Do we appreciate the beauty of the Arrowhead in this one-of-a-kind wilderness, enough to say no to copper sulfide mining? Will the DNR choose short term profit over the long term welfare and profit of this valuable and beautiful ecosystem?
Many comments that were made concerning the SDEIS for the Northmet Project in 2014 are as telling today as they were then. Though some dates, names and numbers have changed, the substance of these objections to mining and the safety of the aquifers in this water dependent environment remain true.
I include my own comments on the SDEIS in 2014 below:
(North Met SDEIS.firstname.lastname@example.org)
March 7, 2014
RE: Comments on the SDEIS for the North Met Project
The proposed copper mine in Babbitt should be a concern to all of us since it will threaten water resources in an extremely important hydrological area of the North American continent and at the source of the largest fresh water body in the world, our Great Lakes.
Copper mining leaks sulfuric acid into waters above and below ground and is one of the worst polluting mining processes in the world historically. Metal mining requires prodigious amounts of water and copper mining has historically degraded those resources. The facts prove this true and reverse osmosis, which Polymet contends will successfully filter contaminants, has significant dangers as well.
Average annual water required for mine operations has been estimated at 275 gpm, or between 20-810 gpm for this report. If we were to accept these numbers, then uses could vary from as little as 10,512,000 gallons of water per year or as much as 425,736,000 gallons per year. Greater than 90% of this water would be captured and treated using reverse osmosis, a process that poses risks as outlined in 2006 by the World Health Organization’s report in Geneva, Nutrients in Drinking Water, Chapter 12.
According to studies done since the 1960’s when reverse osmosis filtration began, demineralized water has proved dangerous in many ways. It will aggressively attack contacted materials by dissolving metals and some organic substances in pipes, storage tanks, hose lines and fittings. Because of this, it poses an increased risk of filtering toxic metals into the groundwater, wetlands and streams at the source and particularly down stream. Time would be an important factor in determining the extent of damage to various plants and animals in the watersheds.
Without the protective or antitoxic protection of calcium and magnesium additional, increased risk of cardiovascular disease occurs in humans from drinking water treated by RO, and reserve minerals in the body are often depleted. This in time results in other adverse effects on animal and human organisms.
Filters and membranes are subject to bacterial growths and would present their own problems. Significant factors are toxins from the filters or membranes would be highly concentrated, and the problem of disposal would remain. Has the SDEIS calculated the very real danger of RO processed waters on plant and animal organisms as well as the disposal of these concentrated toxins?
Estimates of contamination in the SDEIS are based on models that do not take into account inevitable accidents and failures. Without these risks factored into the equation, this SDEIS cannot predict consequences with any success. The model can only be as good as its basis in fact, field study and experience.
Mining wastes would be altered by geologic process but would not degrade; and so the hazards of controlling contamination would continue into perpetuity. Discharges of mining wastewater would continue as long as it rains, with water seeping into pits and ponds and leaching of toxic mining byproducts into groundwater. Potential failure of tailings dams, concentrate spill into streams and wetlands are historically valid concerns and need to be addressed since these will add to the pollution.
Clean up of polluted river beds and aquifers would not be possible. The damage done, no financial assurance would replace the irreplaceable. In addition, the cost of perpetual treatment of waters that would continue to spill and leach toxins into the environment forever, including the dangers of the RO process, would outweigh the profit of a relatively few, finite years. The damage would be permanent and the jobs would be gone.
Fond du Lac Indian Reservation is downstream from the proposed mine. Indigenous cultures have lived and sustained themselves in the St Louis River watershed for over a 1000 years. Wild rice beds can be found all along the St Louis watershed, rice beds the Ojibwa depend upon in this highly connected and diverse aquatic habitat. Laws that were made to protect the environment within the ceded territory have eroded away. Promises made ignored. With the proposed land exchange, this will be affirmed by further eroding these treaty obligations and allowing Polymet to operate outside of protections promised in the treaty. Effects will be felt outside the boundaries of Polymet’s land and no compensation credits would bring these wetlands, the wildlife or the wild rice back.
