St. Paul, Tuesday January 28
PolyMet and the BWCA Revisited
PolyMet is seeking a permit to discharge mining runoff into a wetland called the One Hundred Mile Swamp. According to the Clean Water Act Section 404, the U.S. Army Corps of Engineers can permit discharge into and destruction of wetlands by accepting land exchange as compensation. It is not contested whether the One Hundred Mile Swamp will be impacted by PolyMet’s proposed mine. However, it has been assumed that the One Hundred Mile Swamp is isolated from and does not affect the BWCA.
Wetland Mapping in the SDEIS is Contradictory to US Government Maps
Shortly before release, a line was added to the Wetlands section of the environmental impact statement in Section 4.3.3 (Wetlands) “however, no delineated boundary exists for the One Hundred Mile Swamp.” This statement is in fact completely incorrect. Delineated boundaries for the One Hundred Mile Swamp do exist and they appear in the US Government National Atlas at www.nationalatlas.gov/streamer. The US Government National Atlas shows that the One Hundred Mile Swamp is drained by Langley Creek which is a tributary to the Dunka River which is in turn a tributary to the Kawishiwi River which flows straight to the Boundary Waters.
It is an inconvenient fact that mine waste indeed appears to be headed to the BWCA by way of the One Hundred Mile Swamp, Langley Creek and the Dunka River. There has been no hydraulic conductivity testing in the One Hundred Mile Swamp that alleviates concern about flow through the wetland and into the BWCA watershed. Rather, data from the SDEIS indicates that ground water contours descend in the direction of Langley Creek and the range of lateral hydraulic conductivity data presented in the SDEIS indicates that mine waste may traverse the One Hundred Mile Swamp to Langley Creek in as little as 64 days.
Instead of actually determining the downstream flow of mine drainage, the SDEIS added the misleading statement about delineation of the One Hundred Mile Swamp, and worse, simply drew maps with a much smaller swamp area that omits the half that drains to Langley Creek. The first incorrect map appears as Figure 4.2.3-1 of the SDEIS (page 472 of the full SDEIS as downloaded as pdf) and there are at least five others.
Absence of Water Testing Leaves the BWCA and Quetico Completely Unprotected
On the basis of the re-drawn maps, attention has been diverted from the Boundary Waters. No baseline water testing was done in Langley Creek, the Dunka River or anywhere else in the BWCA watershed nor would any water testing be done if mining were allowed. This leaves the Dunka River and the BWCA completely and utterly unprotected.
Contrary to popular belief, the PolyMet SDEIS makes no explicit statement about drainage from the mine site to the BWCA watershed. What the executive summary does say is that the mine site drains to the Partridge River which is not located within the Hudson Bay Watershed and does not flow to the BWCA. While this statement is in fact correct, most readers of the SDEIS incorrectly extrapolate this to mean that mine waste will not flow to the BWCA. The punch line is that the mine site drains not only to the Partridge River but also to Langley Creek via the One Hundred Mile Swamp. And Langley Creek does flow to the BWCA.
Boundary Waters Should be Protected from Upstream Pollution with a Federal Level Environmental Impact Assessment
The Boundary Waters are a national treasure and should have a federal level environmental impact evaluation. Local and state officials are under economic pressure to permit the mine. In the interest of appeasing PolyMet owner Glencore Xtrata by lowering the barrier to entry such as not requiring financial assurance, state officials will also diminish the number of jobs required to operate the mine by allowing lessened environmental monitoring and protection. Not only does light weighting environmental monitoring diminish valuable skilled jobs, it violates the public trust of American citizens and future generations.
Request a Longer Public Review Period and a Corrected SDEIS
At a minimum, a longer public review period of 180 days for the current SDEIS is required. It is not possible for the public to read and comprehend a technical document of over 2000 pages in just 90 days. The longer public review period will allow adequate oversight of the environmental impact statement and mining plan. Subsequently, deficiencies and inaccuracies in the SDEIS can be corrected by additions and modifications to it. Click here for information on how to request a longer review period before Thursday March 13, 2014.
Request That Critical Financial Information be Added to the SDEIS
Besides technical information, an important addendum to the SDEIS is a section on the reclamation bonding that is required to provide funding for protecting the environment after the mine is closed. Given the enormous cost of post mining maintenance, Glencore’s excessively poor reputation, and the capital structure of PolyMet, it is absolutely unreasonable for the Minnesota Department of Natural Resources and Governor Dayton to not allow public oversight on financial assurance for post mining reclamation and remediation. An entire section devoted to reclamation bonding is required. Click here for information on how to request financial assurance information be added to the SDEIS before Thursday March 13, 2014.
The SDEIS Requires an Explicit Statement About Mine Waste and the BWCA
It is a critical feature of the mine whether or not the BWCA is impacted and the SDEIS therefore requires an explicit statement that mine waste either is or is not capable to percolate to the BWCA. It can’t legitimately be stated that mine waste will not enter the BWCA watershed without data, and that data is required to be presented in the SDEIS for public examination. Incorrect maps and misleading statements do not constitute meaningful evidence.