The U.S. Fish and Wildlife Service says it used the best available science to reach its biological opinion that the Rosemont Mine won鈥檛 jeopardize 12 endangered species living nearby.
The mine鈥檚 critics note that two other federal agencies, including the Environmental Protection Agency, have said that science is far from good and that the computer models underlying it are seriously flawed.
The wildlife service used Forest Service forecasts, based heavily on three computer models, to help shape its opinion that the mine is unlikely to dry up neighboring Cienega Creek in at least the next 150 years, although it could dry up part of a tributary.
The biological opinion also concluded that the mine won鈥檛 destroy the endangered species鈥 critical habitat.
Completion of that opinion, released last week, was a key step required for final decisions on the $1.5 billion mine by the Forest Service and the Army Corps of Engineers.
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鈥淵ou may have heard the saying that all models are wrong and some are useful,鈥 said Steve Spangle, field supervisor for the wildlife service鈥檚 蜜柚直播 ecological services office. 鈥淯nless you have a crystal ball, you need a scientific model to predict the outcome.
鈥淧eople always take shots at models and the models by definition include assumptions that may be right or wrong. You take the best fit assumptions, and model those and come out with a series of possible outcomes. There are always going to be criticisms of any model 鈥 that is the nature of the beast,鈥 Spangle said.
鈥淲e did what the law requires, which is using the best available information,鈥 he added.
But as the Forest Service kept producing environmental reports relying on the computer models over the years, the EPA and the Bureau of Land Management kept challenging them.
The EPA and BLM have questioned the very use of computer models to predict what could happen to Cienega Creek 150 to 1,000 years from now. The EPA has urged the Forest Service to conduct a formal risk assessment that doesn鈥檛 employ computer models.
While the Forest Service has done many runs of the models, some things simply aren鈥檛 knowable, said Jason Brush, wetlands office supervisor in the EPA鈥檚 San Francisco regional office.
鈥淚t comes down to risk 鈥 what鈥檚 the best state of our knowledge of risk? We have drought and climate change in an arid state. There鈥檚 a debate over this or that model, and significant questions of whether it will happen in X or Y year. Everything we鈥檝e seen suggests there will be impacts,鈥 Brush said in an interview last month.
Last week, the EPA, asked for comment on the biological opinion, said only, 鈥淭he EPA remains engaged in the multi-agency process for the Rosemont Mine proposal.鈥
BLM spokesman Adam Milnor said the agency probably won鈥檛 comment until the Forest Service and the Army Corps of Engineers make their decisions. The BLM legally can protest the Forest Service鈥檚 decision, while the EPA can seek a higher review of it and can veto the Army Corps decision.
Also last week, the 蜜柚直播-based Center for Biological Diversity, which opposes the mine, released a study it commissioned from a hydrologist that blasted the Rosemont models. Issues with the models鈥 basic methodology, calibration and other aspects are so great that it鈥檚 difficult to trust the Forest Service鈥檚 conclusions about Rosemont鈥檚 impacts, said the report from Robert Prucha, of Integrated Hydro Solutions in Golden, Colorado.
鈥淭here鈥檚 a series of steps used to create a model and there are actually industry standards used to create them, to collect data and to characterize the natural systems, 鈥 Prucha said in an interview. 鈥淚 had trouble with a number of steps they took. My sense is that they made some mistakes.鈥
On Friday, Coronado National Forest Supervisor Kerwin Dewberry and Spangle said they鈥檒l be reviewing the reports.
鈥淥ur environmental analysis of the project involved detailed study of complex subjects. We believe a thorough analysis utilizing the best available science was conducted during our process, in compliance with the National Environmental Policy Act,鈥 Dewberry said.
CONSERVATION AREA
Cienega Creek is the centerpiece of the Las Cienegas National Conservation Area. That鈥檚 a federally owned parcel of grasslands, pools, streams and cottonwood groves a few miles east of the mine site. It鈥檚 also the centerpiece of the debate over the Rosemont biological opinion and the computer models.
Cienega and its tributaries, wetlands and pools are home to eight of the 12 imperiled species studied. Of them, the endangered Gila topminnow is particularly dependent on the creek.