The affected wetlands are highly connected diverse and water dependent lands in unconsolidated sand and gravel aquifers of ecological significance and sensitivity. Much of these surficial aquifers are shallow, with bedrock features lying only 3.5 to 17 feet below the surface. In spite of this, the SDEIS has no bedrock groundwater samples available from the plant site and the tailings basin, and no testing was done in the Biwabik Iron Formation for these sites. For what reason?
The report assumes that most all water in these wetlands is recharged by rainfall and that the underlying bedrock is of low conductivity. I could not find substantial proof of this in the report. There are no long term records and field reports of rainfall over many seasons and years. Even so, the assumption seems to be made that there are no fractures, no artesian aquifers of significance in the area, ignoring reports of the fractured nature of igneous and metamorphic rock prevalent throughout NE Minnesota. More study needs to be done to get a clearer picture of the interaction between bedrock and surface aquifers of the region.
The surficial aquifers have developed highly diverse ecosystems over thousands and millions of years, with organic matter that acts like a sponge for waters arriving from above, below or laterally. Excesses disperse through the high connectivity of these wetlands such as 100 Mile Swamp to others in the St Louis watershed. Therefore, polluted water will affect not only flora and fauna that depend on these wetlands, it will, eventually, affect Lake Superior and the Great Lakes.
Since contained aquifers often recharge in outcroppings along the uplands, and since mining will be done in the Laurentian uplands, contained aquifers of igneous, metamorphic rock and sand and gravel should be of great significance in determining the impact of copper mining on underground water. All of these aquifers are present in the area. The distributions and flowages along nonconforming wavy bedrock formations in the area should be prominent factors in the decision-making process and at the forefront of the SDEIS. The Laurentian Divide runs through the middle of the tailings pond at 1700-1800 feet and very little is documented to date about the complex underground flows from this area. In fact, there is more study necessary before we understand specific recharge and discharge areas in this divergent geological and hydrological area of the Mesabi.
Once copper mining is begun, contamination of groundwater cannot be prevented in the Laurentian Divide. Water will be contaminated as aquifers are traversed, through cracks, joints, fractures, and bore holes in bedrock aquifers and in direct contact with waste rock as it is mined. It can also flow along bedrock under glacial drift to locations unknown from the site of contamination, seeping into and out of these mining pits and tailings bins without being captured. What technology would be in place to prevent this?
Polymet admits that seepage will occur. Once the mine is closed, seepage and discharge from mining pits of waste rock, slurry and tailings basins will continue into perpetuity. No reliable, extensive studies have truly been done, nor can they be, to determine how much water will actually seep into and from the mining pits and tailing basins at these sites over hundreds of years. In spite of this, the SDEIS has provided a figure of 31 gpm at closing for untreated seepage; and tells us that this would be less than 5% of the total wastewater discharged. Using these figures, this estimate calculates to an annual wastewater discharge of 1,208,880,000 gallons, 16,293,600 gallons, of which, would be untreated each year. These discharges will continue for an undetermined amount of time.
In NE MN, groundwater flows frequently diverge from surface topography. No substantive studies have been done to determine the recharge and discharge areas for all aquifers along the Laurentian Uplands, including the Embarrass and Partridge River watershed aquifers. How much of the pollution will discharge into unexpected waterways from contamination in the recharge areas? Extensive and conclusive reports need to be produced on these flowages, especially of the Pre Cambrian metamorphic bedrock layers. Do we know what vital waters are supplied by particular aquifers in the Laurentian Divide at the proposed sites? With inevitable variables over hundreds of years, and without additional, extensive, field work and research concerning these aquifers, what reliable calculations can be made to predict drawdowns, potential depressurization of artesians and upwelling of brackish waters among other possible dangers? There are few wells on site and very little detail concerning underground water flowage at the sites proposed for Polymet’s operations.
A great concern is that water will be drawn continuously from surficial and possibly bedrock aquifers, as well as St Louis watershed streams and Lake Colby in order to mine copper for 20 years. Once begun, it will be necessary to perpetually discharge water in order to mine the rock; and, so, what guarantees can there be that groundwater will not be mined as well, as levels of ponds, pits, and rivers are managed to maintain certain levels? It is impossible to predict the effect that global warming will have on water reserves, nor is it possible to predict weather from year to year. “Existing conditions” are variable.
