The Warning (In the Groves of El Dorado)


A shaft of light beamed down

Through sheets of tropical rain

Glowed in outstretched palms

Fraught with lingering pain.


As rains fell in a fury

Like tears in a flood of rage

The elder stood sore and weary

At the sight of what he surveyed.


Deluged by memories of Eden

Lost in the endless brigade

To cull the jungle for profit

As if a penny arcade,


Where rainbow colored tears

From one armed bandits stray

Oil streaming from virgin lands

Beauty, blessed, betrayed.


Vanished in the slaughter

Countless bounties to be mourned;

The groves of El Dorado

Now dying and forlorn.


Standing in solemn reverence

As rains came to a halt,

He held his gaze ahead

In the steam of this jungle vault.


Witnessing, at dusk, a warning,

As ghostly remnants remained,

Poised in silent testament

Where giants of Earth once reigned



The facts speak for themselves …

Line 3 is, for the most part, a new line with a new route and not actually a replacement.  The “aging pipeline” is being left in the ground and in order to determine a new route, according to an article written by Mike Fernandez of Enbridge, there were 320 modifications prior to the final determination.  That alone tells us just how tricky it is to navigate the waterways of northern Minnesota.

If Minnesota’s standards are so high as he suggests, higher than the federal guidelines, then, why have any pipelines been allowed in a land of 10,000 lakes at the headwaters of the Rainy River, the Mississippi River and the St Louis River, extreme headwaters of the St Lawrence Seaway and the mouth of the Great Lakes at Lake Superior?

Oil and water don’t mix and this is no place for a pipeline.

Counterpoint: Poetry and fiction …. by Mike Fernandez at Enbridge

Dangerous Pipelines, Greenpeace reports

Water, Wilderness, Dark Skies and the Seventh Generation


In Northern Minnesota, a land of water, wilderness and dark skies, water protectors from all over the country are engaging government, Governor Walz, in particular, and Enbridge, Polymet and other multi-national corporations by peaceful protest.  They ask simply to protect the water for future generations now, not after the fact.

Once the pipes have been laid and the mines built, there will be no way to keep tar sands oil, copper sulfides and other pollutants out of the water from these enterprises in a land of 10,000+ fresh water lakes.  The damage will have been done and this is just a fact.

The Boundary Waters Canoe Area Wilderness and Voyageurs National Park in Northern Minnesota have been designated dark sky sanctuaries for good reason.   For wilderness.

Under a bridge of Maples
Bemidji Maples


Where is the sweet spot in our challenge to frame a better world?

The possibilities for reform are as great as the challenges we face today.  In recognizing that all in this world depends on the framing, how we perceive these challenges.

near Babbitt, MN

On the one hand, we have a global climate disaster in the making while corporate executives of fossil fuel and metallurgical industries seemed bent on making it worse, for their financial profit.  The actions they take to expand their footprint across the globe does not benefit them essentially and does not make the world a better place for their children and grandchildren.  Money has taken common sense out of the mix.

On another, we have the need to find alternative sources of energy that do not damage the environment and make the climate a greater challenge.  Wind, solar, water, insulation, thermal etal … I am not an expert on any of this, but I am aware that any of these alone is not the answer.

To store energy, at this time in our consciousness, batteries seem to be the answer … but at what cost?  Disposal of spent batteries, production and the mining of resources are also a challenge.

So, there is always the other side of an argument.  What do we do to find a sweet spot in our search?  We cannot continue to destroy the environment for quick answers or financial gain.  Money needs to be taken out of the debate if we are to find the best and most sustainable solution.

In the deep north of Minnesota a battle is raging for the health of our waters. In the land of sky blue waters, in a region that finds the source of three of the greatest rivers on the North American continent, our Minnesota government has approved a new tar sands pipeline by the Canadian company Enbridge.  The pipe will leak, as pipes do.  It will fall into disrepair and be left to deteriorate in ground, as Enbridge is doing with their older pipeline to spare them the cost of removal.  It will despoil and pollute ancient wild rice sources and wetlands throughout its course across the deep north of Minnesota, a land of more than 10,000 lakes.  In the nine months that it takes to build, four thousand or so workers will have a job and then go home.  The pipeline and the pollution will remain.

Minnesota is also at the heart of a fight to keep the Boundary Waters Canoe Area Wilderness and the St Louis watershed, and Rainy River Watershed from being pollluted by proposed copper mines in the area.  Polymet and the Northmet Project being one.

These battles for the sake of our waters and lands are being fought across the country.  We have an outgoing president in Donald Trump who is fast tracking this destruction.  And so, my questions concerning the framing and the solution to these formidable challenges: what do we do to find a sweet spot where our energy concerns lie, and how do we get money out of the heart of our decisions on these matters?

Apache Nation Organizes Day of Action Against Proposed Copper Mine

North America is About to Get Its Largest Copper Mine

For a better world we need to do better than this.


Removing oil pipelines and other dirty infrastructure from our wetlands would create jobs too, better jobs

The focus at this demanding time in our history needs to be on what can be done and not what we need to stop, while not forgetting one or the other.  It’s said that the best offense is a defense.  But what does this say to us now?

The motivation for a defense is fear.  What could we do with a different mindset?  What is possible for Minnesota if we made our focus removing the oil pipelines instead of playing defense to Enbridge’s offenses?  What if we played offense to other multinational corporations that would make Minnesota their cash cow while leaving our environment polluted and it’s citizens to clean up the mess?

