A copper sulfide mine in the Arrowhead of Minnesota will change the meaning of “north woods” as we know it.

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Over a century’s toll of mining iron ore in the uplands of the Laurentian Divide:

For the sake of our waters and the northern ecology of this priceless watershed, please send your comments:

MPCA’s NorthMet Project Webpage

DNR’s NorthMet Comment Portal

An Open Letter to Minnesota Governor Mark Dayton

The watersheds of the Mississippi, the Rainy River and the Great Lakes have their source in northern Minnesota, particularly in the Laurentian highlands of the Arrowhead, a wilderness that knows few equals in this regard.  Minnesota citizens, then, have a global responsibility to preserve this vital, rare and important aquifer from exploitation.

For over one hundred years, the state of Minnesota has condoned mining in the Laurentian Divide.  For over one hundred years the Missississippi and the St Louis Rivers, the Great Lakes and the Rainy River watershed have suffered from our failure to see the significance of these waters.  Elevated levels of lead and mercury … not including acid rain from the coal-fired plants supporting mining operations, smelters and other correlated equipment have done their part to interfere with vital natural processes.  Have we learned from our past mistakes?

In spite of this over one-hundred year history of mining in Minnesota and the correlated air and water pollution, failed infrastructure and inadequate protections, the state continues to promote mining activity.  Desperate measures to sustain an industry that will fail, that will pollute vital water reserves, where there can be no adequate protections in this water rich area, in an ecology that has no precedent on Earth, will serve no one in the long term.

Copper mining will destroy our water resources and our one of a kind wilderness in Northern Minnesota.  I was disappointed to have read that you support the NorthMet Project.

Sincerely,

Anita Suzanne Tillemans

 

aquifers surrounding the Babbitt area where Poymet wants to build a copper mine
aquifers surrounding the Babbitt area where Poymet wants to build a copper mine

 

Link to articles on arterutan concerning copper mining in the Arrowhead:

Arrowhead Aquifers and the Hill of Three Waters

Arterutan site link to other content on the Northmet Project

 

 

 

What would Sigurd say?

 

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Sigurd F Olson believed that beauty could be destroyed by a sound or a thought.  He spent his life championing protection of all wilderness, in particular the Boundary Waters Wilderness Area.  He lived in Ely, Minnesota and built a cabin on Burntside Lake where he meditated and found peace.  He knew that the appreciation of beauty was love at its essence, a profound appreciation of wilderness; and beauty, a necessity for our survival.

In northern Minnesota spans the wilderness he held so dear; and he lived his life in appreciation of wilderness through his writings and his advocacy.  He helped spare the BWCA from an onslaught of interests that would have destroyed it through the construction of roads, permits for motor boats, planes and eventual development. Would he have failed to stand up to copper mining interests?

As Minnesotans and stewards of the Arrowhead, at heart of three of the greatest river systems in North America, we are on a precipice.  What greater security is there than wilderness, clean water and air, the beauty and the silence of untouched wild areas?  International interests, determined to mine copper in the big Stoney, the great Minnesota Arrowhead, seek permission to do so.  Should we open this Pandora’s Box at any price?

Once copper sulfide mining has begun, the entire region, by precedent, will succumb to other like-mines in and surrounding the BWCAW, which lies on this prospect, that of the Duluth Gabbro Complex or the big Stoney.  There are already over a thousand prospecting holes, which have been drilled at the boundary of the BWCAW and along Kawishiwi River and Birch Lake to date.

Estimations through computer modeling have determined that 20 years of the proposed Polymet mine would destroy at minimum 912.5 acres of irreplaceable wetlands at the mining site alone, and as a consequence flora and fauna dependent on these waters, leaving a toxic environment for hundreds of years, perhaps into perpetuity.  The boundaries unknown.

Consider that the St Louis watershed consists of 3,696 square miles of mostly open wetlands and high quality habitat for plants and animals… including, as an example, the home of “100 Mile Swamp” between the two watersheds of Embarrass and Partridge rivers .  St Louis River’s headwaters are located at Seven Beavers Lake near the proposed Hoyt Lakes processing plant and a few miles south of the mining site in corporate Babbitt.  It’s headwaters flow for 179 miles before becoming a 12,000-acre freshwater estuary near Lake Superior, where it enters the body of the Great Lakes.

The mine site will be located in Babbitt, which hosts both the St Louis River watershed and the Rainy River watershed.  Can we be assured that the water in contact with waste rock there and therefore, discharge of sulfuric acid and other contaminants will not be shed into the Rainy River Basin which contains the BWCAW, Voyageurs National Park, Vermilion Lake and River, Crane Lake and others?