Wetlands destroyed will not be replaced in kind. This has been admitted. Included in the area of concern will be 100-Mile Swamp. The name alone gives us a clue as to the nature of the area proposed for copper mining and discharge. These wetlands are open and continuous, one feeding into another along the entire watershed of the St Louis River. What will the accumulation of polluted water from the mine over decades, hundreds of years do to the St Louis River estuary? The St Louis River is already an AOC. What will happen to the entire wetland area of St Louis County? What of algae bloom, reduction of oxygen and creation of a dead zone at the mouth of the St Louis River and Lake Superior? Polymet would be using the river for a chute to dispose of copper mining wastewater essentially into the largest body of freshwater in the world, the Great Lakes. This should be of concern to every person on the planet.
Once granted permits to mine, Polymet will, of course, set a precedent. Copper mining will then most certainly extend into the Rainy River watershed, since there are others waiting to mine and have already been granted exploratory permits on the border of the BWCAW. Would NFS have granted these drilling permits if it had not considered allowing copper mining so close to the Boundary Waters Canoe Area Wilderness? Once noise, air, water pollution have been granted at these levels, even higher levels will then be more acceptable. It is easy to see then how lovers of wilderness, the BWCAW, the Quetico … might be threatened by a copper mine in Babbitt.
Lake Superior is known as the “mother of waters” and the Mississippi, the “father of waters”. I wonder, the true mother of both. Do we know the actual source of the Mississippi? Could it be that aquifers of Giant’s Ridge are the true source of the Mississippi, St Louis River and the Rainy River? Could it be that we do not know enough about the aquifers that underlie the Laurentian Divide? Minnesota is a land of more than 10,000 lakes, a land of waters, water that has no boundaries essentially. When one area is polluted, the effects are felt like a ripple.
Concerned members of the Ojibwa Nation have indicated that groundwater seepage is greatly underestimated. This is from experience of hundreds of years, perhaps thousands of years. Without studies of rainwater, and seepage over many seasons and years, how can the SDEIS predict outcomes confidently? Where little allowance has been made for fractured and folded metamorphic rock in the area, fault lines, and percolation from confined aquifers that are also in the area, it would seem that the report is flawed. This error could cause other faults in predicting leaching, groundwater effects, toxin releases and solute levels in wetlands, lakes and streams.
Technology is only as good as it is applicable. What technology could predict fllowages of unseen aquifers or prevent water from eventually dispersing underground and returning to unknown points of discharge? Copper mining will pollute one of the most precious resources we have, our fresh water, in an area of complex aquifers that depend heavily upon each, interconnected in ways that we have yet to understand. Without consideration for loss of wilderness, which would be great enough, pollution and drawdown of our water table on the scale that Polymet could bring would be disastrous for a much wider area than this report has addressed. What financial assurances would restore these priceless reserves of water?
As water and air know no boundaries, moving millions of tons of ore, discharging millions of gallons of slurry and wastewater will have effects beyond pipeline, tracks, and roads within the specified corridor and mining sites. Transportation, alone, will extend from Babbitt and Hoyt Lakes areas to the shores of Lake Superior. How many more trains will be traveling through and over the wilderness of Superior National Forest and the Arrowhead? How many more trucks? How many earth movers, ATVs, OTVs, roads, how much dust, cumulative noise pollution from 24/7 mining operations (explosions, drilling, digging, crushing, processing, hauling etal)? In twenty years, how much of the remaining wilderness will survive?
Wilderness by definition is not managed. The introduction of roads into these wetlands will most certainly change patterns of drainage and endanger plants and wildlife. These losses are impossible to calculate. The whole nature of the St Louis River watershed and estuary will be altered and no mitigation efforts would spare it or bring it back. The scope of the SDEIS does not address the actual extent of operations related to this project and effects that will most definitely exceed the actual boundaries of the two sites and the transportation corridor. How can any of these facts be ignored?
