Clients who use our “on-call” program management get the benefit of having our experts manage your entire environmental program – usually for much less cost than hiring an “in-house” environmental manager. This may include everything from developing and managing: stormwater plans, water and air permits, water sampling, quarterly and annual reporting and even the training of your site staff.
Redstone’s clients include a diverse array of landowners, developers and commercial and industrial businesses including:
- Mine Owners, Mine Developers and Operators
- Energy Project Developers - Oil & Gas, Utility Companies and Developers
- Federal, Tribal, State and Local Public Agencies
- Infrastructure Developers
At Redstone we have learned significant lessons over the many years we have been in the environmental permitting and planning profession. These critical “lessons learned” have greatly contributed to our service philosophy. These principles are best used in a focused, disciplined and systematic way to help our clients succeed in gaining, or re-establishing operating permits for their mine projects at lesser cost, and greater efficiency than many other environmental consultants. Many mine owners and operators increasingly feel that among others, Clean Water Act (CWA) and National Environmental Policy Act (NEPA) permitting processes are too long and too costly. While this may be the case in many instances; it does not necessarily mean that it must be so in all cases.
At Redstone we have observed that many permit applicants who encounter delays, or costly setbacks in acquiring mine permit approvals have made a few, somewhat predictable, yet significant mistakes:
1. They may have either not provided the types of data and analyses to demonstrate how their proposed operation may affect the environment during and after operation; and/or they have not adequately considered feasible project “alternatives” that may be more “environmentally friendly.”
2. Another common problem is that applicants may not collect data that satisfy the environmental permitting process, but rather satisfy only the goals of the Project. This is in many ways an oversight. The objective of the sampling should be to detect constituents at a level which satisfies anticipated permit levels. For example, metal constituents in surface water samples should be measured using methods with detection limits that are higher than water quality criteria values. This reduces the potential for a permitting authority to find problems or ask for costly, more time consuming second and third rounds of sampling.
3. Other problem examples would be when geochemical or hydrological and hydrogeological studies are conducted only to satisfy objectives associated with mine development and not to help evaluate potential environmental impacts.
4. Yet other problems arise from the following scenarios; water balance estimates do not properly bracket high and low flows, water treatment needs are underestimated, the use of laboratory detection limits that are too high, the use of inappropriate modeling approaches, the failure to consider temporary shutdowns and post-closure scenarios, and overall data quality problems (e.g., non-representative samples).
The challenge lies largely in determining with a reasonable degree of certainty what measures are needed to assure that a technically complex operation, which is often highly exposed to the variable forces of nature, will remain in compliance with applicable laws and regulations throughout active mining as well as during and following closure.
At Redstone we believe that the best way to help our mining clients is to minimize delays and expensive operating closures during the initial NEPA and CWA permit application process, as well as later during the normal operating process, by anticipating and considering the following general guidelines:
Mine project planning should reflect the following principles:
• Evaluate possible environmental data requirements and initiate environmental planning on the front end to avoid costly “re-do” planning later.
• Collect data to meet specific environmental objectives or requirements, and collect them at the required levels of detail and precision – understand the oversight agencies data needs.
• Provide adequate data and analyses for all proposed alternatives. While this may be costly initially; it is must less costly than mobilizing a complete new round of sampling and field work.
• Be flexible when choosing facility designs, locations, and technologies. Develop plans which may allow for the inclusion of oversight agencies in decision-making or advisory capacities. This “front-end” inclusion greatly encourages agency “buy-in” of final designs
• Propose use of treatment, disposal, and reclamation technologies with demonstrated records of success.
• Use appropriately conservative and justifiable assumptions and interpretations.
• Be pro-active in resolving potential environmental problems.
• Establish, and most importantly maintain, open lines of communication with the federal and state regulatory and land management agencies that will oversee the processing of the permit application(s) very early in the process, not after data are collected and planning is near completion. Maintain these lines of communication throughout the review and permitting process, and then throughout the life of the mine as well as through the closure phase.
• Review data collection plans and data quality objectives with the appropriate regulatory agency prior to gathering the data.
Because the CWA permitting and NEPA review processes typically require an applicant to provide a variety of data at different levels of detail and precision, applicants are likely to realize cost savings by evaluating their potential data needs from the outset of a proposed project. This is a KEY recognition; and one that inevitably leads to a huge reduction in cost and frustration later in the project. This approach will also enable a complete and coherent set of data to be collected efficiently and at the required levels of precision, while avoiding data gaps or overlap. In order to specifically evaluate potential impacts to surface and ground water resources, applicants may need to study an area larger than that required for the mining operation; a normally successful approach is to use a watershed perspective.
Applicants are encouraged to evaluate different mine layouts, facility designs, and technologies in an effort to minimize the potential for environmental impact during and following operation. If newly developed or unproven treatment or disposal technologies are proposed to be used, applicants can expect to be asked to provide the results of “bench” or “pilotscale” tests conducted to evaluate the effectiveness of the technology and to institute more detailed monitoring to demonstrate their effectiveness.
Finally, applicants will find that impact analyses often require assumptions of future conditions, waste behavior, and land uses. This is especially true for interpretations, extrapolations, and modeling of geochemical test results and site hydrology evaluations (e.g., water balances). In all cases, applicants should aim to be conservative in their judgment of future conditions and waste behavior and be able to justify their assumptions and interpretations. As with data collection, applicants are strongly encouraged to discuss sampling and data analysis plans, including assumptions and uncertainties, with the appropriate regulators prior to performing the analyses.
Our Mission
Redstone’s mission is to provide simple, direct and cost-effective environmental compliance solutions for your mine, project or initiative, allowing you to maintain your production or development schedules to the greatest extent possible.
Redstone follows these Value Principles to bring you the best service possible:
- Our Primary goal is your success – and finding ways to help you achieve it.
- Providing clear, consistent, and understandable communications with oversight agencies and with you, the client
- Providing comprehensive, scientifically-sound, legally-defensible compliance documents and reports; delivered on time and within budget
Employing our scalable project team approach—eliminating the need for you to hire and manage multiple consultants for simple or complex projects
Redstone’s team of associates provides a wealth of experience to help you achieve your goals. We do this by providing low-cost, high-value, professional consulting services in environmental permitting and planning, environmental impact assessment, biological & ecological surveys, feasibility and constraints analyses, sustainability systems design and engineering, and organizational and business development services and training.
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