As a follow up to my review of the FEIS, November 2015, I have included, as part of this letter, twelve comments and questions concerning the proposed copper mine in Babbitt and associated processing plant in Hoyt Lakes.
How would a land exchange void the responsibility vested in USFS as the steward of public lands presently in their care?
With the proposed land exchange, USFS would be forfeiting its authority to mining interests over lands that were set aside for protection. The Forest Service would be trading, not only lands, but a trust that these ecosystems would be protected from exploitation for generations to come.
Polymet will be mining water resources, destroying wetlands, by their own admission; and, in effect, degrading natural resources, flora and fauna, with its lease to continuously extract metals in an open-pit mine. They will be requiring permits to do all of this, including permits to take endangered species on lands that the Forest Service was given in trust, lands that USFS would need to trade in order for mining to occur.
In addition, this would help establish precedent that could facilitate more land exchanges of this type. By trading these lands, USFS would, essentially, be demonstrating a lack of will in exercising its authority.
This land exchange, essentially, would create a barter system that conflicts with the USFS’ role as steward and allows exploitation. By any reasoning, the land exchange cannot be reconciled with this public trust.
Is it wise to risk the security of the St Louis Watershed, one that feeds the greatest freshwater lake by area in the world, Lake Superior, and lies at the extreme headwaters of the St Lawrence River?
All life depends upon reserves of water; and the Arrowhead is at the source of one of the largest supplies on Earth. St Louis River, at the extreme headwaters of the St Lawrence Seaway, supplies freshwater to Lake Superior and the Great Lakes. Products of the Laurentide Ice Sheet melt, Rainy Lake, Lake of the Woods, and Red Lake formed in the basin of Lake Agassiz, which extended over 170,000 square miles, possibly the largest freshwater lake ever (similar in size to the Black Sea). This glacial lake provided water to northern Minnesota, the Red River Valley and may still be discharging its glacial waters from the fractured metamorphic bedrock aquifers of the Arrowhead. The FEIS confirms that bedrock of the region has low conductivity and could take thousands of years to discharge.
In addition to the glacial waters of Agassiz, others glacial lakes like Norwood, Upham and Aitkin, products of the LIS, as well, have discharged their waters into the Arrowhead of Minnesota. Diverse moraines such as the Vermilion Moraine, left evidence in patterns of glacial till that can be seen around Babbitt, Ely, the Embarrass River area, and Hoyt Lakes, overlain in many areas by lush vegetation and lakes.
Covered by such a luxuriant carpet, the land that Polymet and others want to mine can be as difficult to inspect for existing aquifers, confined or otherwise, as it is to locate existing faults and fractures of bedrock in the area. This does not mean they don’t exist.
The fact that the NorthMet Project prospect lies within the boundary of the Vermilion Moraine, along with the BWCAW and Ely, makes this even more difficult. The potential of water traversing aquifers through fractured metamorphic bedrock, sight unseen, is heightened. No one spot duplicates another, essentially with variations in depth to bedrock by hundreds of feet, coverage of waterlogged vegetation and lakes, and a diversity that is like no other on earth.
Like faults, aquifers can be inferred invariably through their effects. Observe the copious discharge of water from the Big Stoney along the north shore of Minnesota. Observe the waters that so readily flow from the area of the Mesabi Widjiu, in rivers like Prairie River and Swan River from the Hill of Three Waters, the Vermilion River, St Louis River, Rainy River, and the great Mississippi. All one needs to do is observe.
As faults and fractures allow water to disperse in bedrock, these aquifers eventually find outlet in rivers, streams, fens, wetlands, falls, ponds and lakes at varying distances and directions from the site of recharge in the Laurentian Uplands.
According to the FEIS, surficial aquifers surrounding the mine site have a low conductivity, though not as low as bedrock in the same area, which supposedly decreases with depth. In this environment, then, it took thousands of years for glacial waters to make their way to the basin of Lake Superior. These waters can be seen dispersing in rich wetlands and rivers throughout; and they continue to nourish land in the Arrowhead supporting a vast and intricate ecosystem.
Does it make ecological sense to place a copper mine where it can do so much harm to water resources, with the potential of collecting into highly toxic sludge, polluting more and more of the surficial aquifers of the region, as waters are made stagnant and dead over the years?
There will be floods. There will be upheavals, as history proves … waters will disperse, as it is the nature of water to do. What will be left after the mine extracts precious reserves of water from aquifers, seen and unseen, confined or not, to process metals that serve its profit margin? Will there be any wild areas left, named or unnamed, categorized or not when the pollution from concentrates, waste rock and filters have found their way through this valuable ecosystem and the watersheds of the Arrowhead?
Our national security depends upon protection of freshwater resources, and the Arrowhead stands as a source of one of the largest fresh water reserves on earth. No copper mine is worth the risk of degrading this precious resource.
