The environmental issues on the Manh Choh-Fort Knox ore haul route begin with the type of ore extracted from the ground at the Manh Choh mine and continue with the type and frequency of ore transportation from that mine to the Fort Knox Mine near Fairbanks.  

The first citation below briefly makes the case for the necessity of looking at all components of the environment of open pit mines, such as Manh Choh and Fort Knox, including “indirect influence of mining enterprises activities”, which reasonably includes transportation of unrefined ore rock from one mine to a refining system at another mine, which is the Manh Choh-Fort Knox proposal.

The second citation below explains how federal standards of environmental protection, as embodied in NEPA (National Environmental Policy Act) have been routinely used for years in Alaska, with the requirements for both EAs (Environmental Assessments) and EISs (Environmental Impact Statements) but have been avoided by the developer(s) of both the Fort Knox and the Manh Choh mines, with the cooperation of both the Alaska State government and the Army Corps of Engineers (USACOE).

The third citation below presents, in the form of two Abstract from longer articles, the case for the evaluation of non-exhaust particle pollution in any decision to allow public thoroughfares to be used as industrial haul roads.  This kind of evaluation is completely absent from any systematic, scientific study of the use of the Tetlin-Fort Knox corridor as an industrial haul road.

The fourth citation focuses again on non-tailpipe emissions with information on the measured increase of these emissions in PM 2.5 and PM 10 pollution near highways.  This document in full is available on request.

Finally, Rick Thoman, Climate Specialist, Alaska Center for Climate Assessment and Policy, International Arctic Research Center on the UAF Troth Yeddha’ Campus, has determined that at least one part of the proposed ore haul route, the Richardson Highway near Birch Lake, can reasonably be expected to have increasing freezing rain events that will be unpredictable both in timing and in amount but could seriously limit the safety to all users of the highway when the ore haul trucks are on the highway. 

This particular safety consideration is completely absent from any systematic, scientific evaluation of the suitability of the proposed route for use as an industrial haul road and is part of the larger argument for a pause of indefinite length—a preliminary injunction—so that this, among many other safety issues, can be carefully studied and considered and alternatives to industrial ore hauling, such as a refining mill on the Manh Choh mine site, on two-lane public thoroughfares can be seriously entertained.  Rick’s slide presentation, “Interior Alaska Climate Change and Mining”, is available on request.

1. Geo-Environmental Problems of Open Pit Mining: Classification and Solutions

* January 2018E3S Web of Conferences 41(2):01034
* LicenseCC BY
Author: Michaela Koščová
Slovak Academy of Sciences


Open mining development is the cheapest method, because it uses powerful production equipment, which allows a large amount of minerals to be excavated during a shift. Working conditions in open development are less dangerous for the health of workers, and a smaller number of supervisory personnel than in underground mining is required. In the process of open development, stripping works are first carried out, i.e. the removal of the empty rocks covering the deposit. Constantly growing requirements for energy sources, metal ores and building materials cause the need for intensive development of the mining industry. There is a rejection of significant areas for the development of minerals in an open and closed way. The causes of degradation are both the mining of minerals, as well as construction, the placement of production and consumption wastes in the natural environment. Changes in the components of the environment are observed as a result of direct or indirect influence of mining enterprises activities. This requires an analysis of the entire complex of geo-environmental problems of open mining and the identification of the most urgent ways to solve them.

2. The National Environmental Policy Act (NEPA) of 1969

The National Environmental Policy Act (NEPA) of 1969 was a response to a growing awareness of environmental degradation in the U.S. in the form of polluted waterways, diminished air quality in cities, acid rain from coal-fired power plants, and more. NEPA provided a mechanism through which a thorough assessment of the environmental consequences of various actions and developments on lands, air, and water quality in the U.S.

In Alaska, EAs and EISs have been developed for numerous development projects such as roads, bridges, harbors, dams, oil wells, pipelines, hard rock mines, and more. Most hard rock metal mines in Alaska have required an EIS, whether they are on Federal, State, or private lands. Red Dog Mine in NW Alaska, for example, was located entirely on NANA Native Corporation land.

The Fort Knox Mine, which is located on State and private land just north of Fairbanks, is an anomaly in that it has not gone through an EIS process.

The proponent bypassed the EIS process by contracting consulting firms to prepare an EA. The EA included most of the components of an EIS, although there were no independent SMEs reviewing the plan. The entire EA was available for public review and included all comments and proponent responses in Appendix B. They requested and received a Section 404 permit from the USACOE and the State provided all other review and permitting they required. The EA was finalized in August 1993.

True North and GIL mines, 12 and 10 miles from Fort Knox, respectively, have not gone through an EIS or an EA process. They appear to be wrapped within the Fort Knox permitting umbrella despite being or planning to be significant open pit hard rock mines. Any State documents associated with them are found within Fort Knox documents on the DNR Large Mines website, although there are few details available to the public of their operations, geochemistry, or theexpected long-term mitigation needs.

