An operating mine in the Chilkat Valley is unlikely to undergo a complete Environmental Impact Study. Any analysis will be splintered over various agencies, jurisdictions, and piecemealed through several limited actions.

The 2016 road application on BLM land did not include an underground adit, although Constantine stated this intent to investors. As a result, the Environmental Assessment (EA) found no significant impact. Another application was submitted to extend the road to state land. The public review documents gave no information about activities on state land. This information was not revealed until the final decision. Again, no significant impact, no Environmental Impact Study (EIS).

On state land, Constantine was granted a permit for Phase 1 by DNR but this was not revealed to the public until months after the appeal window had closed. It contained information on the underground workings, but permits for this (Phase 2) have been be applied for separately.

This is where we are at. The Phase 2 plan requires permits for waste rock storage and disposal of tunnel seepage water. There will be a public comment opportunity.

Any future expansion of the road on BLM might require an EA if Constantine does not broker a land transfer to the state. Activities in wetlands regardless of jurisdiction would require an Army Corps analysis.

Even a full EIS for a mine would be incomplete because it would only cover the mentioned 15-year life-of-mine. Constantine will continue to explore. Greens Creek was a 12-year life-of-mine 30 years ago.

Guy Archibald

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