also, i have personally documented nearly 30,000 individual S. wetlandicus in the past two years.

Recently have been communicating with Marlene Metz (Facebook) and found she was communicating with you! So when my hubby and I traveled thru Lyons last week on our way home from our Rocky Mountain National Park vacation, thoughts turned to you. Got on the internet and found this article. Enjoyed the beautiful Colorado scenery and applaud your conservation efforts. We have lived in Texas since 1980 and get to Colorado nearly every year – love it.

Let me hear what you have been up to since the 25th reunion when we last talked. Best to you, Margie

Recently have been communicating with Marlene Metz (Facebook) and found she was communicating with you! So when my hubby and I traveled thru Lyons last week on our way home from our Rocky Mountain National Park vacation, thoughts turned to you. Got on the internet and found this article. Enjoyed the beautiful Colorado scenery and applaud your conservation efforts. We have lived in Texas since 1980 and get to Colorado nearly every year – love it.

Let me hear what you have been up to since the 25th reunion when we last talked. Best to you, Margie

Thanks for your comment. I respectfully disagree. There is convincing evidence that some uranium mining and milling operations have the potential to result in discharges of pollutants that can harm native fish species. This evidence makes it reasonable to be concerned about the potential cumulative impacts of contaminants from uranium mining and milling operations on native fish species, particularly given that the endangered bonytail and razorback sucker are already on the brink of extinction.

The Environmental Assessment and the summary of a draft University of Arizona study that you reference appear to suggest that much of the uranium in the Colorado River may be naturally occurring and that uranium mining in the Grand Canyon region may not raise Colorado River water uranium and radioactivity levels to the EPA thresholds of health concern. I am not in a position to critically evaluate the strength of the conclusions in these two documents without further research, particularly given that the EA is in draft form and has not been approved by the agencies responsible for analyzing impacts of mining, and the University of Arizona study apparently has not been completed and released. The conclusions may be valid, however, it does not follow that uranium mining and milling operations do not have the potential to result in discharges of pollutants that harm native fish species.

Uranium mining and milling can result in discharges or runoff of water and sediment that contain a number of pollutants that can be toxic to native fish, including uranium, selenium, ammonia, arsenic, molybdenum, barium, copper, iron, lead, manganese, vanadium and zinc. The question of whether a particular operation is likely to result in discharges of pollutants that harm native fish is complex, and depends on a number of factors, including: 1) whether the geologic formations present in the area have the potential to leach pollutants of concern when disturbed through mining or milling processes, 2) whether there is a pathway for contaminants to move from the mine or mill site into waterways, and 3) whether the amounts of the pollutants that might move into the waterways are large enough to exceed lethal toxicity levels, or result in chronic toxicity that negatively impacts survival and reproduction over time.

I do not argue that every uranium mining and milling operation is likely to result in toxic discharges that harm native fish. However, near the Dolores River here in Colorado, there have been several instances in which uranium mines and mill tailings leached or discharged pollutants of concern into waterways that support native fish. For example, historic uranium mill tailings on Department of Energy lease tracts near the Dolores River contaminated the alluvial aquifer with uranium, selenium, manganese, molybdenum, nitrate, radium 226, radium 228, benzene, and toluene (Department of Energy 1995; Department of Energy 2005). According to U.S. Fish and Wildlife Service (2007),” Uranium processing facilities [along the Dolores River] operated during the late 1940’s through the 1960’s severely impacted the river and may have contributed to the decline of Colorado pikeminnow in the Dolores River drainage.” Valdez et al. (2002) found that, “Native fish composition and abundance were found to be poor downstream of the San Miguel confluence, a river reach heavily impacted by poor water quality due to uranium tailings”. More recently, discharge of treated water from dewatering activities at the Whirlwind Mine has exceeded state water quality standards for uranium and selenium on several occasions (Energy Fuels Resources Corporation 2008). In addition, along the Colorado River near Moab, Utah, a USGS study (USGS, 2002) concluded that ammonia concentrations entering the river from the Atlas Uranium mill tailings may present a risk to endangered fish species, and the Department of Energy recently began the process to move 16 million tons of these tailings away from the river.