When a fighter puts his fist up to block a punch, he has the other hand to knock his opponent out.  What Enbridge is doing in the state of Minnesota is no less aggressive than a fighter in the ring.  What Polymet, essentially Glencore, with it’s proposed copper mine in the Laurentian Divide at the heart of three of the greatest river systems in the North American continent, in Minnesota, at the extreme headwaters of the St Lawrence Seaway, the Great Lakes, the Rainy River watershed, and the Mississippi headwaters endangers our national security, our waters.

We need to put more focus on what can be done to create the kind of world we need long term and stop being pushed into the ropes in this fight.

For more information on this discussion:


Questions Concerning Mining and Pipelines in Minnesota’s Deep North

Questions Concerning Mining and Pipelines in Minnesota’s Deep North 

  • How much water will be drawn from Lake Colby to meet Polymets needs and to control levels of the St Louis River?
  • SDEIS admits candidly presumptions were made to inform the model and therefore, as a consequence, outcomes cannot be truly assessed adequately … ongoing assessments and studies will be needed even after the permit has been granted and since models are only as good as the data provided, what of the unknowns?
  • What of the decision made to halt discharge of waste rock into Lake Superior by Reserve Mining in the 1970’s?  What of the drainage ponds that continue to leak to this day?
  • How many wolves remain in the St Louis River watershed?  How do we know that these will not run the threat of extinction by mining in the area, noise and pollution affect den habits … and since the area is a stronghold for this species, why haven’t their numbers been determined for this study ?  Wolves mate in late February and den in late April when sites are located for raising the young.  What affect will the noise and pollution of precious waters and streams, traffic do to change these habits and lower populations?
  • Wild rice has been harvested for thousands of years in this watershed.  Have studies been made to determine the extent of damage of releasing untreated contact water into the St Louis River, tributaries, lakes, wetlands and aquifers … including draw down of the water table not only at the sites but beyond the mining and processing sites?
  • Does the study model consider transportation corridors beyond the 7 mile link between mine and processing centers? or the related pipelines?  Rail, road and air traffic will increase with mines in the area, most assuredly.  Have the levels of noise been considered along with dust, light pollution and smells associated with diesel, gas, electric machinery, rigs 24/7?
  • Will the ore be smelted on site? and what of that air, noise, smell and water pollution from this factor?
  • Loss of wilderness in Lake, Cook and St Louis counties alone will be felt almost immediately through sights, sounds and smells of mining operations, 24/7, air pollution from these smells and dust….  Solitude and peace will be gone and the wilderness.  Can we afford the cost for a relatively few short-lived jobs?
  • In the long term, though, these losses will be dwarfed by loss on a greater scale than the SDEIS can model, contamination of the big stoney or the mother of waters.  No study has ever been made to determine just how much water sheds from Arrowhead aquifers.  Who will ultimately pay for the mistake of building mines and pipelines through the heart of Minnesota’s deep north?
  • Ultimately, Polymet’s mine will be a shadow of operations in the area once the precedent is set and floodgates are open.  In addition, with pipeline #3 burrowing it’s way into the aquifer, crossing the Mississippi headwaters and wetlands that support an abundance of life dependent on these waters, on its way to Duluth from Canada, who will profit?  It won’t be the residents.
  • If the NFS and BLM have no intention of allowing mining in the area of the BWCAW and the Rainy River Watershed, then why have exploratory permits and almost 2000 drilling holes been allowed into this area?
  • What will be the final amounts discharged from leaky pipelines, mines and processing sites once the resources are spent and jobs are gone?  What will be left?
  • What will be left of the wetlands, forests, streams and waterfalls … the flora and fauna … the wilderness?
  • Shouldn’t our relationship to the resources that support our lives be based on stewardship?  What profit is there in destroying our base?
  • What of the migratory foul, the wolves, the Canada Lynx … the St Louis River estuary?
  • Are the chemicals used in water treatment safe? have they been tested? have all metals, contaminants, filters from mining and pipelines proved anything less than toxic to life? 
  • How many of the wilderness activities will be altered permanently in the area through the processes of tar sands oil delivery and mining?
  • Will discharges into the St Louis River from the wetlands surrounding a tar sands oil pipeline and copper mining bring algae blooms, depleting water of oxygen and threatening already threatened aquatic plants and animals and create a dead zone at the mouth of the St Louis?  Have contaminants been estimated, modeled for the mouth of this great estuary?
  • Has possible contamination from brackish systems underground been considered as these structures are built?
  • Has climate change been factored into the model?
  • How many seasons of water data have been integrated into the models used to approve these dirty systems?
  • Drought is first noticed in the highlands.  Have the effects of a draw down been considered in our models? loss of pressure in the artesian wells?  Do we know how much water there is to take for mining?  Isn’t any water too much?  How far will the spillage of one Enbridge pipeline spread through these wetlands of Northern Minnesota?
  • The wellness of a society depends upon respect for the environment?  What respect does any foreign corporation have for the welfare of our waters in Minnesota?
  • Is any water filtration system adequate to protect these waters more than 500 years into the future … what kind of management can be expected during and after closure to manage sulfate concentrations in the effluent of a copper mine?
  • How can a tailings pond hold up indefinitely under the harsh conditions of Northern Minnesota and what of global warming and ever serious climate events?
  • What measures will be taken or are possible to reduce “fugitive” dust from construction and operations on site and on the road?
  • How big would the final basins and pits be once copper mining has been established?
  • How much can be done once pipeline #3 spills undetected or uncontrolled or mismanaged?  What kind of clean up is even possible with tar sands oil?
  • What of the pollutants from the hydrometallurgical process, smelting operations?
  • What is PGE precipitate, compositions?
  • Have possible failures been modeled? to pipeline, tailings basins, waste rock piles and pits?
  • What do we have in the words: proposed, possibility, potentials, predictions, probability …. but words.  Why have two of our governors approved of the Northmet Project and Pipeline #3?  What were they thinking and what was behind their decisions?
  • What are the 28 solutes?
  • What is a P90 level exactly?
  • What engineering controls will be used in the rivers and wetlands for the NorthMet project? and what controls for construction and operation of Enbridge’s pipeline #3?  What controls are possible in such a priceless environment?
  • How much untreated water will actually be released from the proposed Polymet mine, how much seepage from pits and tailings basins actually?  Will we never know until it is too late to do anything about it?  One reason these structures should never be built.
  • How was affected wetland acreage determined, what data concerning aquifers and underground water  flowage referenced?  were long term studies made on the effects of drought conditions and possible draw down potentials considered?
  • Has consideration been made for the open nature of the St Louis River watershed’s wetlands, the Mississippi headwaters, streams and marshes associated, and the connectivity of all these bodies to the immediate areas affected throughout Northern Minnesota in the case of the Northmet Project and Enbridge’s tar sands oil pipeline#3?

