Make the Corps study the whole Ambler mining district

Issues on the record, awaiting the decision

• PendingThe concentrate goes out by truck.

  The concentrate goes out by truck. The company's technical report plans about 46 containers of concentrate a day, roughly 23 truck trips a day on the Ambler Road, then rail from Fairbanks. At Red Dog, BLM's own supplemental EIS reports concentrate dust up to 2.5 miles from the haul road even with sealed lids, and heavy metal dust that can persist in the soil for many decades. The EIS should model concentrate dust along every stage of the haul, take baseline metals samples in soil, plants and water before any hauling starts, and set the monitoring result that would stop it.

  From MTJP editorial review

• PendingThe Western Arctic Caribou Herd counted 490,000 in 2003 and 121,000 in the 2025 photocensus, and its working group calls Critical, Declining the right management category.

  The Western Arctic Caribou Herd counted 490,000 in 2003 and 121,000 in the 2025 photocensus, and its working group calls Critical, Declining the right management category. Between 88 and 95 percent of households in the Kobuk River communities use caribou. The EIS should analyze delay and deflection of the herd from the mine's concentrate traffic and access roads together with the Ambler Road, at the herd level and at the Kobuk crossings, and report what happens to those households' harvest.

  From MTJP editorial review

• PendingThe company expects most of its waste rock to be potentially acid generating and plans to collect and treat the seepage rather than separate that rock.

  The company expects most of its waste rock to be potentially acid generating and plans to collect and treat the seepage rather than separate that rock. The notice gives 'approximately 375 million short tons (340 million tonnes)' with the noun missing, and the company's report gives the same 340 million tonnes as its waste rock total. The EIS should confirm what that figure counts, publish and interpret the kinetic leach testing the company has run on waste rock, analyze selenium, zinc and arsenic, which BLM's 2020 Final EIS says can leach at neutral pH, and weigh separating acid-generating rock as an alternative.

  From MTJP editorial review

• PendingThe notice writes the purpose as extracting ore 'using proven and economical mining and milling methods' and the need as maximizing value to Ambler Metals LLC, then says alternatives must meet that pu

  The notice writes the purpose as extracting ore 'using proven and economical mining and milling methods' and the need as maximizing value to Ambler Metals LLC, then says alternatives must meet that purpose. Written that way, dry-stack tailings or a different site can be screened out on cost before harm to waters is compared, though the Corps' rules say the District Engineer uses independent judgment to define purpose and need. The concentrate would ship to smelters outside Alaska with no buyer under contract, and the Department of War's investment in Trilogy, closed September 11, 2026, carries warrants that can't be exercised until the Ambler Road is completed or the company changes control. The EIS should define the purpose broadly enough to compare methods, sites and permit denial, and disclose where the concentrate would be processed and the federal financial interest in the outcome.

  A hole PLAN found in the agency’s own notice, quote verified against the text

• PendingThe notice counts 10.1 acres of ponds and streams as permanent fill without saying what lives in them.

  The notice counts 10.1 acres of ponds and streams as permanent fill without saying what lives in them. BLM's supplemental EIS confirms Dolly Varden spawning in upper Subarctic Creek, where the tailings would go, and the company's report says some fish overwinter there. Downstream, the Kobuk supports what BLM calls the largest population of spawning sheefish in northwestern Alaska, and between 76 and 94 percent of households in the Kobuk River communities use sheefish. The EIS should map spawning and overwintering habitat in the footprint, count the stream miles lost, model how seepage capture and dewatering change the groundwater that keeps those reaches open in winter, and model treated discharge down the Shungnak into the Kobuk.

  From MTJP editorial review

• PendingThe notice names ten villages and the Northwest Arctic Borough as cooperating and participating entities, but schedules in-person scoping meetings in only three of them, Shungnak, Ambler and Kobuk, pl

  The notice names ten villages and the Northwest Arctic Borough as cooperating and participating entities, but schedules in-person scoping meetings in only three of them, Shungnak, Ambler and Kobuk, plus Fairbanks and one virtual session. The Corps should hold or fund meetings or phone sessions in the other seven named communities, take testimony in the languages and ways people there use, and extend scoping so their comments can reach the record.

