Comments submitted to the DNR on September 7, 2017
RE: “NorthMet Water Appropriation”
The guarantees are clear. The proposed North Met Project will mine tens of millions to over a billion gallons of water every year sent downstream, 10 percent of this untreated, to the Lake Superior Basin. This permit will allow the mine to pump billions of gallons of water from its site into streams in the St Louis watershed at the extreme headwaters of the St Lawrence Seaway in the Lake Superior Basin.
Even after closure, for an undetermined amount of time, the amount of water released from the mine naturally and otherwise will be in the millions of gallons annually, treated and untreated. Filters from “treated” water will be concentrated into a toxic sludge left behind in tailings ponds; and the water from this proposed copper-sulfide mine will need ongoing treatment perhaps forever. Effects from this toxic pollution will span centuries if not thousands of years.
Average annual water required for mine operations has been estimated at 275 gpm, or between 20-810 gpm (SDEIS report), which translates from 10,512,000 gallons of water per year to as much as 425,736,000 annually. This has been revised into the billions since then, for this permit. Greater than 90% of this water would be captured and treated using reverse osmosis, a process that poses its own risks, including demineralization (2006 by the World Health Organization’s report in Geneva, Nutrients in Drinking Water, Chapter 12), leaving anywhere from 1,0512,000 gallons to over 42.5 million gallons of untreated water that will be sent downstream from the plant (each year). This water appropriation permit will allow even more.
The Uplands in the Arrowhead of Northern Minnesota include varied and complex aquifers connected along pathways underground that have not been charted and cannot be known. This fact, coupled with the extreme weather variables of our times, should give anyone pause. For instance, there can be no guarantee that the earthen tailings ponds holding toxic waste sludge from Polymet’s proposed copper mine could withstand a 1000-year flood of the sort that inundated Houston Texas this year, in August 2017.
What cleanup would be possible of toxic buildup in streambeds and the inevitable contamination of flora, fauna and fungus over hundreds of years resulting from copper mining in this water-dependent, varied and complex ecosystem of the Arrowhead? The St Louis watershed is uniquely positioned and vulnerable to the toxic effects of a copper sulfide mine.
Water, one of the greatest solvents, can be guaranteed to seek its level through paths of least resistance, many unknown. The water in the St Louis watershed of the Laurentian Divide has been seeking its level over tens of thousands of years to the Hudson Bay Basin, the Mississippi River Basin and the Lake Superior Basin of the Great Lakes, through glacial waters of Lake Agassiz, other glacial lakes and the Laurentide Ice Shield. Just as naturally, the waste rock and toxic waste ponds from this proposed open pit mine will leach into the ground water; and through rains, ground water seepage, and faults in the bedrock find its way downstream, a guaranteed outcome that cannot be controlled or predicted accurately.
Polymet, admittedly, needs a water permit in order to pollute and mine these vital waters; but loss and degradation of these waters will only be the beginning. Since the proposed mine site is an important and complex recharge area, artesian wells could be depressurized and other ground water resources diverted or diminished unexpectedly. Tourism will suffer from the related activities of a large mining operation near the BWCA in Babbitt and Hoyt Lakes where blasting, processing, transportation of products and supplies, road construction and repair will be ongoing while the mine operates. Wetlands like the 100-Mile Swamp between Babbitt and Hoyt Lakes will ultimately be lost.
A copper mine, then, will change the surrounding landscape, since mining activities know no boundaries. The dimensions of this mine could change as deposits are discovered and, through precedent, threaten one of the most pristine water-dependent ecosystems, one of the wildest and most beautiful places in the world, the BWCA. There will be no end, once begun, and this will change the meaning of “north woods” as we know it. The Rainy River Watershed and throughout the big stony of the Arrowhead, where copper leases abound, the whole of St Louis, Cook and Lake counties could essentially be affected.
On a balance sheet, what is the price of real wealth, clean water, air, naturally fertile soil, insects, birds, mammals and all manner of life that support the health of this planet? What price freshwater? Are there truly any acceptable limits to the pollution and draining of the St Louis watershed?
Who, essentially, will profit in the long term by putting these freshwater resources at risk in order to permit this private for-profit enterprise, the NorthMet Project? It will certainly not be the air quality and the peace, environmental health, the integrity of this wilderness. What will be left if we allow any and all lands, no matter the cost, to be developed for the profit of a finite term at the degradation of the infinite?
I close here with my formal objection to this water appropriation permit. I make this objection on the grounds that this permit will allow mining operations in a water-dependent ecosystem that knows no equal, a wilderness that will be changed forever by copper mining. Mining and pollution of millions of gallons of water each year is not in the best interest of those who live in NE MN, those who live downstream, or those who depend on potable water, the wilderness, for its beauty, its wildlife, flora and fauna, its sustenance. We will all be less for having lost this gem by defaulting on our responsibility to raise the standards of protection for our freshwater.
Anita Suzanne Tillemans