In spite of promises, one truth remains. Consequences will go beyond the limits of liability for Polymet, and their operations will endanger lands and waters that neither Polymet nor the National Forest Service owns. It is also clear that the words “directly” and “indirectly” have no meaning in a place that stands over aquifers of the complexity, quantity and caliber of those in the Arrowhead region of Minnesota. Although “direct” impacts are considered to be within the boundaries of mining operations, permanent, irreconcilable impacts will have no boundaries. Pollution will reach underground into the water table, above ground into our air, and down stream most certainly into our oceans through vital freshwater resources. Water and air will find paths and pay no attention to lines drawn on a map.
The SDEIS considers addressing pipeline failures and spills speculative and beyond the scope of the study. What then is a study based on assumptions and predictions hundreds of years into the future? There is already an abundance of information on copper mining around the world; and these facts alone would be enough to forbid this project in a critically important hydrological region like the Arrowhead of Minnesota. Water should take priority over all else for good reason.
As political realities change, it is conjecture to state with assurance what regulations if any will provide protection to the public from inevitable consequences of copper mining in this highly ecologically sensitive environment. We do know some things though. For instance, we do know that once the land exchange is made, that much of the treaty obligations under the ceded territory and wildlife and wilderness protections will no longer have any teeth. As any corporation, Polymet will follow their bottom line. If they can pay a fine and get a variance, they will. Observe taconite mining of the Iron Range. Will our environmental laws be eroded even further with copper mining?
SDEIS promises that safeguards and standards will be established in the permitting process, but these are not given in this report and cannot be assessed for the public view. There are too many unknowns, it would seem, for a solid foundation on which to build a positive outcome.
The SDEIS calculates that 533 million tons of waste rock and ore will be removed in 20 years and that 113,000 tons of copper, 18,000 tons of nickel/copper, and 500 tons of PGE annually or a total of 2,630,000 tons of marketable product will result. If these figures are correct, then, that would mean 2,260,000 of this product would be copper. Using these figures, it appears that 198,700,000 tons of spent ore would remain along with 308,000,000 of waste rock. Is it correct that less than .004 of the mined material will be copper at the cost of so much pollution? A trade like this does not seem to be in our best interest.
If concentrate spilled into a stream, it would settle forming sediment, highly toxic unless dredged which would have disastrous effects. This sediment would persist for decades and eventually end up in Lake Superior. Wetlands are susceptible to spills releasing slurry, return water, diesel fuel, solutes, leaching into water tables. Reduction in wetlands due to degradation of habitat and wetlands ability to support fish and invertebrates would result in an incalculable loss of wildlife population abundance.
There are multiple uncertainties in planning, designing the construction and operation, as well as, the closing of a mine. Models that forecast behavior of a system engineered with inherent human error, undetermined factors, predicting the outcome of centuries of management and untested at length are Idealized and cannot be considered accurate representations of what may occur when the plan becomes reality.
It is “reasonably foreseeable” that weather will change and is unpredictable, even in the short term. No scenario that forecasts over hundreds of years can be taken seriously. It is obvious from a logical standpoint and the facts that present themselves from mining of 123 years in the Mesabi Iron Range, that the water and environment will be permanently changed and that no mitigation will return our waters and wilderness to pre-mining condition.
As Minnesotans we stand as stewards at the source one of the world’s greatest resources for freshwater. Will we learn from past mistakes and reject this copper mining proposal? There is no financial assurance that could provide good reason for what is simply a bad idea, one that will have devastating consequences into perpetuity. What precious metal or mineral can trump the importance of protecting these waters and maintaining the balance developed over millions of years, laid on a foundation created billions of years ago? Mining operations will cease along with the jobs and profit, long before the degradation has run full circle. What will Minnesota and the world have in return for a few years of jobs and cash if we fail to act as responsible stewards? There are no financial assurances that would cover the cost of such a tragedy.
Simply because man can do something, does not necessarily mean that he should. Because nature has no boundaries, man does have a responsibility to consider the consequences of his actions. We need to take into account the over-reaching consequences of this project in an irreplaceable and unique, geological and biological ecosystem that is Northern Minnesota, the source of three of the greatest river systems in the North America, essentially sourced along the Mesabi Range. The fate of lands, air, and water in and around this project are linked by a unique geography that has no precedent and for this reason is impossible to map or predict, with certainty. What can be seen through experience is enough to forbid this project.