Our health and well being depends on wetlands and wildernesses, apex predators and all manner of life.  We cannot survive without clean water or the flora and fauna, all living things that depend on water as we do.  What will be our legacy to the 7th generation?

For love of wilderness.

Links to documents on landscape ecology ….




MPCA Rainy River Headwaters Watershed Monitoring and Assessment Report 2017



M-159 Babbitt_copper_pdf

A Less Than Perfect Union

A Case for Justice

The Nature of Intelligence and the Process of Peace_pdf

Man as Nature

Enbridge Line 3 Report and effected waterways and bodies

Air Quality Permit Comment

State of the BWCA 2018 Friends of The Boundary Waters

USDA report School Trust Land Exchange Superior National Forest 2015

MDNR report on Mn State School Trust Land Exchange Case #4558


Water Facts and Human Society


Water Facts and Human Society

Mundane are the myriad of truths about water.  Still, that does not change the fact that water is essential, nor that death is an immediate consequence to life without water.  We see the results of our failed relationship with water in the news every day; and every day that we ignore the fact that our relationship with this vital resource must change, we come closer to extinction.  According to the World Health Organization, at least 2 billion people drink from contaminated water in 2019 and by 2025 half of the world’s population will be living in water stressed areas.  Eighty percent of all diseases in the developing world are water-related.

As third world countries develop, land becomes a commodity rather than a resource for all.  Farms are turned under and communities laid waste for profit.  Numbers become more important than quality and therefore population becomes its own worst outcome… because, there is money to make from the many.  When lives come cheaply, the rich make profit from the destitution.  In desperation, people have limited choices and those who would use their desperation do.  Facts speak for themselves and this is nothing new.  Human civilization, as we know it, needs to make some vital changes and much sooner than we have planned.  The truth is what it has always been and will remain.

These are the cold hard facts of winner take all.  This kind of struggle will be the end of us; the problem compounded by our short sightedness as a species in our relationship to water.  We use it, and since approximately 70% of the earth is covered by water it appears to be abundantly available, except when it isn’t.  A common known statistic is that only 2.5% of this water is fresh and only 1% of that is available.

Minnesota is at the heart of three of the greatest rivers systems in the North American continent, the Mississippi River, the St Louis River and the Rainy River, draining into the Gulf, into the Great Lakes at Lake Superior, and Hudson Bay respectively.  Lake Superior, the largest body of fresh water by surface in the world (Lake Bakail the largest by volume) lies at the mouth of the St Louis River, which is the largest river to drain into Superior.  The volume of fresh water in the Great Lakes runs second only to Lake Bakail and contains 21% of the world’s freshwater.

As you can imagine, the area covered by the three river systems sourced in Minnesota is enormous; and so, the importance of keeping these systems healthy and, in effect, the world secure.   The Hudson Bay drainage basin is estimated at 1,490,00 square miles.  The St Louis river, at 3,634 square miles and flowing into an irreplaceable estuary and the Great Lakes.  The Mississippi drainage basin at 1,151,000 square miles is only exceeded by the Hudson Bay drainage basin.  At the same time that organizations abound proposing to clean up and make sustainable the systems in place, most are ignoring the “elephant in the room” in Minnesota.

As Minnesotans debate tirelessly over the past almost 50 years concerning mining in the Laurentian Divide, mining continues.  It pollutes our precious water reserves in the ground, the air and waterways, lakes and wetlands.  The facts of this toxic pollution abound with acid rain destroying the forests, waste from waste ponds seeping into the ground and into Lake Superior and throughout the region reducing the quality of life and making the St Louis River and its estuary into an “area of concern”.  None of this, though, prevents consideration of the area for the most toxic mining proposals, opening up this area surrounding the BWCA and the BWCA to copper mining, all while declaring that copper is needed for a sustainable new energy future.  What future can we have without fresh water?  How secure is a country without potable reserves of freshwater?

There are 260 species of fish that must imbide the waters of the Mississippi as its pollution runs downstream.  What of the 326 some species of birds, 60% of those of North America, that use the Mississippi River basin?  Forty percent of migratory waterfowl on this continent rely on the Mississippi River corridor.  If we hold these creatures lives cheaply, how cheap do we hold our own then?  These are the very lives that our lives depend upon.

