Polymet Scoping Decision Comments

July 6, 2005

                                                                                                           
DATE: July 6, 2005
   
TO: Randall Doneen, Principal Planner,
  Minnesota Department of Natural Resources
  Jon Ahlness, Corps of Engineers
   
FROM: Clyde Hanson, Co-Chair
  Mining Without Harm Campaign
  Sierra Club North Star Chapter
  4038 Cascade Beach Road
  Lutsen, MN 55612
  (218) 387-9081
  .(JavaScript must be enabled to view this email address)
   
Formats: Email MS Word attachment and mailed hardcopy
   
RE: NorthMet Sulfide Mine and Ore Processing Facilities Project
  Sierra Club Comments on Draft Scoping Decision Document and Scoping EAW



These are the official comments of the Sierra Club, which has 20,000 of your friends and neighbors from all walks of life as members and volunteers in Minnesota and 750,000 nationwide.  Our mission is to explore, enjoy and protect the planet.  Dangerous types of mining and mineral processing new to Minnesota are proposed in the Superior National Forest south of Ely.  They’ll spew acid, toxic metals and mercury into our clean air and waters.  Thousands of acres of wetlands vital to fishing, hunting, Duluth’s water supply and Lake Superior fisheries would be at risk.  Decisions affecting our communities will be made by foreign companies.  After the mines play out, the perpetual costs of treating polluted waters and tending toxic wastes could fall on taxpayers because, sulfide mines are “reactive” or acid producing for thousands of years.  Arrowhead citizens are working together to protect the people at risk of pollution-caused sickness and our wild heritage by asking the government and companies for Mining Without Harm.  These comments are one step in our campaign.

Draft Scoping Decision Document Comments

The scope and depth of the environmental impact statement (EIS) for this proposed sulfide mine is critical to informed public debate and decision-making.  Our comments are noted in red and sections of the draft scoping decision document are included below to provide context for our comments. Please call or email with any questions on interpretation or fact. Your close attention to our comments is appreciated. 

1.0 INTRODUCTION AND PURPOSE

1.1 BACKGROUND

The proposed project includes open pit mining operations with ore hauled to the processing facility on a largely existing rail line. Ore would be processed at a refurbished and modified taconite processing facility formerly known as the LTV Steel Mining Company plant. The hydrometallurgical process of flotation and autoclave leach facilities would be used with refurbished crushing and grinding facilities to produce copper metal and precipitates of nickel, cobalt, palladium, platinum, and gold. Precipitates are proposed for shipment off-site to third party treatment. The flotation process will generate flotation tailings that are proposed for disposal on top of a portion of an existing taconite tailings disposal facility. The hydrometallurgical process would generate some waste residue (quantify volume and chemistry) that is proposed for disposal in lined cells on top of the existing taconite tailings adjacent to the area proposed for disposal of flotation tailings. (Describe the hazards of the existing taconite tailings and how this new project would change the risks and environmental consequences)

1.2 SELECTION OF APPROPRIATE ENVIRONMENTAL REVIEW DOCUMENT

The DNR will engage the services of a consultant to assist in EIS preparation, however the DNR will retain responsibility for EIS content (please specify how will DNR assure the impartiality of the consultant when they are funded by the project proposer and DNR gets funding from mineral leases?).

The USACE is serving as co-lead agency in preparation of the EIS with the DNR. Although the mine site for the NorthMet project is located on USFS land, there is an existing mineral lease for the deposit. The USFS has determined that they do not have a federal action if the NorthMet project is developed in compliance with the existing conditions of the lease. (Document this decision in the EIS. Significant rare forest resources will be impacted directly as will the BWCAW, so the USFS lands, including those off the mine and plant site, would be impacts).  The USFS is serving as cooperating agency in the EIS preparation with the USACE and DNR.

1.3 PURPOSE AND NEED OF THE PROJECT

PolyMet anticipates that optimized mining and processing operations would involve extracting and processing 32,000 tons of NorthMet ore each day.  All mining activities must be conducted and sequenced as efficiently and cost-effectively as possible.  In this way, the production of copper and other metals can remain competitive, not only within the United States, but also in the worldwide metals market.  (Economic considerations must not be part of the purpose and need.  These criteria would bias the EIS and preclude consideration of many project alternatives.  This statement would make profitability maximization a rationale for not addressing environmental impacts.  The purpose and need must be revised to focus on the public purpose and need, not the project proposer’s purpose and needs.  The public need is to achieve the functions of the mined metals that create quality of life, not to build a hoard of metals)

PolyMet would strive to operate the NorthMet project in a manner that is efficient and cost-effective, and that minimizes impacts to the environment (define “strive” and “minimize” as these are weasel words that sound good but mean nothing “on the ground”).  The mining activities would also result in between 490 and 600 long-term jobs (Document these estimates in the EIS.  Will the company guarantee that these jobs will be created if the project is permitted? If the jobs are not created, will the permits be declared void? These are higher estimates than the proposer presented at the public meeting.  The EIS needs to document where the labor force will be from and whether it will be unionized or not.  The proposal to share maintanence facilities with North Shore Mining and the companies’ prospectus to potential investors that states that a “contract miner” will be used are evidence that this relationship is likely) in the Babbitt and Hoyt Lakes area, in addition to several hundred jobs during the one-year construction phase.

1.4 THE SCOPING PROCESS

Public review and comment on the Draft Scoping Decision Document will be conducted as prescribed MEQB rules part 4410.2100. (And meet NEPA law, rule and case law standards for an EIS.  Please document these in the final scoping decision.) After public review and comment the DNR and USACE will consider the comments received and develop a Final Scoping Decision Document. A notice of availability will be published in the EQB monitor for this document. (Is there an appeal process for scoping decisions? Federal?  State?  We suggest getting feedback from stakeholders before finalizing the scoping decision document to minimize conflicts later in the process.)

2.0 PROJECT ALTERNATIVES

The MEQB rules require that an EIS include at least one alternative of each of the following types, or provide an explanation of why no alternative is included in the EIS (Guide to Minnesota Environmental Review Rules, page 12):  alternative sites, alternative technologies, modified designs or layouts, modified scale or magnitude, and alternatives incorporating reasonable mitigation measures identified through comm

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