How can protection of a species be reconciled with destruction of habitat and nesting sites?
Since the various animal species do not pay attention to lines drawn on a map, they will trespass naturally. Water knows no real boundaries, either, over time; and time is the key word. In time, all things great and small in this water dependent ecosystem will be affected by actions proposed today in the Arrowhead.
The FEIS notes, that approximately 1,535 acres (58 percent) of mature forest would be lost at the mine site alone, that the species of greatest conservation need (SGCN) found at the mine site would be birds from Table 4.2.5-1 and that they would be “displaced.” The FEIS goes on to state that it is likely these birds would not be injured or killed, though nesting birds could be affected. The FEIS states that the mine would not likely affect individual migratory songbirds or other bird species protected under the MBTA; but would likely affect habitat and nest sites used by them.
How does one “affect” another’s home, without affecting the individual; and, as a matter of course, disturb nesting sites without disturbing the propagation of a species? With time, more species than those cited by the FEIS would be “affected” in the course of their reproductive cycles; and this, in turn, would naturally affect survival of a number of species in the area.
What security is there in a mining economy that depends entirely on the market, one that will not contribute to the real long-term wealth of this area?
Such an economy based on mining depends on the whims of a market. Copper mining will pollute the resources essential to our survival, perhaps into perpetuity, while providing profits and wealth to relatively few people over twenty years, more or less. After the mines have gone, as we see today, there will be masses of unemployed people, desperate, in a failing economy.
Recycling metals is on the upswing and processes for this type of recovery are being more fully developed as the North Met Project is being pondered. This could make mining for copper less profitable in a very short time. The price of commodities will vary, and markets are fickle. As a consequence, copper cannot guarantee a secure future, and certainly not a green economy in the Arrowhead.
Statistics abound concerning the wealth of wilderness tourism; and it cannot be reconciled with a mining scenario. When the copper mines are gone, what will be left? The choice is truly between wilderness and mining. Transport down scenic highways to and from the NorthMet Project will weave a web far beyond the sites that FEIS reviewed. Tourists will be traveling down the Superior National Forest Scenic Byway, along highways and roads to Hoyt Lakes, Embarrass, Ely, Babbitt and Silver Bay.
These potential long-term customers will see the effects of mining and it will affect the tourist industry. The sounds of blasting, trucks and drilling are not conducive to wilderness by any stretch; and neither is the potential of streams and waterways polluted with sulfuric acid and other toxins from mining copper.
Atmospheric conditions are unpredictable and Polymet will not be able to control these. The sounds of drilling from exploratory wells for copper and other metals can be heard in the BWCAW at this time. If Polymet gets permission to pollute and take lands in the Laurentian Uplands, there will be little peace for these areas, no chance of true wilderness experience and tourism.
Jobs that create a steady future do not lie in mining a land that, once mined, is degraded. Fields that once grew wild rice, grow no more. Waters that held rich stores of fish are dead and dying. Ecosystems fail and waters need constant treatment. Wetlands that once held diverse flora and fauna are no more.
This is not security.
The FEIS did not adequately address the potential effects of fossil fuels on the atmosphere surrounding the NorthMet Project.
Fossil fuel needs will escalate at LTV and the mining site, fuel and coal needs for the plant and mine, fuel for the vehicles, the crushers, the earthmovers and trains. Acid rain will emerge as an even greater problem, and the FEIS did not address this issue sufficiently. Repercussions will be felt in the Boundary Waters Canoe Area Wilderness, most certainly, from atmospheric effects alone.
Coal fired plants have provided energy to mines along the Mesabi Range for decades and, in the last 50 years, signs of acid rain have degraded foliage and forests in the path of their plumes. Witness dying birch, and mountain ash (that have all but entirely disappeared along the North Shore of Minnesota).
The effects of a copper mine in this fragile ecosystem will reach far beyond the boundaries of the plant and mine sites with potentially devastating effects.
This FEIS does not address known fractures, fault lines within the project site, and those along the Range. What of the Waasa and Camp Rivera Faults? What of the Vermilion Fault?
The effects of faults and fractures have been downplayed in models, which were made to inform the FEIS. The connectivity of bedrock with surficial aquifers assumed to be low, and the upper surface of fractured metamorphic bedrock assumed to be fractured more heavily at the top than down under. This conclusion seems convenient and arbitrary, since these structures cannot be truly known, sight unseen. Is there some reason that Polymet did not use the available information on inferred faults for more in depth field study on these particular areas?
The devil is always in the details. Though details can be used to obfuscate and avoid larger issues, these particular details are major omissions in a study that assumes to represent a truthful picture of the potential risks involved to groundwater from seepages and discharge through cracks, joints, fractures, faults, bore holes, from waste rock, slurry and tailings basins in the Laurentian Uplands.
