On November 6, 2018, Missouri Coalition for the Environment (MCE) submitted supplemental comments on Doe Run’s proposal to permanently redirect the flow of the West Fork of the Black River. MCE’s comments highlight the need for Doe Run to put forward a more robust mitigation plan, especially in light of how much time has elapsed since the damages were made in 2014.

The Doe Run Company mines lead and other materials in rural Reynolds County, two hours south of St. Louis. In April 2014, a series of structural failures inside Doe Run’s mines led to sinkholes, flooding, and the company pumping lead, cadmium, and zinc-laden water into the West Fork Black River.

Doe Run made an emergency decision to literally move the Black River to avoid the flow from entering the mine itself. At the time, the diversion was meant to be a temporary, emergency response. Now, Doe Run is hoping to make the Black River change permanent.

Local communities were understandably alarmed by the sinkholes, one of which threatened the historic West Fork Sutterfield Cemetery. The diversion of the river has dramatically impacted the river’s ecology, destroyed aquatic ecosystems, and even caused the popular “Granddaddy” swimming hole to dry up completely.

Over the last four years, MCE submitted a series of Freedom of Information Act (FOIA) requests to the U.S. Army Corps in order to gather key information about Doe Run’s proposal to permanently divert the Black River and to ensure that the company is accountable for the long-term wetland and ecosystem impacts.

MCE submitted initial comments to the proposal in April 2018. Those comments focused on the significant, irreversible impacts to the recreational and aesthetic values of the river if the diversion were to be made permanent. MCE’s April comments also analyzed Doe Run’s proposed mitigation efforts, based on the very limited information presented in the public notice.

Ten days after MCE submitted these comments, the Corps released 1,400 pages of documents related to Doe Run’s permit application in response to MCE’s FOIA request. The documents revealed that Doe Run is not doing nearly enough to mitigate the impacts of the environmental destruction caused by the mine’s structural failures and mismanagement.

MCE’s supplemental comments were submitted in early November 2018 and are based on the hundreds of released FOIA documents. The supplemental comments highlight the need for Doe Run to put forward a more robust mitigation plan especially in light of how much time has elapsed since the damages were made in 2014. What’s more, the FOIA documents revealed that Doe Run’s mitigation plan relies heavily on mitigation banking — a system of credits and debits devised to ensure that environmental losses resulting from development are compensated for by preserving and restoring wetlands, native habitats, or streams elsewhere. Instead of purchasing mitigation credits from the closest mitigation bank, Doe Run intends to purchase credits from a mitigation bank nearly 75 miles away, and the company provides no sound rationale for doing so. Choosing the closer mitigation bank would offset the environmental impacts as close to the degraded site as possible and would strengthen the mitigation plan.

You can read MCE’s supplemental comment letter to the Corps, urging Doe Run to put forward a more robust mitigation plan HERE.