Letter regarding Elbow Lake
June 1, 2023
Letter regarding Elbow Lake
Commenters on the MT DNRC’s Elbow Lake gravel pit/asphalt plant proposal received notice on May 15 that it has been approved. The MT DEQ had already approved the permit, on April 27. In case you missed it earlier, this is the proposal by Kalispell-based LHC Inc. to establish a new 21-acre gravel pit and asphalt plant directly beside the Clearwater River, across the road from the Blackfoot-Clearwater Game Range, within a parcel designated Tier 1 Community Type of Greatest Conservation Need because it is grizzly and elk habitat, and within ½ mile of 30-ish full-time residences and recreational cabins.
The DNRC’s environmental assessment includes 70 pages of comments submitted by citizens – 90 comments in all, some from local property owners and many from farther afield. With one exception the commenters opposed the permit. The concerns expressed are many and should have been carefully considered by the agencies charged with protecting our environment and natural resources: disturbance to wildlife who use this exact corridor for seasonal migration, air pollution, water pollution, noise, and the list continues.
In just 3 pages in an appendix to the EA, the DNRC dismisses every one of the concerns expressed. A few of the more egregious examples:
- In response to a carefully detailed analysis of risks to the Clearwater River and waters beyond, submitted by the Clearwater Resource Council and substantiated in a map developed using a widely accepted hydrology mapping tool, the DNRC simply deems the map “not accurate” – without providing justification for the assertion.
- Many property owners are concerned about a negative impact on their property values. The DNRC completely dismisses these concerns: granting the permit “may or may not have an impact upon adjacent private land values.”
- Missoula County officials – representing the citizens who will be most affected - and others requested a 30-day extension of the public comment period or a public hearing.
The DNRC disregards these requests as not warranted, due to “the complexity of the project and the number of substantive issues already identified.” Doesn’t this very reason argue in favor of additional exchange with concerned citizens?
Where they do acknowledge the risks to wildlife, human health, and air and water quality, the DNRC minimizes these risks by declaring them “negligible” and “short-term.”
Here is what the DNRC means by “short-term”: 17 years. This is best case, actually: the permit will be issued through 2040 and could be renewed.
Why do Montanans need this gravel pit in this location? We don’t! It will be used for the Salmon Lake and Clearwater Junction highway projects. The need for the gravel is not disputed - but there are at least five existing gravel pits within a 10-mile radius, as listed in the public comments and on the DEQ’s website. LHC itself holds a permit at an existing site just east of Ovando. And while the DNRC’s scoping notice encouraged the proposal of alternatives to the new pit, their EA dismisses these suggestions as not within the scope of the analysis.
Stakeholders seeking information from the DNRC on how to appeal the decision, after days of receiving essentially no information, were eventually informed that there is no recourse beyond a legal challenge. That doesn’t mean we should stay silent.
If you believe the DNRC’s EA is inadequate, or that they should engage the public they are meant to serve in a meaningful way by holding a hearing or extending the comment period, tell them so. You will find the EA here [https://dnrc.mt.gov/TrustLand/subsurface-resources/Elbow-Lake-Gravel-Project] (scroll down and click on Environmental Assessment).