Third Party Technical Review of Environmental Permitting Documents
Reviewing the impacts disclosed in environmental impact statements for communities, non-profits, and environmental law firms.
Elemental Statistics is an environmental consulting firm specializing in third party review of EISs and other permitting documents, often for projects involving fossil fuels or mining. We assess if the scope of the risks and impacts are truly represented not only in the EIS but also in the supporting research and, when available, the data.
NEPA requires that project proponents and lead agencies take a hard look at the potential impacts from proposed projects in environmental impacts statements (EISs). EISs are highly technical documents that may be thousands of pages long. They often include multiple appendices and refer to research that has not been through thorough peer review. Given the short period for comments, the volume of material, and the specialized knowledge required, it is often difficult, if not impossible, for members of the potentially affected communities to assess the adequacy of the impact disclosures and any associated mitigation and to make substantive comments.
We break it down for you.
Contact Us
susan@elementalstatistics.com
(206) 719-4730
Case Studies
Alaska oil and gas industry spill impacts on polar bears and walruses
Client: Defenders of Wildlife
As part of the permitting process for being allowed to work in the Beaufort Sea and surrounding land areas, several oil and gas companies needed to describe the potential impacts on walruses and polar bears, including those from hazardous materials spills. Until all the spill rates of different sizes, substances, and locations are calculated using up to date data and coupled with complete and relevant exposure variables for the component ongoing and planned activities, the analysis of spill risks described in the proposed rule for incidental take does not address the true threats to walruses and polar bears.
Stibnite Gold Project
Clients: Idaho Conservation League and Advocates for the West
The Stibnite Gold Project (SGP) will require large quantities of more than 30 different hazardous materials being transported to and from the mine site in thousands of heavy truckloads each year. Those hazardous materials include fuels, explosives, acids, and toxic materials, but the dangers posed by the reagents are not discussed. Overall, the analysis of the potential impacts from hazardous materials in the SGP DEIS is inadequate to make an informed decision.
Alaska Mining Spill Retrospective
Clients: Brooks Range Council, Earthworks, National Parks Conservation Association, and the Tanana Chiefs Conference
Alaska has a long history of hard rock mining. In this analysis, Elemental Statistics compared the spill risks presented in the permitting documents from Fort Knox/True North, Greens Creek, Kensington, Pogo, and Red Dog mines with the records in spill databases from the Alaska Department of Environmental Conservation, the Coast Guard National Response Center, and the Pipeline and Hazardous Materials Safety Administration.
Pebble Mine Fish Habitat Modeling
Client: Wild Salmon Center
Co-author: Gordon Reeves
One of the claims of the Pebble Limited Partnership is that placing a mine at the headwaters of three streams would not reduce or harm salmon habitat, but would actually improve stream flows for fish. In this analysis we considered the baseline habitat sampling along the North and South forks of the Koktuli River and Upper Talarik Creek, the underlying mechanics and assumptions of two fish habitat usage models, and predicted stream flows if Pebble Mine were developed.
Pebble Mine Spill Risk Analysis
Client: Wild Salmon Center
This analysis was a review of the spill risks associated with the transportation corridor and potential releases from tailings storage facilities. The release scenarios considered in Pebble Limited Partnership’s (PLP’s) Final EIS were limited to a small subset of spill sizes, substances, and sources. Our review of the transportation corridor considered the quantities of diesel, ore concentrate, ore concentrate slurry, and reagent movement via trucks, barges, and pipelines in light of historical spill data from Alaska. We also applied basic rules of probability to the results of PLP’s tailings storage failure modes and effects analysis.
SPOT Offshore Oil Terminal in the Gulf of Mexico
Client: Earthjustice
The Sea Port Oil Terminal (SPOT) Deepwater Port Project draft EIS used two models to analyze oil spill size, frequency, and fate. We analyzed both models for consistency of their inputs, assumptions, and results, and for technical flaws. We coupled spill data and estimates of spill rate from the Bureau of Ocean Energy Management with estimates of the volume of oil that would be handled at the terminal to find the number of spills expected in four different size classes.
Get in Touch
If your community has concerns about the conclusions reached in NEPA environmental permitting documents, particularly those related to petroleum and mining industry projects, Elemental Statistics can help evaluate where the impacts are fully disclosed and scientifically valid and where there are gaps that should be addressed. All stakeholders and decision makers should be fully informed of potentially significant risks and impacts.