Inferences are made all the time in science, through reason and implication, through the use of data and study. All knowledge is brought about in this way. To discount information on inferred faults is careless. The FEIS makes its own inferences. It infers that bedrock has low conductivity around the site and plant. It infers that the pollution would not travel far from the sites. It infers that all systems will operate sufficiently as expected over the lifetime of the mine and into perpetuity. It infers that, if a fault is found, it will be dealt with successfully. It infers much in supporting a copper mining scenario. Details and independent, in depth fieldwork is still needed concerning bedrock aquifers, faults and fractures in the area because of their potential for being conduits of pollution into ground water reserves, sight unseen.
Polymet admits seepage will occur, but it continues to minimize the risks through assumptions concerning the conductivity of fractured metamorphic bedrock and sand and gravel aquifers throughout the area. Water will most assuredly traverse aquifers and find the path of least resistance. The FEIS minimizes and leaves these pathways open to conjecture with promises that all will be handled, in time.
Potential effects that can be caused by drawdown in artesian springs, are given little review and field study, limited by assumptions and documents supporting the FEIS conclusion that bedrock geology plays a small part in hydrology of the area.
At the same time, we are assured that if there are, indeed, fractures, faults and confined aquifers found during operation, or that drawdown becomes a problem, these issues will be dealt with at the time. Of course, once an artesian has been drawn down, the chances of drawing it back up are limited. At this point, there does not appear to be any technology that can guarantee the renewal of an aquifer, or restoration of ground waters fouled?
Considering the importance of geology in this complex area of Minnesota, the FEIS omits much in detail.
Ground water in the Laurentian Divide frequently diverges from surface topography and therefore locations of recharge and discharge can be impossible to predict. Polymet’s probabilistic models cannot possibly be informed adequately to address the enormous danger of mining water, drawdowns, depressurization of artesians, and upwelling of brackish water to name only a few dangers posed by this project.
In the process of review, some of the most relevant information appears to be missing from the FEIS, or discounted, much of the obvious geological and hydrological evidence that would prove a no action alternative best for the environment and for the habitants upstream and downstream of the proposed mining project.
For instance, significant evidence on the fractured metamorphic nature of these lands, inferred and actual fractures and faults that have been named, the prospect of artesian springs, other faults and fractures in bedrock that may conduct water from the site, the potential that water inflows are much greater by many accounts have been given short shrift in deference to a computer model fed with data chosen, in particular, for this study. It all seems quite arbitrary, and these omissions are significant.
The area that includes Babbitt, Hoyt Lakes and the transportation corridor are covered with sand and gravel surficial aquifers, which run the possibility of overdevelopment in irrigated areas. This region also includes igneous and fractured metamorphic bedrock aquifers, where water can be found in cracks, joints and fractures within otherwise solid rock formations. Hoyt Lakes is a land of sand and gravel buried aquifers, which can be a major source of water (eg the Biwabik formation). Further down the St Louis River, in addition to sand and gravel surficial, and buried aquifers, igneous and fractured metamorphic bedrock aquifers, there are also sedimentary bedrock aquifers. Even though yields from these sedimentary cretaceous deposits are supposed to be low, the possibility that ground water discharges in lowlands from sand and gravel and fractured aquifers, also in the area, certainly exists.
Igneous and fractured metamorphic bedrock aquifers line the North Shore of Minnesota where there are over sixty water features in falls, rivers, and streams. The St Louis Watershed drains a basin of over 3500 square miles at the extreme headwaters of the St Lawrence Seaway. It appears that waters from glacial lakes, formed during the melt of the Laurentide Ice Sheet might still be discharging into Lake Superior as these waters work their way through the fractured bedrock aquifers of St Louis, Lake and Cook Counties. As noted, FEIS confirms that due to low permeability of the bedrock, discharge could take thousands of years… and so it seems that polluted waters could do the same. Polymet would be long gone before the consequences of copper mining could be fully assessed.
The FEIS avoids much discussion on differentiating major geologic areas, although Ely, Babbitt, Hoyt Lakes, Embarrass, the BWCAW and the whole of Giants Ridge are encompassed in a single one of these regions. The FEIS avoids in depth review of the existence of confined aquifers (extremely important in the security of the groundwater), avoids discussing in particular dissimilarities in surface composites and bedrock as relates to their conductivity and connectivity, specifics on the variability of depth to bedrock, inevitable flooding scenarios, weather anomalies, likely spills and exposures, drumlin fields, watershed anomalies (for instance, the fact that the tailings pond at the Minntac plant has outgrown what was once the boundary of the Vermilion Watershed, redrawn on maps to put it within the St Louis Watershed). Polymet’s NorthMet Project will increase the size of this tailings pond and so it is crucial to understand fully the hydrology of both surficial and bedrock aquifers directly underlying this tailings pond in particular.