I offer Minnesota as only one example of the way in which our thinking needs to change.  If one thinks of the “whole” of an activity, the costs of that activity will become clear.  Mining and other like activities cannot be thought of as solutions when these are, in themselves, the problem.  The human species is tireless in its search for “newer and better”; but have we forgotten the things we’ve left behind?  Millions of years cannot be discounted in a moment; and this “moment” of the last two hundred years does not a nuanced progression make.

We are called on to rethink our assessment of the substance of water and the amount that we actually use in any given activity.  We need to call on the past for enlightenment in the effort.  We are not in opposition to the nature surrounding us, we are at its core.  We destroy and treat thoughtlessly the very thing that we need for our survival.  For instance, in Professor Tony Allen’s conceptualization of water, using the phrase “virtual water,” we are provided with a more truthful view of actual water consumption.  Each plateful of food, each activity, whether single or as a company, a community … takes on a broader impact in our minds.  We are not simply eating a steak, we are consuming the water that it took to produce that steak.  We are not only driving an automobile, we are responsible for the water it took to mine the steel and other components for that car, the pollution of water caused by its production, as well as the gasoline it takes to run.

The bottom line should never be money, which most of us will never see.  The bottom line is, for a fact, water.  Without it, there is no life.  It will be the cause of future wars and great distress if we choose to ignore the facts.

For so many, survival means making money and success is counted rather than lived.  We match our worth with worth in quantity rather than quality.  How big are our houses, how fancy our cars, our lifestyles….  As a society, we judge others by the beauty of their surface rather than the content of their character.  Is it any wonder that the wealth of this Earth is being lost and degraded with this point of view?  Is a beautiful wild place but a place to exploit for profit or recreation?  Does our current outlook on our own happiness make for one that runs deep and creates long lasting futures for any of us?  Have we forgotten the very things we need for true happiness?

Our bodies contain up to 70% water and some organisms contain up to 90% water.  It is the first building material of a cell, regulating temperature, transporting and making available the food we eat through the blood stream.  Water flushes waste, it lubricates joints, acts as a shock absorber throughout the body and, importantly, the brain and spinal cord, and among so many other things it enhances mental function.  The brain contains 73-75% water.  Adults need at least 2.3 to 3.2 quarts of water each day in their food or otherwise, for survival.  Perhaps education, so dearly needed, will make the change?

I fear that humans will do as humans do, so often, thoughtlessly.  We live in the moment.  Most of us don’t plan well for our futures.  We love, we hate, we dance, we sing, we make war, love, and work for the ones we love.  We are often controlled by passions of the moment; and this makes us all the more susceptible to the ones who don’t.  What will make the difference?  Perhaps we need to love ourselves better and more fully? What could be more important in that effort than water?

I have included a few of the links visited for this paper, below:

USGS  Watersheds and Drainage Basins:

Visually understanding the amount of water compared to our planet size:

Water uses and percentages in our bodies …:

Up to minute stats on usage amounts. Envisioning “virtual water”:

Quick Wikipedia facts on water:

For love of wilderness and the health of our waters.

Anita  Dedman-Tillemans

August 2019

Appeals Court puts stay on key permit for Polymet.

Concerns are monumental for good reason. What could be more important for national security than the safety of our waters?

Court puts key PolyMet copper-nickel mine permit on hold

Court panel delivers victory for PolyMet opponents

On pending Polymet copper mine and Enbridge oil pipeline #3 …

As we move forward into a new era where the prospect of fossil fuels has become a nemesis to our survival long range, there are major decisions we must make concerning how we will transition to a new energy economy without destroying the natural resources we need so dearly … like water.

Copper has become an “essential” tool in the new age economy, but how do we “mine” this resource sustainably without endangering our natural resources?  I suggest that mining in a water dependent area like the Arrowhead is not the way.

As the State of Minnesota moves forward with the permitting of a copper mine (Polymet’s NorthMet project) in the center of this ecological treasure (approval of which both Governor Dayton and Amy Klobuchar have supported) lawsuits are in progress.  In an effort to defend the state’s bad decision under the direction of our new governor, the taxpayers, unwittingly, will be paying for the defense of something the majority of Minnesotans did not want … and in the long run, once begun and into perpetuity, will also pay the consequences.

As an additional note of great consequence the comment period for the Enbridge Pipeline #3 pending permits is open until May 17, 2019; and you can comment here.  I have also included the link to my article What we should all know about Enbridge’s replacement line 3 in Minnesota.

For the sake of our wilderness let’s make our voices heard.


Some articles of interest on Polymet and the Northmet Project:,14863


Enbridge comment period open from March 18 to 4:30 p.m. May 17, 2019:

Arrowhead Aquifers and the Hill of Three Waters

We could speak of the beauty, the wild, the spirit of something greater than ourselves, the sustenance we all gain from these masterpieces.  Such is the Arrowhead of Minnesota

What is the true source of three of the greatest water systems of North America, that of the Rainy River, Lake Superior drainage basin, and Mississippi River? Have underground aquifers and waterways in the Arrowhead been mapped such that we can understand the full scope of these resources?

