North Coast Chapter - CNPS Response to SDEIS for the NICORE Mining Proposal By Annie Eicher

The following is a response to the SDEIS for  the NICORE Mining Proposal written by Annie Eicher, Conservation Coordinator for the North Coast Chapter CNPS.    To find out more about the NICORE Mining Project, please visit the Siskiyou Project website located at   

North Coast Chapter
P.O. Box 1067, Arcata, CA 95518
January 27, 1999
Joel King, District Ranger
Illinois Valley Ranger District
26568 Redwood Highway
Cave Junction, OR 97523

RE: Response to the SDEIS for the Nicore Mining Proposal

I'm writing on behalf of the North Coast Chapter of the California Native Plant Society to urge you to select the "No Action   Alternative" for the Nicore mining proposal within the Rough and Ready Creek watershed.
The California Native Plant Society (CNPS) is a nonprofit organization of over 10,000 amateurs and professionals dedicated to the preservation of  California's diverse flora. CNPS conducts a variety of educational programs and conservation efforts all focused on long-term protection and preservation of native flora in its natural habitat. The North Coast Chapter represents over 250 members in Del Norte, Humboldt, Trinity and western Siskiyou Counties. 
On May 1, 1998, we submitted to you our comments on the DEIS for the NICORE mining proposal. We stated our opposition to the mining proposal and expressed our concern about the devastating impacts of mining on the unique and sensitive botanical resources of the Rough and Ready Creek area. 
Despite the new proposed alternatives to the original mining plan, we still endorse the "No Action Alternative." We maintain that Nicore has no right to mine Rough and Ready Creek, considering the high ecological values of the area and the current and foreseeable depressed market conditions for nickel-laterite ore. We recommend that you make a determination on Nicore’s right to mine by taking these steps:
1) Conduct validity examson the mining claims prior to approving any surface disturbing activity within the entire Rough and Ready Creek drainage; and
2) Withdraw the Rough and Ready Creek/South Kalmiopsis area from mineral entry. 
The proposed mining couldirretrievablydamage rare plant populations known to occur in the Rough and Ready Creek area. Mining activities will also increase the risk of spreading Port Orford cedar (POC) root disease. The wide-ranging spread of this disease is placing POC in jeopardy despite control efforts by the Forest Service. 
The botanical richness of Rough and Ready Creek was formally recognized by the establishment of the Rough and Ready Creek Botanical Area (RRBA) with "the goal of protecting, preserving, and enhancing the exceptional botanical features of these areas" (Land and Resource Management Plan, Siskiyou National Forest, page IV-87). The "Desired Future Condition for Botanical Areas" is that "natural physical and biological processes will prevail without human intervention. Plant and animal life inhabiting these unique ecosystems will continue to flourish" (Land and Resource Management Plan, Siskiyou National Forest, page IV-87).  Additionally, the botanical resources are also recognized as an "Outstandingly Remarkable Value" within the Rough and Ready Creek corridor (Nicore Mining Plan of Operations, DEIS, page 3-5). The Forest Service guidelines dictate that management activities  and uses within botanical areas be consistent with the values for which these areas were created.
To say that mining is inconsistent with the botanical and geologic values for which the RRBA was created would be an understatement. This inconsistency exists because of the antiquated 1872 Mining Act. This act is resulting in uses that conflict with the Forest Service's own designated land management prescriptions. These conflicting uses have become the greatest threat to the rare plants endemic to the ultramafic substrate of northwestern California and southwestern Oregon and may ultimately lead to federal listing of an entire suite of species.
Siskiyou National Forest Standard and Guideline 10-2 states that "Areas with mineral potential should be recommended for withdrawal from mineral entry only when mitigation measures would not adequately protect other resource values which are of greater public benefit" (Land and Resource Management Plan, Siskiyou National Forest, page IV-55). Clearly the botanical resource
values in RRBA are of greater public benefit than the minerals that would be extracted under the current proposal.
We urge you to adhere to your standards and guidelines as set forth in your Land and Resource Management Plan and initiate the process of withdrawing these claims so the RRBA can be managed in a manner consistent with it's special values.
We strongly encourage you to take measures now towards providing permanent protection of the Rough and Ready/South Kalmiopsis Area from mining. Thank you for taking our comments into consideration.
Annie Eicher
Conservation Coordinator
Cc: Vice President Al Gore
Sen. Dianne Feinstein
Sen. Barbara Boxer
Rep. Mike Thompson
CNPS North Coast Chapter: Comments on Nicore DSEIS, 1-27-99

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California Native Plant Society - North Coast Chapter
P.O. Box 1067 Arcata, CA 95518-1067
Last updated February 1999