourism pumped $140 million just into the Montana portion of Greater Yellowstone.

By contrast, in 1989 in twenty Ecosystem counties in aggregate, mining and oil and gas employed five percent (5%) of Greater Yellowstone's work force -- down eleven percent (11) from twenty years ago. And, while mining output rose between 1977 and 1986 by 41%, total employment dropped by 1.2%. In Greater Yellowstone specifically, income flowing from mining, timber, oil and gas and manufacturing, has dropped 33% over the last ten years.

Our intent in providing these figures is to clearly show that in Greater Yellowstone, the spectacular wild landscape and hunting and fishing opportunities attract and hold a population that wants to live and be productive here. Natural amenities make this area an attractive place to live, and that is the stimulus to economic development. In addition, farming and ranching, also important economic activities in a number of Ecosystem counties, depend on sources of clean water, healthy range and well protected soils.

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If the economic future of this region is to be sound, we cannot kill the goose that has laid the golden egg Greater Yellowstone's wildlands and natural amenities. We must ensure that mining activities, which contribute a tiny proportion of the income and employment opportunities in the region, are done only to the extent and in such a way that is compatible with maintaining the integrity of the Greater Yellowstone Ecosystem.

3) Looming Problems in Greater Yellowstone: Caribou Mountain (Idaho), New World Project (Montana), and Emigrant Gulch (Montana).

In two days, you will hear detailed comments submitted by a number of Montana activists and citizens regarding the environmental problems posed by a number of mines in Greater Yellowstone, including the Stillwater Mine, the proposed East Boulder Mine, and the proposed Noranda Mine at the border of Yellowstone Park. In an effort not to steal their thunder, I will not discuss these projects in great detail, but rather

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