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Adventure as a Way of Life

Two Odd Facts

Odd fact one: America’s national forests are not entirely public. They often contain “inholdings,” pockets of private land surrounded by public land. Some 180,000 acres of inholdings are within federal wilderness areas.

Odd fact two: Even in places so remote you can’t get there from here, there is a potential of environmental contamination.

Sometimes these two odd facts intersect. An example is in the Wild Sky Wilderness at Mt. Baker-Snoqualmie National Forest in Washington, where The Wilderness Land Trust (motto: Keeping Wilderness Wild) had the chance to protect 350 full acres of inholdings by acquiring them and giving them to the US Forest Service. By doing transactions like this, the trust helps give access to wilderness areas previously closed to the public and provides intact habitat and unbroken migration corridors for wildlife, including endangered species.

But a Phase I environmental site assessment was needed before the property could change hands; this would give the Forest Service information for a decision whether to accept the property from The Wilderness Land Trust, and it would also help evaluate any risk to the trust. This is especially important in this area, which is spotted with small historic mining claims that could have metals contamination.

Some of the information for this assessment was gleaned by interviewing individuals who were knowledgeable about the area, and by poring over regulatory files, maps, aerial photos, and other historical material, but a site visit was also needed.

The Adventure Begins

Miners had somehow clambered their way to the property in the late 1800s and early 1900s. Loggers made it there as well, before the 1960s. But the only way in was by helicopter (too expensive) or by foot.

So, two of Hart Crowser’s intrepid geologists packed their backpacks and camping gear, and headed out for, you could say, a wilderness adventure. Their goal was to explore the possibility that some contaminated mine drainage may discharge from underground workings on or upstream from the property into surface water.

They first consulted National Weather Service mountain forecasts to schedule the visit between a series of strong Pacific weather systems and to reach the site before it became snowed in for the season. On November 9th, they drove the gated Forest Service road up the south fork of the Sauk River valley from the Mountain Loop Highway toward the Monte Cristo Campground trailhead. They were stopped about a mile from the trailhead by a debris flow that had covered the road, so continued on foot to the trailhead and from there to Poodle Dog pass (named after a real dog, we understand) at the head of the Silver Creek valley.

Debris Flow

Debris flow across Monte Cristo road at the beginning of the adventure

As they trudged up the pass, heavy snow began falling, obscuring the landscape. From the pass, the geologists left the established trail and worked their way down into the Silver Creek valley and onto the property, at times following a route marked by old surveyor’s flagging. They located a partially open adit (a mining tunnel entrance) associated with the historical Q.T. Lode claim as well as a waste rock pile on a nearby property associated with the historical Orphan Boy claim.

Heavy snowfall throughout the day increased the adventure factor and kept the geologists from exploring part of the property, and further snowfall closed access until Spring. Even so, they were able to use their reconnaissance information along with their previous research to prepare a Phase I report.

In any case, this summer, soon after snow-melt, was the best time to detect and characterize any mine drainage. A geologist went out one more time accompanied by a Forest Service engineer. He helped the engineer with a different job at a remote mine (volunteering a day of his time) in exchange for assistance at the Silver Creek claims. This time they investigated mine openings along Silver Creek and its tributaries, and looked for any secrets the snow had hidden the first time around, in order to support the mission of The Wilderness Land Trust.

Applying Net Environmental Benefit Analysis to Contaminated Sites

Exxon Valdez oil spill site

Exxon Valdez oil spill site.

First, do no harm….

Or at least don’t do more harm than good.

That’s the idea behind NEBA—Net Environmental Benefit Analysis—as applied to the cleanup of contaminated sites. As defined by a vintage 1990s Department of Energy paper on the subject, net environmental benefits are:

“…the gains in environmental services or other ecological properties attained by remediation or ecological restoration, minus the environmental injuries caused by those actions.”

Spills like Exxon Valdez Spurred the NEBA
The NEBA concept originated with the cleanup of large marine oil spills. One of the first formal considerations of Net Environmental Benefits was the cleanup of the Exxon Valdez oil spill in Prince William Sound, Alaska in 1989. After the spill, the U.S. National Oceanic and Atmospheric Administration (NOAA) looked at whether high-pressure, hot water washing of unconsolidated beaches might actually do more harm to the intertidal habitat—and the plants and animals that depend on it—than just simply letting the oil degrade naturally.

Since then, NEBAs have been used for a few other types of cleanups, including metals contamination in wetlands and organic contamination in sub-tidal sediment, but only infrequently and on an ad hoc basis.

No current NEBA Guidelines, However…
Formal consideration of net environmental benefits has not been more widespread in cleanup decisions, probably because federal and state cleanup frameworks, such as Washington’s Model Toxic Control Act (MTCA), do not explicitly allow consideration of the harm of the cleanup itself and don’t provide guidelines for when the process would apply and how the benefits and impacts should be evaluated.

But that might be changing. At least it is in Washington State, where the Department of Ecology thinks that the NEBA’s time has come. Ecology is working on new draft Terrestrial Ecological Evaluation (TEE) guidance that, for the first time, lays out the implementation of NEBA at cleanup sites under MTCA.

NEBA and Abandoned Underground Mines
In conjunction with Ecology, Hart Crowser has already “test driven” the NEBA concept as it applies to the cleanup of abandoned underground mines. Many of these sites pose risks to terrestrial plants and animals because of the toxic metals such as copper and zinc left behind in tailings and waste rock.

Although the risks to individual organisms living on the waste material might be high, the overall risk to plant or wildlife populations are often fairly low because the extent of the waste material is so small. Nonetheless, the remedy selection process under MTCA would typically lead to a decision to cap the contaminated material with clean soil or to dig it up and haul it away to be disposed of elsewhere.

Bringing Common Sense into Cleanup Decisions
But what if the cleanup involved building an access road? Through mature forest? Or up a steep, exposed mountain side? Or across a stream or wetland? How are those habitat or ecosystem injuries balanced against the benefits of the cleanup itself? Ecology’s upcoming NEBA guidance should go a long way to addressing these dilemmas and bringing some common sense into certain cleanup decisions.

“Especially Valuable Habitat”
The new guidance is expected to introduce the concept of “Especially Valuable Habitat” and how to use it as a threshold for judging whether or not a NEBA may be appropriate for a particular site. It’s also expected to allow some flexibility regarding how injuries and benefits are quantified and balanced.

In the meantime, check for updates on when the new guidance is expected at Ecology’s website.