Water cascades in great quantity from the “big stoney” to Lake Superior and parts unknown …

Legend has it that various tribes of the Ojibwe were pressed to defend their forests from an invasion of Sioux at one point. Since the buffalo had not returned to their territory as expected, the Sioux were in search of the sustenance in lands claimed by the Ojibwe, abundant and fruitful, forested wetlands of what is now known as Northern Minnesota. Since the Sioux were fierce and savvy warriors and could defeat the small tribes of Ojibwe individually throughout the land, leaders decided to unite. They met to decide their strategy on the “hill of three waters”… a unique quirk in geography, one mile north of present day Hibbing where water falling at this precise point can divide and flow in three directions, one to the Gulf of Mexico, one through the Great Lakes to the Atlantic Ocean, and the last to Hudson Bay.

Chiefs of the Ojibwe traveled from Canada, Lake of the Woods, and Nett Lake following water routes in the Big Fork River and Shannon River to unite with other leaders at the “hill”. Leaders of those Ojibwe in the Big Sandy Lake area and Mille Lacs Lake took waters north on the Mississippi and Prairie Rivers to Day Lake and then up Day Brook to the “hill”. Chiefs from Wisconsin, Fond du Lac, and Lake Superior joined their brothers on the “hill of three waters” by taking the St Louis River and Penobscot Creek. Unified, they eventually defeated the Sioux and regained their territory.

Along the Laurentian Divide where the “hill of three waters” is located, white settlers believed that the direction of flow was directly North and South. Native Americans knew long ago that this was not the case throughout the divide, and that water flowed to the river basins of Lake Superior, Rainy River as well as the Mississippi River, particularly at this point, where the Hull Rust Mine is located now. As a result of mining and pollution emerging in unexpected areas, we have learned that unusual geological formations exist in northeastern Minnesota that guarantee a complicated and diverse environment not easily understood.

For instance, portions of the South Kawishiwi River Intrusion and of the Partridge River Intrusion can be found underground at the same Babbitt location in and around mining facilities. Therefore, underground water in parts of Babbitt flow not only into the Partridge River watershed but also into the Rainy River watershed, which shares water with BWCAW. This is complicated even further by overlying and sometimes interconnecting aquifers – surficial and buried, contained and uncontained within varying compositions. Contained aquifers can potentially discharge water a hundred miles more or less from the recharge area or site of pollution. Groundwater and surface water frequently diverge in this area, and so more knowledge is needed concerning Minnesota’s groundwater geology before we can truly begin to understand the consequences of our actions regarding mining of any kind.

Wetlands abound in the “stoney”, along with thousands of flora and fauna, many rare and uncommon. There are orchard orioles, killdeer, snow geese, loons, woodcocks, purple finch, mink, great blue heron, broad-winged hawks, eagles, partridge, beaver, wolves, moose, bear, Canadian lynx, coyotes, blue bills, mallards, night hawks, snowy owls, white-throated sparrows, deer, blueberries, bearberry, rock ferns, caribou moss, and so many other species of plants and animals. What is the potential harm to these populations if the fragile balance of this ecosystem is destroyed, an ecosystem so interconnected with the health of its waters?

Do we sell or do we protect? This is what this decision concerning Polymet Copper Mining comes down to, essentially. There are no real guarantees that Polymet will be around to pay for clean-up once the mine closes and the money runs out of state; and we will never be able to undo the damage of their intrusion into these hydrological treasure troves, a literal mother lode for our planet’s fresh water. Have we already done irreversible damage by allowing almost 2,000 bore holes for copper mining prospectors near the BWCAW?

Groundwater in the area naturally seeps into holes drilled or pits dug in the area. As a consequence, while the mine is in operation, Polymet will continuously discharge water from mining pits and tailings basins to extract the ore. Colby Lake will serve as a source of supplementation and discharge, and widespread discharges will occur in the form of untreated, contaminated water along with altered (treated) water at both sites into the Partridge River, Embarrass River watersheds and the entire St Louis River watershed. These are the knowns.

Since aquifers recharge normally on high ground and discharge in low lying areas, the affected aquifers and water bodies will essentially be mined, as rock is extracted in the Laurentian highlands, instead of recharging (as nature would allow). Loss of pressure, as a consequence, in confined aquifers (artesians) could have devastating and far-reaching consequences; and, of course, we cannot truly know how many wetlands will be lost due to drawdown of the water table and the cumulative effects of long term contamination above and below ground.

Once the mine is closed, the threat to vital fresh water resources would continue, most likely into perpetuity and, therefore, maintenance at an estimated cost of at least $6,000,000 annually. The actual costs will, more than likely, be far greater. In a myopic view alone, what of inflation and the logistics of changing political will and financial realities? How long will water continue to seep into and from the bedrock of the Laurentian Divide contacting waste rock in the mine pits as well as contaminated water in the tailings basins? Do we even know how much water is involved? Can we know?

Ongoing treatment, passive or aggressive, will never return these waters or this region to its original state. Observe ongoing pollution witnessed from mining in the area already. What financial or political assurances would suffice in a tragedy of the scale that sulfide mining would unleash?

From limited hydrological information available to date concerning underground flowage for these vast bedrock formations in the Arrowhead, it seems that the calculations Polymet has made are insufficient to describe the scope of ecological damage possible in this unique environment, and therefore, the effect on freshwater reserves in the stoney of Lake Superior and Rainy River Basins at the very least. Consider the diversity and interconnectedness of the aquifers in St Louis, Lake and Cook counties, the unpredictability of discharge locations from confined aquifers, the potential of contamination by bore holes traversing aquifers. Due to these and so many unknown factors associated with this complex geological area, how is it possible to predict short term or long term consequences of mining this priceless water table for the extraction of any ore body?

