The Wild Fishery of the Smith River Basin: DEQ should evaluate the baseline conditions of the Sheep Creek and Smith River wild and native trout fishery. The Tintina project has the potential to dewater and contaminate both surface water and groundwater connected to the Sheep Creek tributary, and then to the main Smith River.  There is clear evidence that wild trout, and potentially some native fish species, use Sheep Creek extensively for spawning and as a cold water refuge during low, warm water conditions in the Smith.  There is also clear evidence that during their life-cycle, trout migrate between Sheep Creek, the Smith River, and the Missouri River. In addition, during periods of low water, Sheep Creek is the largest source of clean, cold water to the mainstem river, which is vital for the health of the entire Smith River fishery all the way to its confluence with the Missouri River. Considering that impacts to water quality and quantity in Sheep Creek are a concern for the fishery all the way into the Missouri, there must be a thorough baseline study of this extensive, at-risk fishery. DEQ should include and rely upon Fish, Wildlife, and Parks, Region 4 fishery biologists and managers in the EIS analysis.

Jobs and Economic Growth in Outdoor Recreation:  In evaluating the possible negative impacts to water quality and quantity associated with Tintina's mining proposal, DEQ should seriously consider the hit this would cause to a significant portion of Montana's robust and growing tourist and outdoor recreation economy.  Tourists spend at least $350 million annually in Montana on fishing, which is at the heart of the state's $7 billion per year outdoor recreation economy.  That economy generates over 71,000 Montana jobs.  Around 7,000 people float the 60-mile permitted stretch of the Smith River annually, with the hope of connecting to a part of Montana that is still wild. The fact that the Smith is the only permitted river out of Montana's many amazing rivers makes clear how valuable it is for our recreation and tourist economy.  Economists have determined that fishing on the Smith River alone contributes up to $10 million annually for Montana's economy, and that doesn't include other recreational, agricultural and tax benefits it generates. These are indefinitely sustainable dollars, and they benefit real people and real jobs  that would be lost if the river is degraded. Outfitters who have worked for over twenty years on the Smith River have collectively employed hundreds of guides and other staff.  Add to these careers the cost taxpayers might have to foot to clean up a big spill, or to keep toxins from leaking in the future, and it becomes a high price to pay. Unfortunately, the citizens of Montana will assume all the risk, while the corporate boardrooms of Tintina's owners in Perth, Australia and New York City reap the rewards.

Water Quantity in Sheep Creek and the Smith: The Smith River and Sheep Creek already suffer from low flows during most years, putting pressure on downstream water users and preventing the fishery from reaching its potential. Tintina plans to pump large volumes of groundwater in order to keep the underground tunnels dry during mining. This could alter flows in Sheep Creek and other streams that rely on that groundwater for a portion of their flows. DEQ should evaluate the potential impacts to Sheep Creek and the Smith River from reduced flows as a result of mine activities.

Water Quality in Sheep Creek and the Smith: DEQ should evaluate the potential long-term impacts to water quality in the Smith River watershed from acid mine drainage because the Tintina Project is a sulfide deposit.  When sulfide minerals are dug up and exposed to air and water, they can react to form acid mine drainage, which is toxic to fish and other aquatic life.  Once acid mine drainage develops on a large scale, it is impossible to stop, and it can continue for hundreds of years - requiring expensive long-term treatment.  DEQ's analysis of acid mine drainage potential for this mine proposal should include evaluation of mine tailings, which will require isolation from air or water to safeguard against leaching toxins.  Other mines in Montana that have developed acid mine drainage have caused lasting damage and cost taxpayers tens of millions in treatment costs. DEQ should also evaluate the potential water quality impacts of other harmful metals, such as arsenic.