Taken individually, small underground mining operations may not have major impacts on native fish, even when they result in discharge or runoff of small amounts of contaminants into river systems. However, degradation of water quality due to the cumulative impacts of pollutants from various sources has been implicated as a major factor in the declines of the four endangered Colorado River fish (U.S. Fish and Wildlife Service 1987; U.S. Fish and Wildlife Service 2008). Uranium mining and milling operations can contribute to water quality degradation that results from the combined impact of a variety of human activities. USFWS (2002, 2008) note that the four endangered Colorado River fish can be threatened by pollutants that result from accidental spills of petroleum products and hazardous materials, discharge of pollutants from uranium mill tailings and mines, as well as high selenium concentration in the water and food chain (U.S. Fish and Wildlife Service 2002; U.S. Fish and Wildlife Service 2008).

In addition, some pollutants of concern, such as selenium, can have chronic impacts on native fish, even at very low concentrations. Elevated selenium can not only be taken up directly from water by aquatic organisms, resulting in acute toxicity at relatively high concentrations, but can be taken up from food, and has a propensity to accumulate in the aquatic food chain, causing adverse effects on fish and waterfowl populations, including impaired reproduction, deformities, reduced survival and other problems (Chapman 1999; Lemly 1999; Hamilton 2004). Selenium contamination in the Colorado River basin has been implicated in the decline of the four endangered Colorado River fish species, and may be impeding their recovery (Hamilton 1999). There is evidence that high selenium levels may adversely affect reproduction and recruitment in these fishes (Stephens, Waddell et al. 1992; Stephens and Waddell 1998; Hamilton 1999; Osmundson, May et al. 2000; U.S. Fish and Wildlife Service 2008). Runoff or discharge of water with very low concentrations of selenium can result in adverse impacts on fish and waterfowl. One study in waters downstream from uranium mining and milling operations in Canada, have found that, in areas where water concentrations of selenium are very low (less than or equal to 1ug/L, and lower than the 5ug/L water criterion established by U.S. EPA), selenium has been incorporated into the food chain via primary producers, gradually built up in sediments and benthic biota, and reached levels that have the potential to cause reproductive impairment in fish (Muscatello, Belknap et al. 2008). In addition a short pulse event can quickly load an aquatic environment with selenium, and that selenium could then be conserved in the ecosystem for long time periods (Hamilton 2004).

Thus, to me it is reasonable to be concerned about the potential cumulative impacts of contaminants from uranium mining and milling operations on native fish species, particularly the critically endangered bonytail and razorback sucker.

I would be happy to provide any of the references cited here and listed below to you upon request.

Literature Cited
Chapman, P. M. (1999). Invited debate/commentary: selenium – a potential time bomb or just another contaminant. Human and Ecological Risk Assessment 5(6): 1123-1138.

Department of Energy (1995). Finding of no significant impact proposed remedial action at two uranium processing sites near Slick Rock, CO. Uranium Mill Tailings Remedial Action Project Office, Albuquerque, NM. DOE/EA-0339.

Department of Energy (2005). Verification monitoring report for the Slick Rock, Colorado, processing sites. Office of Legacy Management, Grand Junction, CO. DOE-LM/GJ896-2005.

Energy Fuels Resources Corporation (2008). Submittal of December 2007 discharge monitoring report and notification of non-compliance. Colorado Department of Health Water Quality Control Division, Denver, CO.

Hamilton, S. J. (1999). Hypothesis of historical effects from selenium on endangered fish in the Colorado River Basin. Human and Ecological Risk Assessment 5(6): 1153-1180.

Hamilton, S. J. (2004). Review of selenium toxicity in the aquatic food chain. Science of the Total Environment 326: 1-31.

Lemly, A. D. (1999). Selenium impacts on fish: an insidious time bomb. Human and Ecological Risk Assessment 5(6): 1139-1151.

Muscatello, J. R., A. M. Belknap, et al. (2008). Accumulation of selenium in aquatic systems downstream of a uranium mining operation in northern Saskatchewan, Canada. Environmental Pollution xx: 1-7.

Osmundson, B. C., T. V. May, et al. (2000). Selenium concentrations in the Colorado pikeminnow (Pytchocheilus lucius): relationship with flows in the upper Colorado River. Archives of Environmental Contamination and Toxicology 38: 479-485.

Stephens, D. W. and B. Waddell (1998). Selenium sources and effects on biota in the Green River Basin of Wyoming, Colorado, Utah. Environmental chemistry of selenium. W. T. J. Frankenberger and R. A. Engberg. New York, Marcel Dekker: 183-204.