It is likely that water in the area’s confined aquifers could be thousands and possibly millions of years old, the implications of which cannot be ignored for any amount of money. We have waste on this earth that could be recycled without destroying our environment, our home. Have we come to a crossroads in our handling of this planet, an ecosystem that we so dearly need for our survival? Isn’t water more important than any profit we can make from mining? Once understood that we cannot mine our water resources without devastating results, perhaps we will favor sane and ecologically sound solutions to those challenges that engage us?

We could speak of the beauty, the wild, the spirit of something greater than ourselves, the sustenance we all gain from these masterpieces. Such is the Arrowhead of Minnesota. What profit is there if not life itself? It is undeniable that people in the area need jobs … although, who of these long term residents came with the intent to mine this jewel? If given the opportunity to work in a sustainable activity, who would not choose to do so? What kind of opportunities could be created with a mindset that encourages positive long term results over short term gains and financial profiteering? Don’t we owe it to ourselves and life itself to make the effort?

Anita Suzanne Tillemans

originally published

January 31, 2014

Cook County, MN

Polymet Gets Crucial Permitting for the NorthMet Project and Copper Mining in the Arrowhead

On November 01, 2018, our DNR announced through Tom Landwehr, commissioner, approval of ten crucial permits that Polymet, a Swiss-based conglomerate, needs to start a copper mine in Arrowhead of Minnesota at the extreme headwaters of the St Lawrence Seaway.  This will open the door to an expanded footprint for the proposed NorthMet Project once begun, allowing for greater extraction of water resources from this water-dependent ecosystem, along with the taking of endangered species, Canada Lynx, Timber Wolf, birds and fowl, plant species etc that interfere with this project.

The permits granted on November first: six water appropriation permits, two dam safety permits, a public waters work permit and last (but not least) an endangered species takings permit. The project still needs water permits and air quality permits from the Minnesota Pollution Control Agency and a wetlands permit from the Army Corps of Engineers.

Other important points:

Since the project is now deemed less profitable as proposed, Polymet in all probability, will need to mine faster and expand the proposed footprint to make the money investors expect.  This means that the proposed mine, with its assured potential of 500 + years of pollution, approved by the DNR, will dwarf the damage of the mega-mine actually needed to fullfill its promise and its bottom line.  This will be in direct conflict to any environmentally sound promises.

To quote DNR commissioner, Tom Landwehr,  the NorthMet project “meets Minnesota’s regulatory standards for these permits.”  Wth such confidence as a foundation, and since our citizens are the ones who will suffer the consequences of a poor decision, being the ones who will more than likely “foot the bill,” why would the DNR under Landwehr reject the Minnesota Center for Environmental Advocacy’s request for a contested case hearing, an independent judicial review, a chance to prove that this decision could stand such scrutiny?  Why has it taken over 10 years to permit this mine?  Why do the majority of Minnesotans reject this proposal?

Funding clean water projects, and the like, without reducing point source pollution seems a poor way to protect our resources.  Is it a radical idea that the health of our freshwater trumps the profits of an international corporation?



Common Loon NE MN waters

State of Minnesota issues permits for PolyMet mine proposal

Link to Public Comment by Duluth for Clean Water concerning NorthMet Project

Risk Analysis of Probable Maximum Flood and Climate Change at the PolyMet Flotation Tailings Basin Prepared for Clean Water by Tom Myers, PhD, Hydrologic Consultant

NorthMet Copper Mine Proposal and Permitting Links

The NorthMet project, in order to mine copper in the Arrowhead of Minnesota, will need many permits to address the pollution and the degradation of these premier wetlands, waterways and the ecological treasure that is northern Minnesota.  To this end, there have been many studies showing how much the land will be changed by a copper mine and the necessity of amendments that may reduce the damage.

I have included a few helpful links below for those who would be interested in understanding the process and what stage we are at in this process below.


NorthMet Project’s Permit to Mine documents

Permits to address water quality standards to accommodate copper mining

Permits to address air quality standards to accommodate copper mining


401 Certification Documents to address wetland degradation

Other necessary permits for Polymet (to take endangered species, public waters work permits and sensitive plants surveys report, Dunka Road upgrade)

Water Appropriation Permit

Dam Safety Permit



Appreciation of beauty is a moral test. Will we pass when it comes to protecting the extreme headwaters of the St Lawrence Seaway and Hudson Bay in Minnesota?

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

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

Lafayette Road,

Box 25

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.

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

Mining Prospects in the Arrowhead

Links of interest:

Friends of the BWCA on sulfide mining

waterways and waterfalls of NE MN

State of the BWCAW



NFS and Polymet Land Exchange

Issues of copper mining various sources

Sierra Club on Twin Metals

Is there no better way to fund our schools?

School Trust Lands in BWCA, over 83,000 acres of state-owned land, have been kept from earning money due to the fact that the land is protected as wilderness.  According to the Associated Press in an article April 18, 2018, $4,000,000 from the government funding bill, recently passed in Congress, will allow officials to move forward with a 2012 plan to make lands available for use in a three way exchange.

In preparation for this resolution to the decades long dispute, The Conservation Fund has bought 8,000 acres of prime private forest lands in NE MN which will be used in the exchange for the school trust fund lands, lands which will then be owned by the U S Forest Service.

School Trust Land Exchange Scoping SUPERIOR NATIONAL FOREST March 2015

Since the U S Forest Service has just exchanged lands so that Polymet can mine next to the BWCAW as soon as the DNR permits, I wonder.  How will this work out for the BWCAW if/when copper mining reaches its tentacles into the area surrounding Babbitt particularly to the North and Northeast?  Can we expect the US Forest Service to stand down when mining interests request another trade?

