Draft Wishbone Hill Health Impact Assessment Comments

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The Draft Wishbone Hill HIA is available online to the public at http://www.epi.alaska.gov/hia/.

The “rapid appraisal” Health Impact Assessment for the Wishbone Hill proposed coal mine contains too many data gaps and inaccuracies to be a fully informative document that families in our community can rely on to make personal decisions about their health and welfare.  Even with this incomplete information, the rapid appraisal HIA indicates that the proposed coal mine at Wishbone Hill poses substantial health risks to people living nearby.  We have a right to an accurate assessment of the health risks involved in a major development project in our neighborhood.  A comprehensive HIA should be done for the Wishbone Hill coal mine before any mining activity is permitted.

Sample Comments:

Document Name Draft Wishbone Hill HIA 
Section 1.0 Introduction
Sub-Section 1.4.3.1 Comprehensive HIA
Page Page 3
Figure/Table
Comment “The hallmark of a comprehensive HIA is collection of new data, to address critical data gaps identified during the scoping process…A comprehensive HIA may be appropriate for projects that involve: … Major disruption of subsistence practices; Major impacts to key social determinants of health; and information gaps related to a well-known aspect of a project.(WBH HIA pg 3)” Based on these criteria, a comprehensive HIA should be done for the Wishbone Hill coal mine before any mining activity is permitted. Critical data gaps for this mine include: inadequate baseline water quality, inadequate groundwater and aquifer mapping, unknown risk of surface and groundwater contamination, lack of noise studies, lack of light /visual effects studies, lack of information on physical effects of blasting, unknown risk of air pollution by both diesel exhaust and particulate matter (PM2.5), and inadequate data on the risk of accidents from coal transportation. Numerous people in Chickaloon Village have described the subsistence and other traditional practices that would be disrupted by this mine. Key social determinants of health, such as psychological distress and community conflict are already well-known problems related to the proposed mine, and these will worsen significantly if the mine is developed.

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Document Name Draft Wishbone Hill HIA 
Section 2.0 Places, Persons, Project
Sub-Section 2.12.3 Mine Facilities; Hours of Operation
Page Pages 21-22
Figure/Table
Comment The hours of operation for mining activities, which cause exposure to noise, blasting, fugitive coal dust and diesel fumes, are misrepresented. The HIA describes daytime operation only for the mine, but claims that the coal trucks will run at night. Trucks will make multiple trips per shift, so coal loading and truck traffic will add to the noise, coal dust, light, and diesel fumes all night, disrupting sleep and increasing local exposure to airborne contaminants. Usibelli’s permit application also includes 24/7 operations with no restrictions or mitigations, so there is no documented basis for daytime-only mining operations.

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Document Name Draft Wishbone Hill HIA 
Section 7.0 Prioritizing Health Effect Categories
Sub-Section 7.2.2.2 Accidents and Injuries Data Gaps
Page Page 117
Figure/Table
Comment The transportation route to Port Mackenzie is not adequately assessed. The focus is all on the Glenn Highway, and the risk for driving coal trucks out Knik-Goose Bay Road was not fully characterized.

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Document Name Draft Wishbone Hill HIA 
Section 7.0 Prioritizing Health Effect Categories
Sub-Section 7.2.3.3 Exposure to Potentially Hazardous Materials Potential Impact
Page Page 119
Figure/Table
Comment Damage to houses from blasting should be included in the list of potential impacts. Broken windows in the winter could cause frozen pipes and could cause significant property damage, including rendering a house uninhabitable within hours. Usibelli representatives have stated publicly that the blasting will likely break windows, so even the mining company admits that this is a plausible scenario. Mitigation should include a requirement that Usibelli set up a fund for reimbursing local residents for all repair costs, lodging and food for residents displaced from their homes, and compensation for stress. Even with this mitigation, dozens of people living near the mine will still bear the burden of mental and physical health problems known to be caused by stress and anxiety.

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Document Name Draft Wishbone Hill HIA 
Section 7.0 Prioritizing Health Effect Categories
Sub-Section 7.3 Overall prioritization of Health Effect Categories
Page Pages 125-127
Figure/Table Table 37
Comment Of the eight Health Effect Categories listed, six are ranked “High” for stakeholder concern, and seven are ranked either “High” or “Medium” for the potential impact of that health effect, and for the likelihood that the health effect will happen. This indicates that we have substantial information that coal mining at Wishbone Hill will damage the health of the community. This mine should not be permitted without significant changes to the operations plan that will prevent these negative health effects.

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Document Name Draft Wishbone Hill HIA 
Section 8.0 Mitigation
Sub-Section 8.2 Mitigation Recommendations
Page Pages 127-131
Figure/Table
Comment The recommendations for every HEC are completely inadequate. They include closing some, but not all of the important data gaps. The recommended mitigations do not actually mitigate damage to human health, but will only record (monitor) the effects.

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Document Name Draft Wishbone Hill HIA 
Section 8.0 Mitigation
Sub-Section 8.2 Mitigation Recommendations
Page Pages 128-129
Figure/Table
Comment Modeling and monitoring should be done. However, mitigation should also include required changes to mining activities (including cessation) if modeling or monitoring shows human exposure to contaminants. These changes should be mandatory, and no mining permits should be issued until all modeling is complete, baseline data gathered, and an operations plan that protects human health and the environment is submitted to the stakeholders and the regulatory agencies.

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