Adaptive Management Plan
If something happens, someone will do something, sometime....maybe.
If something happens, someone will do something, sometime....maybe.
One of the major flaws in Ecology's SEIS is it's reliance on adaptive management or more accurately a plan that is titled adaptive management but in reality has absolutely no mechanism to adapt to changing situations. It could be more accurately characterized as a monitoring plan. Adaptive management should be an active systematic process for continually improving management policies and practices by sequential learning from the outcomes of operational programs. It should be designed to experimentally compare selective policies or practices by evaluating alternative hypotheses. Ecology and Kinross want to redefine adaptive management and use it as a basis for the entire mine plan.
To put this plan in perspective, Ecology relies on this adaptive management plan for most aspects of the mine proposal including:
Dewatering impacts to seeps and springs
Dewatering and water supply impacts to steamflow
Fine sediment deposition and water quality changes to Marias Creek from the mine access road
Aquatic habitat improvements to mitigate for streamflow impacts from mine dewatering
Development rock management
Water treatment plant operations
Upland habitat protection, enhancement and management
Wildlife management along haul road
Kettle river tailings impoundment
The adaptive management plan is being relied on to evaluate the monitoring data and compare it to what is predicted in the SEIS and to evaluate compliance to the requirements of various permits including:
The NPDES for the collection, treatment and discharge of mine water,
The water rights for the use of surface water and ground water supply and mitigation,
The construction and operational stormwater,
The hydraulic permit approval for the construction and maintenance new culverts and stream restoration,
The permits on National Forest Land,
The waste discharge and Dam Safety for the tailings impoundment
Adaptive management details include an action threshold and indicates who would take what action. The specific plans have three phases;
Phase I (early action) based on 50% of predicted impact: Kinross would review data and determine the likelihood predicted impacts would be exceeded. If they think there would be a potential for greater impacts they would inform agency in their annual report. Take voluntary action and continue monitoring. The agency would take no action.
Phase II (planning) based on 80% of predicted impact: If Kinross decides monitoring suggests impacts would exceed predictions, they would then develop a Contingency Plan. The agency would meet with Kinross and develop a plan.
Phase III based on 100% of predicted impact: Kinross would implement Contingency Plan. The agency would oversee contingency actions.