Just a thought.

MINERAL CHARACTER DETERMINATION For Minnesota State School Trust Land Exchange – Case #4558 Nonfederal Land and Mineral Ownership Information

The question arises, as well, why is funding of our schools linked to exploitation of our lands and waters? Perhaps there is a better way.






Comment on NorthMet Draft Air Permit due March 16, 2018

The NorthMet Project has been in process of application for many years now, because the project will cause unusual problems, and because it will imperil wilderness lands, waters, air, wildlife and the economies that depend upon clean air, water and healthy ecosystems. Permitting a copper mine will set precedent and change the land use forever.
Since the copper deposits in Minnesota are of low grade, the process will naturally require removal of more rock than copper. By Polymet’s own estimate the NorthMet ore body comprises 275 million tons of Proven and Probable reserves grading 0.28 percent copper with Measured and Indicated Mineral Resources of 694 million tons grading 0.27 percent copper and 0.08 percent nickel. Since Polymet intends to mine and process 32,000 tons of ore per day (11,680,000 tons of ore per year) what does this mean for the air quality surrounding the Project?
According to the reports put forth for this permit, the NorthMet project will require ammonium nitrate and fuel oil for blasting every two to three days. Large excavator shovels with up to 30-cubic-yard-capacity and large front-end loaders will then load the ore into diesel-powered haul trucks, each having the capacity to carry 240 tons of material in a single load, all loaded onto 100-ton side dumping railcars. Sixteen-car trains pulled by locomotives will then transport the ore approximately six miles to the processing facility 20 times each day. In all, PolyMet plans to mine approximately 225 million tons of ore over a 20-year mine life. This plan can be revised at any time as long as notice is given and approved by our regulators. No mine has ever been shut down by regulators once begun in Minnesota.
According to the relevant reports, processing starts once the ore is transported to the LTV site where it will be offloaded into the Coarse Crusher Building. A series of crushers then reduce the ore to approximately 2.5 inches diameter feeding these particles by conveyor to the coarse ore bin located in the Fine Crusher Building. From the Fine Crusher Building, the ore will be conveyed to the Concentrator Building used since the 1950s to process taconite. There, the ore will be reduced into particles about the diameter of a human hair before being transported by chute to other buildings where impurities will be removed using chemicals and large quantities of water. Imagine this fine dust in transport.
As documented in this permit, this facility, then, will require a number of filtrations systems including HEPA, cartridge and fiber, all of which will be expected to comply with standards within each building and require their own handling. Outside of these buildings where there are no filters, fugitive emissions are even more difficult to control.
Fugitive source emissions from mining operations stem from the blasting of rock and the debris that these operations create, loading and unloading of rock, truck traffic, preparation, crushing and screening activities and excavating. Traffic, road building and repair will contribute naturally and this will exceed the boundaries of the NorthMet Project site where no truly effective organic and sustainable control is possible in most situations, physics the determining factor.
Fugitive sources of emissions at the processing plant can be found during construction activities, crushing and screening, along with wind erosion during flotation tailings basin operation, miscellaneous truck traffic, and SAG and ball mill grinding of the ore. The list of unusual problems and effects goes on in the permit reports, unintentionally illustrating why copper sulfide mining would be a major contributor to air pollution in this wilderness, and all the while presuming to make a case for protection.
How much of the regulation in place on spot filtration systems and their filters will be effective? How much of the fugitive emissions and noise will cause untenable situations for wilderness tourism, which is the backbone of this country? Only time will tell after all. If experience has taught us anything, these systems will fail or be neglected in time while the mining effects will continue into perpetuity.
Just a list of the vehicles required in this operation will tell us enough about the effects: 2300HP mine haul trucks run on 25.4 gallons of fuel/hour. 1550HP diesel drills, 19.8 gallons/hour, and 646HP truck dozer graders, 31.2 gallons/hr. And then there will be excavators, rubber tire dozers, transfer loaders, backhoes with hammers, water/sand trucks, and integrated handlers with their own fuel usage and emissions not to mention the noise that will be a daily experience for all within earshot.
Besides vehicles, there will be a great need for space heaters, too many to count for this comment, feed chutes, conveyors, mills, grinders, crushers, rail cars and locomotives, mix tanks and dewatering stations, a lube house, direct and indirect heating equipment using electric, natural gas and propane, degasifiers, a (huge) gasoline tank, bentonite (fine clay dust) handling, and miscellaneous buildings.
There will be a fence patrolled to keep the public out. Polymet will monitor itself. There is no restriction on hours of operation for portable crushing spread operations May to October and other operations are given the time needed to process almost 12,000,000 tons of ore each year. Much of the monitoring is not enforceable in this permit or on a practical level. So where are the real safeguards? The winds will blow, the climate will do its thing and Polymet will be forgiven in a force majeure situation.
We are told that this ore will be processed in an environmentally sound manner. We are told that if limits are exceeded, they will be remedied by the miner except in the case of unforeseeable circumstances that prevent them from fulfilling their contract. Will they monitor and police themselves without regard to profits? If fugitive emissions are found to degrade the environment outside of the parameters of their fence line, will this too be remedied? What will the meaning of going up North hold for citizens once this mine starts construction?
Wetlands abound along this copper deposit, with thousands of flora and fauna, many rare and uncommon all depending on clean air and water, in a wilderness of outstanding quality. There are orchard orioles, killdeer, snow geese, loons, woodcocks, purple finch, mink, great blue heron, broad-winged hawks, eagles, partridge, beaver, wolves, moose, bear, Canadian lynx, coyotes, blue bills, mallards, night hawks, snowy owls, white-throated sparrows, deer, blueberries, bearberry, rock ferns, caribou moss, and so many other species of plants and animals. What is the potential harm to these populations if the fragile balance of this ecosystem is destroyed, an ecosystem so interconnected with the health of its waters and its air?
Do we sell or do we protect? This is what this decision concerning the NorthMet Project comes down to, essentially. There are no guarantees that Polymet or theirs will be around to pay for the damage that acid rain and other hazards of mining for decades in this area will cause. They are a corporation, after all, developed to limit liability. Ongoing treatment, passive or aggressive, will never return this region to its original state. Observe ongoing pollution witnessed from mining in the area already. What financial or political assurances would suffice in a tragedy of the scale that sulfide mining would unleash?
We have waste on this earth that could be recycled without destroying our environment, our home. Have we come to a crossroads in our handling of this planet, an ecosystem that we so dearly need for our survival? Isn’t this priceless wilderness more important than any profit we can make from mining? Once understood that we cannot mine in this area without devastating results, perhaps we will favor sane and ecologically sound solutions to those challenges that engage us?
We could speak of the beauty, the wild, the spirit of something greater than ourselves, the sustenance we all gain from these masterpieces. Such is the Arrowhead of Minnesota. What profit is there if not life itself? It is undeniable that people in the area need jobs … although, who of these long term residents came with the intent to mine this jewel? If given the opportunity to work in a sustainable activity, who would not choose to do so? What kind of opportunities could be created with a mindset that encourages positive long term results over short term gains and financial profiteering? Don’t we owe it to ourselves and life itself to make the effort?
For the reasons outlined in this comment, I request that the Draft Air Permit for the NorthMet Project be denied.

