Laserfiche WebLink
placement of anon-chlorine based dust abatement chemical treatment), are important dust <br />suppression and sediment reduction techniques. <br />7. Weeds/invasive Plants <br />Noxious weeds aze a great threat to biodiversity and can displace native plants, producing <br />a monoculture that has little or no plant species diversity oi• benefit to wildlife. Noxious weeds <br />tend to gain a foothold where there is soil disturbance, such as construction sites and <br />pipeline/utility corridors. Impacts to native plant communities are much reduced when control <br />actions aze taken at an eazly stage of invasion, as weeds can be very difficult to eradicate once <br />they become established. Studies show that new roads and pipeline/utility ROWS can become a <br />pathway for the spread of invasive plants. We recommend that a Noxious Weed Management <br />PIan be prepazed in coordination with State and local agencies and included in the EIS. The <br />Plan should address control of weeds in all areas where ground disturbances will occur including <br />the mine, roads, pipelines, transmission lines, underground cables, railroad lines, etc. It should <br />also address such techniques as washing/cleaning equipment before entering more sensitive areas <br />to help prevent importation of seeds, etc. The current trend for weed infestations in the affected <br />project azea should be evaluated for mitigation effectiveness and improvements if warranted. <br />Yearly review and planning activity requirements for this concern, including evaluation of " <br />effectiveness to date, should be an on-going part of the plan. <br />8. Greenhouse Gas Emissions. <br />The Red Cliff project will generate greenhouse gases. The EIS should include an <br />evaluation of project greenhouse emissions and their potential control technologies to provide <br />public disclosure of this environmental impact. Analysis of the greenhouse gas emissions is <br />consistent with the Administration's policies to reduce U.S. greenhouse gas emissions over the <br />next 10 years without sacrificing economic growth. (See the Council on Environmental Quality's <br />Climate VISION web site). An analysis of this reduction ofthese emissions, covering the <br />expected design life of the project, would seem appropriate. Addressing such emissions in <br />proposed federal actions subject to NEPA is consistent with the 2005 decision from the 8th <br />Circuit Court of Appeals on the proposed DM&E Railroad as analyzed in the Final EIS prepared <br />by the Surface Transportation Boazd (Mid States Coalition For Progress, et al. v. Surface <br />Transportation Board, 345 F.3d 520 (8th Cir. 2003)). <br />9. Pollution Prevention. <br />Under Section 6602(b) of the Pollution Prevention Act of 1990, Congress established a <br />' national policy that details preferences for pollution prevention. Pollution prevention, also <br />known as "source reduction," encompasses practices which reduce, eliminate, or prevent . <br />pollution at its source. By reducing the total amount of pollution that is produced, there is less <br />waste to control, treat, or dispose of, and there aze less hazards posed to public health and the <br />environment. We recommend that the final EIS identify how CAM will avoid/reduce pollution <br />. 5 <br />