In 1998, the wildlife service wrote in a topminnow recovery plan that Cienega is the single largest topminnow habitat, stretching nearly six miles at the time although it has since shrunk some. Cienega holds by far the U.S.鈥檚 largest topminnow population, one of six natural populations (along with 40 that were reintroduced) and the only one left on public land, the service said in the Rosemont biological opinion.
The topminnow is abundant in upper Cienega Creek inside the BLM-owned conservation area. It has also been found in Pima County鈥檚 Cienega Creek Natural Preserve, downstream of Las Cienegas.
The concerns about Cienega arise because construction of the mine would require digging a half-mile-deep open pit. The pit would 鈥渇unction as a well,鈥 pulling in surrounding groundwater, the biological opinion said.
That has raised concerns that the depleted aquifer would have less water to supply Cienega Creek.
The models that forecast how the groundwater would behave were produced by two Rosemont consultants 鈥 Tetra Tech and Montgomery & Associates 鈥 and by Tom Myers, a Nevada hydrologist hired by Pima County, whose officials oppose the mine.
Their analyses were refined by Forest Service reviews, ending with a supplemental biological analysis last year from that agency.
From there, the wildlife service鈥檚 opinion said two key stretches of the Upper Cienega would likely lose at most 11 percent of their streamflow after 150 years during June, the driest month. In two key stretches of Lower Cienega, the creek would still carry 98 percent and 89 percent of its June streamflow, respectively, the biological opinion said.
But for tributary Empire Gulch, a third of a mile stretch of perennial stream could start running only after storms, the opinion said.
Empire Gulch has no topminnows, although it does hold the threatened Chiricahua leopard frog, Western yellow-billed cuckoo and northern Mexican gartersnake, and the endangered Gila chub and Southwestern willow flycatcher.
Last week, the wildlife service鈥檚 Spangle noted that his agency based its conclusions on what could happen in 97.5 percent of all possible outcomes predicted by the Forest Service. While the biological opinion didn鈥檛 look at the worst-case scenario, it examined a wide range of possibilities, he said.
鈥淭he analogy is predicting the path of a hurricane,鈥 he said. 鈥淲hen a news report tries to predict that, they have a pretty good idea of where it hits tomorrow but the farther out you go, the wider the range of possible outcomes. With the unpredictability of this going out a century or more, we felt we covered 97.5 percent of possible adverse effects.鈥
In consultant Prucha鈥檚 new report for the anti-mine biodiversity group, he took aim at assumptions used for the models and what he said was limited data collection from the Las Cienegas area. He said the models failed to use standard hydrological practices and did not account for Las Cienegas鈥 current groundwater flow to understand how the mine might affect it.
鈥淭hey failed to use the best modeling science. They cherry picked the data, to secure the results they desired,鈥 said Robin Silver, the biological diversity group鈥檚 conservation chairman.
GROUNDWATER IMPACTS
Spangle also said the wildlife service and Forest Service made extensive use of U.S. Geological Survey scientists in conducting their reviews, the mine鈥檚 impacts and the computer models. The Geological Survey is generally considered to be the most neutral agency involved in the mine dispute.
Not only did USGS scientists review the groundwater models, they also did separate reviews of three consultant reports that looked more closely at the mine鈥檚 impacts on Cienega, said Jason Douglas, a wildlife biologist for Fish and Wildlife.
鈥淲e needed professional interpretation of what those models would tell us,鈥 Spangle said. 鈥淭hey believed that we were using the best models available.鈥
Mine opponent Silver criticized Spangle鈥檚 statement, since the USGS last year took issue with the Forest Service, outlining three steps it could take to 鈥渟ubstantively improve鈥 the model鈥檚 ability to simulate the area鈥檚 groundwater鈥檚 behavior, according to a Forest Service memo.
The Forest Service balked, saying none would likely change the models鈥 basic conclusions or bring significant gains in knowledge, the March 31, 2015, Forest Service memo said.
鲍厂骋厂鈥檚 Jim Leenhouts said he can鈥檛 recall his scientists making the 鈥渂est models available鈥 statement verbally or find written comments to that effect. Leenhouts, director of the survey鈥檚 蜜柚直播 Water Sciences Center, added that it鈥檚 possible such a comment was made: 鈥淭hose are the available models.鈥