PolyMet draft 401 Certification comments due March 16, 2018

The headwaters of the St Louis watershed detailed for this certification are designated Outstanding Resource Value Waters (ORVWs).  Lake Superior downstream is a restricted Outstanding International Resource Water (OIRW).  As such, changes in water quality are regulated and, according to EPA Region 8 guidance in temporary situations, water quality should return to levels prior to the activity that caused the degradation.  How should a long term project in these waters require any less?

The potential of accurately being able to determine the extent, degree and location of wetlands impacted from drawdown from this Project prior to construction are very low.  Even after the project is authorized and the mine built, these impacts will have to be determined through various types of monitoring during several growing seasons.  The impacts could vary from small changes to complete loss of wetland hydrology. In other words, complete loss of wetland(s).

The knowns are that this copper sulfide mine will result in direct and indirect impacts to 127 wetlands covering approximately 939 acres; and that it may also cause indirect wetland impacts due to potential change in wetland watershed areas, stream flow, groundwater drawdown, wetland fragmentation, or wetland water quality related to dust or rail car spillages.  The NorthMet project, then, has the potential of indirectly impacting more than the 7,350 acres of wetlands predicted.

Temporary activities in ORVWs do not have provisions in Minnesota Rule 7050.0180 placed upon them; but there are still expectations.  Temporary activities should not lower water quality to the extent that existing uses are degraded or removed.  These activities should not result in more than a 5 percent change in ambient concentrations of pollutants or result in a significant long-term increase in the frequency and duration of bacteriological pollution.  Long term water quality and wetland degradation of the kind that the NorthMet Project proposes should require, at minimum, these expectations.

Would NorthMet create no truly unusual problems?  The project itself is unusual; and this certification has not addressed the effects of introducing Acidithiobacillus ferrooxidans, a bacteria that thrives in a sulfide rich mining environment, a bacteria that copper mining relies upon to break down the copper, creating sulfuric acid and eventually introducing bio-available mercury downstream and into the wetlands.

The hazards cannot be overstated and have not been fully addressed in this permitting process.  I therefore, ask that this 401 certification not be granted to Polymet for the proposed NorthMet copper sulfide mine.

Comment on Polymet’s Permit to Mine in NE MN


Witch Tree in NE MN on Lake Superior

Creative expression is an essential ingredient in all of our lives and it stems from a love of beauty in all its forms.  Without this where are we? Is artistic expression something we do when other “more important” things are accomplished? Or is it, like the song of a sparrow, the rush of a spring, essential to our survival?


Sigurd Olson remarked that everyone needs to find their “spot of blue”.  Over the years, his reference developed from a “spot of blue” in his search for water on a portage in northeastern Minnesota in the BWCAW and in the Quetico of Ontario, the sense of adventure and discovery on that quest, to a metaphor encompassing a search for knowledge and spiritual meaning.


Humans have evolved into super predators through the use of tools and weapons.  Once our dominance over the animal and plant kingdoms was assured we turned these weapons on ourselves.  As a consequence, it becomes even more essential that we find our “spot of blue” and a place where we can meditate on our existence and the paths each one of us needs to take for the sake of our species and life on earth.


When there is no wilderness, places where we can find solitude, no respite from the drum of so-called progress, nothing but the steady beat of production at all costs and money our god, what then?  Where will we find the space and the time to appreciate the beauty and find our spot of blue?  Our survival as a human species may depend upon it.


I respectfully request that Polymet’s Permit to Mine in NE Minnesota at the headwaters of the St Louis River watershed be denied.


Anita S Dedman-Tillemans