Similarly, the Manh Choh mine in Tetlin, 250 miles away, appears to be following this same process. There has been no EIS or EA. The USACOE approved a Section 404 wetlands permit for the mine site area after a public notice that did not include any of the supporting documents required to make an informed comment. They declined to consider the entire operation of the mine, ore haul, processing, and long-term mitigation needs. The State then asked for public comment on waste management and reclamation permits at the mine site and made five supporting documents prepared by consulting firms available to the public on their website.

Again, no consideration of the trucking route, fugitive dust, the processing facility, or long-term mitigation requirements, as were considered for all other large hard rock mines in Alaska.
The public interest components of the NEPA legislation and the EIS process are being lost with this approach to hard rock mine permitting. The public is being sidelined. The public will be impacted by the ore haul, the fugitive dust that will be distributed along the roads, and the long-term care that will be required when the Fort Knox mine, which will drain to the Chena River, is eventually finished. Yet, little information on these issues is being shared. While this may be an efficient process for the mining companies, it is a poor process for the public.

(Excepted from, Randy Brown USFWS (US Fish and Wildlife Service}, email to geologist Jeff Benowitz, November 16, 2023 at 5:42:06 PM AKST; original email available on request)

3. A Review of Road Traffic-Derived Non-Exhaust Particles: Emissions, Physicochemical Characteristics, Health Risks, and Mitigation Measures

Julia C. Fussell*, Meredith Franklin, David C. Green, Mats Gustafsson, Roy M. Harrison, William Hicks, Frank J. Kelly, Franceska Kishta, Mark R. Miller, Ian S. Mudway, Farzan Oroumiyeh, Liza Selley, Meng Wang, and Yifang Zhu
Cite this: Environ. Sci. Technol. 2022, 56, 11, 6813–6835
Publication Date:May 25, 2022
Copyright © 2022 The Authors. Published by American Chemical Society. This publication is licensed under CC-BY 4.0.

Implementation of regulatory standards has reduced exhaust emissions of particulate matter from road traffic substantially in the developed world. However, nonexhaust particle emissions arising from the wear of brakes, tires, and the road surface, together with the resuspension of road dust, are unregulated and exceed exhaust emissions in many jurisdictions. While knowledge of the sources of nonexhaust particles is fairly good, source-specific measurements of airborne concentrations are few, and studies of the toxicology and epidemiology do not give a clear picture of the health risk posed. This paper reviews the current state of knowledge, with a strong focus on health-related research, highlighting areas where further research is an essential prerequisite for developing focused policy responses to nonexhaust particles.

Non-exhaust traffic emissions: Sources, characterization, and mitigation measures
Amelia Piscitello, Carlo Bianco, Alessandro Casasso, Rajandrea Sethi


Non-exhaust emissions (NEE) of particulate matter (PM) from brake, tyre, road pavement and railway wear, as well as resuspension of already deposited road dust, account for up to 90% by mass of total traffic-related PM emitted. This review aims at analysing the current knowledge on road traffic NEE regarding sources, particle generation processes, chemical and physical characterization, and mitigation strategies. The literature on this matter often presents highly variable and hardly comparable results due to the heterogeneity of NEE sources and the absence of standardized sampling and measurement protocols. As evidence, emission factors (EFs) were found to range from 1 mg km−1 veh−1 to 18.5 mg km−1 veh−1 for brake wear, and from 0.3 mg km−1 veh−1 to 7.4 mg km−1 veh−1 for tyre wear. Resuspended dust, which varies in even wider ranges (from 5.4 mg km−1 veh−1 to 330 mg km−1 veh−1 for cars), is considered the prevailing NEE source. The lack of standardized monitoring approaches resulted in the impossibility of setting international regulations to limit NEE. Therefore, up until now the abatement of NEE has only been achieved by mitigation and prevention strategies. However, the effectiveness of these measures still needs to be improved and further investigated. As an example, mitigation strategies, such as street washing or sweeping, proved effective in reducing PM levels, but only in the short term. The replacement of internal combustion engines vehicles with electric ones was instead proposed as a prevention strategy, but there are still concerns regarding the increase of NEE deriving from the extra weight of the batteries. The data reported in this review highlighted the need for future studies to broaden their research area, and to focus not only on the standardization of methods and the introduction of regulations, but also on improving already existing technologies and mitigating strategies.

4. Contributions of Non-tailpipe Emissions to PM2.5and PM10 near Highways

Xiaoliang Wang1, Steve Gronstal1, Brenda Lopez2, Heejung Jung2, L.-W. Antony Chen3, Steven Sai Hang Ho1,4, Judith C. Chow1, John G. Watson1, Chas Frederickson2, David Mendez-Jimenez2, TianyiMa2, Ling Cobb2
Desert Research Institute
University of California-Riverside
University of Nevada, Las Vegas
Hong Kong Premium Services and Research Laboratory
California Air Resources Board
2022 National Ambient Air Monitoring Conference
August 24, 2022

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