Metamorphic rock is mentioned very little in the FEIS, as it fails to note that most of the Arrowhead is covered by fractured metamorphic rock, and in the area of the project, that sand and gravel surficial aquifers are prevalent as well, major omissions in outlining the geology of the area. Through these errors of omission, the probability of surficial and bedrock transport appears minimal at best. Is it possible to make a valid review of the project’s feasibility without details like this?
Of course, a model cannot take into consideration all of the factors in this extremely complex area of the North Met Project prospect, and so, I wonder, why experiential data from over 100 years of mining was not favored over probabilistic prognostications and limited field study prepared specifically for the NorthMet Project?
The Mississippi is now polluted; the St Louis River, and waters off the North Shore are imperiled. One hundred years is so little time in the course of a history like the Arrowhead, but much damage has already been done. What would be the result after 500 years of seepage from the degraded rotted and rusted infrastructure of a copper sulfide mine?
Studies that fail to use extensive fieldwork and data available from mining experience of the Mesabi Widjiu over the past one hundred years since the late 1890’s are likely to misrepresent the risks involved with a copper mine in the Arrowhead.
Just as the tailings pond at the Minntac plant site outgrew the boundary of the St Louis Watershed into the Vermilion Watershed, will the pits and ponds at the North Met mine site, so close to the northern boundary of the St Louis Watershed, outgrow its boundary as well, reaching into the watershed of Rainy River?
Indigenous peoples have lived in this area for thousands of years. They know the lands and waters of the area. They have honored this priceless parcel that is the Arrowhead of Minnesota and the Mesabi Widjiu. Perhaps unwisely, maybe without a choice, the tribes ceded this territory by treaty in the mid 1800’s. How shamelessly we have treated this land since that time. The quality of water has degraded, wetlands have suffered, the forests have been lumbered, and lands developed and damaged through mining activity and pollution.
If water seepage and inflow has not been predicted realistically for this study, then, the potential for harming watersheds of the St Louis River, Vermilion River and the Rainy River is great. Tribes inform the co-lead agencies that inflows are considerably higher than suggested by the EIS. How has related data from this observation informed the FEIS?
Due to the precedent that a copper mine in Babbitt will set, if granted, the potential for mining pits and tailings basins surrounding the area of the BWCAW watershed will be greatly increased.
Exploratory wells have been made well past the northern boundaries of the St Louis River Watershed, into the Rainy River Watershed, and on the boundary of the BWCAW. As a consequence, if the North Met project for a copper mine is granted, this will create the potential of a succession of mining pits and wells that move from the NE of Giants Ridge into the domain of the BWCA Wilderness. Consequently, the NorthMet Project prospect has the potential of affecting a larger area than the study proposes.
Elevated levels of arsenic can be found in the BWCAW along with brackish waters from exploratory wells. These details cannot be overlooked because it foretells the real possibility of pollution from Polymet’s mine pits traversing aquifers and connecting the St Louis Watershed to the Rainy River Watershed. The potential of surficial and bedrock connectivity from the mine site to this highly diverse geology of the BWCAW region through fluid and interconnected wilderness waterways, glacial moraine and diverse geology is relevant to the discussion.
Relying on probabilistic outcomes that narrow the view and minimize the prospect of pollution reaching downstream seems unrealistic. The potential of downstream contamination throughout the St Louis River Watershed should be given full consideration in any responsible environmental study concerning the prospect of a copper mine in this ecologically important area at the headwaters of the greatest body of freshwater on earth.
The St Louis River Watershed is composed of tilted bedrock planes that lean toward Lake Superior. Some of this can be seen in Jay Cook State Park, downstream from the prospect. The topography of the Laurentian Uplands and the swampy lowlands is diverse, including beds of wavy bedrock and washboard effects in areas like the Toimi Drumlin Field. The diversity of topography is as great as the diversity of flora and fauna. These areas are hardly flat.
Consider that the final drainage of the Laurentide Ice Sheet is said to have occurred around 8200 YBP and this caused sea levels to rise between 2.6 to 9.2 feet. Can the inevitable flow of local waters to the sea be discounted in a study that truly represents the risk of pollution from a copper mine?
Lake Superior is the product of glacial waters that flowed from the LIS and from glacial lakes that grew from the LIS melt. The St Louis River developed in the basin of Glacial Lake Upham. Relative to the age of this earth, the rivers in Minnesota are young, still cutting paths to the sea.
If downstream effects were given due merit, the facts would be clear that the entire Arrowhead of Minnesota would eventually suffer loss and damage from the operation of a copper mine in the Laurentian Uplands. No reassurance will carry the weight of facts before our eyes, the water we drink, and the air we breathe.
Please do not permit this land exchange to occur.
December 19, 2015 REVISION