Public Comment. Volume III - Montana Legislature

Impact Analysis Studies and Proposed Mitigation Approach Page 7
The original impact study outlined in the State's comments (May 4, 1999 letter from MT
DNRC to TRRC) to the Womack study (1999) has been modified to allow it to take
place on-site concurrently with normal production. This study will address potential
impacts due to vibration, herbicide application, coal dust, derailment/spills, or any other
conditions or situations related to TRRC activity. Responsibility for the study design and
execution would be transferred to a third party, such as a graduate student or students
under the supervision of a local university professor or other researcher, to ensure
independence of findings and impartiality as well as to reduce overall costs. A description
of the modified impact study is included as Attachment A (Vibration and Impact Studies)
at the end of this document.
The results of this study, combined with information about critical factors affecting
hatchery production fiom the baseline study, should assist MT DFWP, TRRC, and the
'. mitigation committee in distinguishing whether impacts can be attributed to TRR
operation or to variations in hatchery conditions.
3.2 Study Period
3.2.1 Baseline Study.
It is assumed that the baseline study will be initiated during the two years prior to
TRRC's anticipated commencement of construction and will not delay that construction.
Ideally, this study will not require alteration of hatchery operations, and additional data
collection will be incorporated into the day to day routine. Once started, data collection
will be continued through the entire construction period and at least two years into fill
operation to develop a complete record of changes in circumstances and responses at the
hatchery level. Thus, the baseline study and data gathering activities to document changes
will span, at a minimum, a six year period. Detailed record keeping will also ensure that
impacts will be detected as soon as possible, and that any losses will be kept to a
minimum by timely response. Given that construction is slated to begin within the next'
two to three years, the baseline study should begin this spring (2000). Because currency
and continuity of data is important, if the study begins and then TRRC is unable to begin
construction as scheduled, MT DFWP assumes that the baseline study will be fbnded
continuously until two years after operation has begun.
3.2.2 Impact Studies
The vibration and impact studies should also take place before construction begins to
avoid any confounding effect from TRRC construction activities or operations. However,
since these experiments will be highly controlled and more laboratory based, there is no
need for these to continue into the construction period. It is anticipated that two to.three
years will be required for design, set-up, and data gathering for these studies. Additional
time may be required for data analysis, but the goal is to have the final results in-hand
before construction is complete.
~ . ~ T I I l L I ~ u C r ? l dI.lr.M2bc
r r l
-228- Volume Ill: Public Comment