The processing center, also, is located in a complicated geological area of the Laurentian Divide at Hoyt Lakes.  The Embarrass River and the Partridge River on either side of this Divide will be affected.  In addition, the Vermilion River watershed is adjacent to the Embarrass River watershed on the north.  What long term effects will be seen here as well?  This is one of many unknowns.

I feel certain that Sigurd Olson would have stood up to copper mining interests.  He would have stood up to interests that threaten to destroy the wilderness of northern Minnesota.  He spoke plainly and with an understanding that the battle goes on forever and that we must all have a hand in protecting wilderness.

Through blasting, transportation corridors, energy needs like the coal fired plant in Silver Bay, water pollution, air pollution, noise pollution … what will be left of this wilderness that we now know as the north woods of Minnesota?  The smallest creatures, insects, fungus, flora, fauna will be poisoned by these mines and this will affect the larger creatures that depend upon them, like birds, deer, wolves, lynx, creatures great and small.

Polymet alone will be applying for over 20 permits.  Included in these are “water appropriation permits”, which is a benign way of saying water mining permits, dam safety permitting, permits for taking endangered species and others needed to make this mine palatable.

For our national security, for the health of this planet, big Stoney of the “mother of waters”, Lake Superior, should be considered of far greater importance than any short term gains that may be had through mining this precious and priceless natural resource.  Please let the National Forest Service, Minnesota Department of Natural Resources, and the Bureau of Land Management know that you do not want the St Louis River watershed and the Great Lakes to serve as a conduit for wastewater from a copper sulfide mine in the Arrowhead.

There are no guarantees but this, that water will find its way to the sea through our Great Lakes from these proposed mining operations.  Are we prepared for the consequences? The health of this planet may be determined by our will to continue the fight.

 

 

 

 

Will we trade the infinite for private profit?

hull_rust_mine
Could dimensions of copper-sulfide mining reach the proportions of the Hull Rust Mine in Hibbing Minnesota? Babbitt, a doorway to the BWCA at Birch Lake and the location of the proposed NorthMet copper mine, is located in the Laurentian Uplands, a recharge area for three of the greatest river systems in North America.

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

Information concerning the NorthMet project

 

 

Comment period on Polymet water permit opened August 11, 2017

The 30-day comment period for Polymet’s permit to mine and pollute the headwaters of the Great Lakes’ St Louis watershed, was opened on August 11, 2017.  If entirely permitted, this privately owned company will be allowed to construct an open pit copper sulfide mine for profit in the Arrowhead of Minnesota leaving the necessity to treat and protect this vital aquifer for centuries.

Polymet claims that it will do the clean-up and protect our waters.  What company can make this promise in truth anywhere, especially in this complex geological aquifer?

Please send your comments by September 12, 2017

http://www.dnr.state.mn.us/polymet/permitting/water_app.html#plymtwap

The difference between “endangered” and “threatened” can make all the difference …. to a mine.

Timber wolves have long shared the wilderness with mankind and so it is in Northern Minnesota.  If Polymet builds a copper mine in the Arrowhead of Minnesota, and sets the precedent for other companies to do the same, it becomes obvious, then, why the removal of wolves and others from the “endangered species” list has been such a persistent issue.   In order to mine, the taking of endangered species becomes an added cost, since a permit must be issued for the taking.

Among the animals that have been taken from “endangered” to “threatened” are the gray wolf and the Canada lynx.  I include just one link below.

https://www.fws.gov/midwest/endangered/lists/minnesot-spp.html

Our water will be more than “threatened” by a mine in this wilderness, and so will the lives of all species in the area, whether “endangered”, “threatened” or not.  A rose by any other name is still a rose.

DNR Plans to Sell Mineral Leases in Northern Minnesota Covering Approximately 195,324 Acres

Moose in the Arrowhead ... already affected by global warming
Moose in the Arrowhead … already affected by global warming

The Department of Natural Resources plans to hold a sale of state-owned non-ferrous metallic mineral leases in Beltrami, Itasca, Koochiching, Lake of the Woods and St Louis counties.  This acreage totals about 195,324 acres.