Stephens, D. W., B. Waddell, et al. (1992). Detailed study of selenium and selected elements in water, bottom sediment, and biota associated with irrigation drainage in the middle Green River Basin, Utah, 1988-90. U. S. G. S. W. R. Invest. Report No. 92-4084.

U.S. Fish and Wildlife Service (2002). Bonytail (Gila elegans) recovery goals: amendment and supplement to the bonytail recovery plan. Region 6, Denver, CO.

U.S. Fish and Wildlife Service (2002). Colorado pikeminnow (ptychocheilus lucius) recovery goals. Region 6, Denver, CO.

U.S. Fish and Wildlife Service (2002). Humpback chub (Gila cypha) recovery goals: amendment and supplement to the humpback chub recovery plan. Region 6, Denver, CO.

U.S. Fish and Wildlife Service (2002). Razorback sucker (Xyrauchen texanus) recovery goals: amendment and supplement to the razorback sucker recovery plan. Region 6, Denver, CO.

U.S. Fish and Wildlife Service (2007). Recovery implementation program recovery action plan: recovery implementation program for endangered fish species in the upper Colorado River Basin. Region 6, Denver, CO.

U.S. Fish and Wildlife Service (2008). Programmatic biological opinion for water depletions associated with Bureau of Land Management’s fluid mineral program within the Upper Colorado River Basin in Colorado. Ecological Services Office, Grand Junction, CO.

USGS (U.S. Geological Survey) (2002). A Site-Specific Assessment of the Risk of Ammonia to Endangered Colorado Pikeminnow and Razorback Sucker Populations in the Upper Colorado River Adjacent to the Atlas Mill Tailings Pile, Moab, Utah, final report to the U.S. Fish and Wildlife Service, Division of Environmental Quality, Salt Lake City, Utah.

Valdez, R. A., W. J. Masslich, et al. (1992). Dolores River native fish habitat suitability study. Utah Division of Wildlife Resources, Salt Lake City, UT.

“It is easy to feel hopeless about the fate of our native fishes and the health of the Upper Colorado River system as a whole, given the ever-increasing demand for scarce water, the difficulties with managing the 40 nonnative fish species that have been introduced to the Basin, and a steady onslaught of proposals for uranium mines and other projects that will add toxic pollutants to the Colorado and its tributaries.”

That is a careless statement, Megan. See, for example, the Draft EA submitted to the Kaibab National Forest in mid-February that addresses the question of possible “toxic pollutants” being added to the Colorado River and its tributaries by uranium exploration and mining in the Grand Canyon region. This Draft EA, based on US Geological Survey data, can be found at http://public.dirxploration.fastmail.us/. The EA pollutant risk assessment results provided there are consistent with the baseline assessment of researchers at the University of Arizona that historical uranium mining and milling activity in the Colorado River basin have NOT affected the water quality of that basin. See the briefly Internet-available summary of the University of Arizona research originally posted by the Environmental Working Group and archived at http://www.dirxploration.com/EWG2232009.pdf. (”Briefly Internet-available” refers to the fact that EWG took down their organizationally-embarassing report within a week of its original publication. Apparently, EWG didn’t want to “dampen fears” — see odd title of their article.)

Very well said. I’m proud to have such analytical minds share the name, “Spangler.”

I am frequently caught on one side or the other of the “man bad, nature good” paradigm. It is a false premise, certainly, but one that nonetheless persists on its own inertia.

I think you are confused because this isn’t an issue that is black and white, and it seems that the author is acknowledging that by not saying “man bad, nature good.” Rather, it’s a complicated issue that there is no easy answer for. How do you show reverence for the early dwellers and what they left behind, without acknowledging that we too are inhabitants of the land and perhaps have the same right our ancestors did of living on and using the land?
As the author says, humans have always been part of the landscape. I think the reason for introspection and heightened concern on the parts of activists like Jerry Spangler is because of the reality that the humans that are part of today’s landscape have the power to inflict a much greater footprint on wilderness than their ancestors could ever have imagined, for good or bad.

I whole-heartedly agree. We must both protect the integrity of the scientific process, upon which our society has seen so much success, and we must also understand that information and data generated through a rigorous scientific process is part of the equation. The human element, whether via politics, discussion, debate, or other forums, is critical to pursue and advance.

Cheers,

BilFish