  A hole PLAN found in the agency’s own notice, quote verified against the text

• PendingThe notice's stated need is to bring critical minerals to market, over the project roads, the Ambler Access Project, the public road system, rail and ship.

  The notice's stated need is to bring critical minerals to market, over the project roads, the Ambler Access Project, the public road system, rail and ship. The Corps' own rule says impacts get the same scope as benefits, and BLM's 2024 record of decision says about 26 miles of the road would cross Gates of the Arctic National Preserve. The notice's cooperating list has neither the National Park Service nor BLM. The EIS should use one route-wide scope for benefits and impacts and invite both agencies, which manage that ground, to cooperate.

  From MTJP editorial review

• PendingThe notice counts 110.6 acres of wetlands and 10.1 acres of ponds and streams as permanent fill but never mentions the Section 404(b)(1) Guidelines.

  The notice counts 110.6 acres of wetlands and 10.1 acres of ponds and streams as permanent fill but never mentions the Section 404(b)(1) Guidelines. Under them, when a project doesn't need to sit in a wetland to work, alternatives that avoid wetlands are presumed to exist unless clearly shown otherwise, and only the least damaging practicable alternative can be permitted. The company's technical report says the tailings site was chosen in 2017 by weighting environmental concerns, permitting, capital costs and operating costs. The EIS should run a full Guidelines alternatives analysis for the tailings facility, the waste rock pile and each road, and publish the 2017 siting workshop and the 2021 tailings alternatives review.

  From MTJP editorial review

• PendingThe notice says water treatment would continue after mining and reclamation end.

  The notice says water treatment would continue after mining and reclamation end. The company's own technical report says the plant will run in perpetuity. A different filing, Trilogy's 2025 Form 10-K, prices treatment at only $1,095 million over a 100-year closure period and says the closure cost estimate is still to come. The technical report also says the discharge criteria are 'to be determined at the later stages of permitting and design.' Alaska law sets financial assurance at the reasonable and probable costs of reclamation. The EIS should price treatment and dam upkeep for as long as they'd actually run, name who holds that obligation if Ambler Metals LLC, a 50/50 joint venture, is dissolved, and say what bond or trust would pay for it, in hand before the Corps decides.

  From MTJP editorial review

• PendingThe notice says the tailings dam at the headwaters of Subarctic Creek would hold 'flood volume 1.5 times the probable 100-year maximum flood event.' Trilogy Metals, half owner of the applicant, told t

  The notice says the tailings dam at the headwaters of Subarctic Creek would hold 'flood volume 1.5 times the probable 100-year maximum flood event.' Trilogy Metals, half owner of the applicant, told the SEC the design is '1.5 times the probable maximum flood,' a far larger and rarer storm than a 100-year flood, and its technical report lists a dam breach assessment among the studies still to be done. The EIS should state which design flood the dam and spillways are built for and why the notice's wording differs, model a breach and overtopping with flow paths and travel times down the Shungnak River, test the design against permafrost thaw, and compare filtered, dry-stack tailings and other sites.

  A hole PLAN found in the agency’s own notice, quote verified against the text

• PendingThe Arctic mine is the first of a district, and the notice describes one pit.

  The Arctic mine is the first of a district, and the notice describes one pit. Its South Route runs to Bornite Camp, Trilogy's annual report says the Bornite Project would use Arctic's infrastructure once Arctic's ore runs out, and BLM's own supplemental EIS calls the connection that supports both mines reasonably foreseeable. Alaska's claim records show 5,122 active state mining claims along the Ambler Road corridor, 3,431 of them staked after the state's development authority applied for the road in November 2015. Clean Water Act rules require the Corps to gather information on cumulative impacts to the aquatic ecosystem, so the EIS should analyze the Ambler Access Project, Bornite and the district's other foreseeable mines together with this one, and say what happens to the mine if the road's permit, which is being challenged in court, doesn't stand.

  From MTJP editorial review