The notice was published today in the EQB Monitor and State Register, Monday, Jan. 30.  For information on the sale and solicited public comments, please view the DNR’s website and the link below:

State Nonferrous Metallic Mineral Leasing Public Lease Sale

At the recent water summit in Morris, Minnesota, Governor Dayton reported that 40% of the water in Minnesota is unfit for human recreation, in some areas this percent is over 90%.  In the Gulf of Mexico, there is an area of over 120 miles where there is no life … a dead zone, my words not his.  He made the point that, in effect, what we do with our water is everyone’s business.  So true.

It is right and good that we work to protect our waters by educating the public on conservation and clean up measures.  The most effective and best real long term measure, though, would be to stop pollution at the source..  Do we accomplish this by selling the very land and waters that need protection to those who would exploit it?

These leases are being sold now for exploration and this means more intrusions into an already endangered aquifer. The DNR would not sell leases if there was no intent to grant mining permits.  Twin Metals and Polymet are only two interests that seek to mine for copper in these invaluable northern aquifers.

In effect, by selling mineral leases at the source of the Rainy River, the Mississippi or the Great Lakes, and linking money made from any of these leases to public education, the state of Minnesota creates a dichotomy, since mining of these water reserves endangers the future of the intended beneficiaries.  Better yet, invest in equitable education by creating the kind of environment with a future in it.

MPCA / Minnesota’s Imperiled Waters List 2016

In our every deliberation, we must consider the impact of our decisions on the next seven generations.

– Iroquois Maxim (circa 1700-1800)

 

 

More news on Northmet …

Bear Head State Park (near the proposed NorthMet Project)
Bear Head State Park (near the proposed NorthMet Project)

For information on the permit process (from the DNR)

and on financial assurance and preparations the DNR is making for the environmental battle ahead .

Permit processing will begin shortly.  One of the permits that will be needed allows for taking of endangered species.  There are timber wolves, Canadian Lynx, moose, many waterfowl and other important species that make this area their home …. not to mention the water.

 

aquifers surrounding the Babbitt area where Poymet wants to build a copper mine
aquifers surrounding the Babbitt area where Poymet wants to build a copper mine.

 

What will happen to fishing through loss of diversity and pollution of groundwater?
What will happen to fishing through loss of diversity and pollution of groundwater?

 

How many wilderness-related jobs and experiences will be lost?
How many wilderness-related jobs and experiences will be lost?
Moose in the Arrowhead ... already affected by global warming
Moose in the Arrowhead … already affected by global warming

Comments on the Final Environmental Impact Statement for the NorthMet Mining Project and Land Exchange, Hoyt Lakes, St Louis County, Minnesota

aquifers surrounding the Babbitt area where Poymet wants to build a copper mine
aquifers surrounding the Babbitt area where Polymet wants to build a copper mine

 

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.

Comment #1

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.

 

Comment #2

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.

 

Comment #3

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.

 

Comment #4

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.

 

Comment #5

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.

 

Comment #6

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.

 

Comment #7

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?

 

Comment#8

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?

 

Comment #9

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.

 

Comment #10

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?

 

Comment #11

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.

 

Comment #12

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.
Sincerely,

December 19, 2015 REVISION

Anita Tillemans

 

 

As we approach a decision on the Polymet Copper Mine …

Mn lake and loon

As Governor Dayton proposes funding for a study to determine Polymet’s finances at the present moment, I wonder how possible it would be to determine those finances into the distant future? Are there any reassurances possible that will predict this corporation’s ability or willingness to clean up the inevitable long term effects of copper mining pollution, into perpetuity? Shouldn’t we consider the already abundant information that promises otherwise?

Grateful that the Governor will be exploring other mines in other areas, I wonder,  is there any other area quite like that proposed in St Louis County on the borders of the Boundary Waters Wilderness Area?  Pollution from mining ore has already done harm in this ecologically fragile area, at the heart and head of three great rivers, and Lake Superior, along Giants Ridge and the Laurentian Divide, in the Arrowhead region of Minnesota.

Will we learn from our own experience and say no to any further degradation of an area so rich in natural beauty and a most essential commodity, water?

You will find several articles linked below concerning this area and the proposed copper mine::

http://www.mprnews.org/story/2015/06/29/polymet-dayton

http://www.kare11.com/story/news/politics/2015/10/24/tour-of-mines-precedes-daytons-tough-polymet-decision/74538374/

http://www.hibbingmn.com/news/local/dayton-all-in-on-polymet/article_04a57e9a-79f0-11e5-ab2d-4fb882a0a823.html

Dayton ‘undecided’ on PolyMet but says ultimate decision will be his

https://anitatillemans.wordpress.com/?s=Arrowhead