What will be the consequences of the land exchange, once Polymet owns the surface and mineral rights to the land on which their operations occur? What powers will the NFS, BLM, DNR and other parties have and exercise to control and monitor damage to our environment then? What will be lost due to changes in trade agreements like the TPP and other legal and political challenges affecting Minnesota’s rights to protection of its own lands and waters?
Downstream from the proposed Northmet project, where all mining water, sediment and dissolved particulates from this plant will eventually go, Jay Cook State park is home to 181 species of nesting and feeding fowl. There are bear, deer, wolves, coyote among 46 animal species in the park. Sax-Zim Bog in the St Louis River estuary is world famous wintering grounds for great gray, borial, hawk owls and other boreal forest birds. Over 60,000 raptors migrate over Hawks Ridge National Preserve in the St Louis River estuary each year.
There are other points of interest. The Laurentian Divide is home to 155 nesting birds and 40 wildlife species. In Embarrass, just north of the LTV site, there are birding and nature trails, river canoeing and fishing opportunities. At Babbitt, lies beautiful Birch Lake feeding into the BWCAW through the Kawishiwi River. So close that mining cannot help but affect the whole area.
The Superior National Forest Scenic Byway tour begins in Two Harbors and goes through Silver Bay to Aurora through Hoyt Lakes over 145 miles of untouched wilderness with relatively few roads. There are wolves here and Canadian Lynx, only a few of the animals that are attracted to this area. Wolves are of concern in particular, since the DNR has still yet to make a count of the existing wolf populations. This, after two hunting seasons. How do we know the threat to this vital apex predator without a study to determine its numbers?
The Erie Mining Company Railroad runs over the Laurentian uplands at 1573-1700 feet above sea level in the transportation corridor, over Partridge River waterways like 100 Mile Swamp, Stubble Creek. Polymet’s trains will traverse open wetland networks linked to Dunka River, North River, Ridgepole Creek , Seven Beaver Lake, Swamp Lake, Big Lake, and Yelp Creek, among a few.
There are 318 species of birds, 200 regular in the Superior National Forest of which 36 are uncommon, 30 rare and 61 very rare, among these the Pie billed Grebe and the Red breasted Merganser. With 155 nesting species, the SNF has the greatest number of breeding birds in any national forest. The BWCAW is of incalculable value biologically, ecologically and a popular wilderness area with over 200,000 visitors annually, with 1500 miles of canoe routes and 2200 campsites. Do we truly believe that copper mining so close to the entry points of this wilderness will not have significant consequences on these resources and the essence of this kind of experience? Some things cannot be measured and this is one.
When the SDEIS, without due attention to inevitable failures, predicts potentials, probabilities based on assumptions, presumptions, possibilities, I wonder how many years of field research and important, hard fact was missed? Instead, the report appears to be based upon “variability and uncertainty around many … model input assumptions” – in other words, a best case scenario that, in spite of this, predicts 500 plus years of mitigation and pollution from 20 years of mining in the Arrowhead. At which point the model terminates. This does not mean that maintenance will no longer be needed after 500 years or that suddenly the pit lakes and tailings basins will simply stop leaching and spilling. It means that the SDEIS stopped assessing the damage. Once the water is polluted and the ecosystem destroyed, one that took millennia to develop, we will be left with a toxic environment that will be changed forever, just fact. What more do we need to know to deny this permit?
The Arrowhead region is one of the crowning ecological jewels of this world. The National Forest Service is mandated to protect water resources as a number one priority. If not here, then where? The no mining alternative is, above all, a choice for environmental diversity and sustainability. People will pay to enjoy wilderness and this area is renowned for its beauty, its waters. Entrusted to us, will we fail to shield this wilderness from exploitation, or will we protect our base by preserving this planet’s most vital resource, starting with “the mother of waters” in the Lake Superior Basin.
Comment written and sent on March 7, 2014 to:
MDNR Division of Ecological and Water Resources Environmental Review Unit 500
St Paul, Mn 55155-4025
As of today, August 25, 2018:
I include two maps and some links concerning copper mining prospects in the Arrowhead below. The DNR has just denied any further study and is in the process of reviewing comments on permits in process.
There are lawsuits pending and a majority of citizens in Minnesota do not want copper mining in the Arrowhead.
Links of interest: