Summary of Public Comment: Superior NF Federal Hardrock Mineral Prospecting Permits DEIS 11/17/2011 Preliminary Draft 1 Summary of Public Comment: Superior NF Federal Hardrock Mineral Prospecting Permits DEIS This document contains a summary of public comment on the Superior NF Federal Hardrock Mineral Prospecting Permits Draft EIS. It includes Public Concern statements that summarize an issue brought up by the public, and quotes from comments that identify this issue. This document is not a part of the Final EIS. It is a draft copy posted on the Superior NF website in response to a request to review public comment on the project. The final document displaying comments and Forest Service responses will be available when the Final EIS is made available.
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Microsoft Word - Draft Public Concern Summary Prospecting Permits
EIS.docxSummary of Public Comment: Superior NF Federal Hardrock
Mineral Prospecting Permits DEIS 11/17/2011
Preliminary Draft 1
Summary of Public Comment: Superior NF Federal Hardrock Mineral
Prospecting Permits DEIS
This document contains a summary of public comment on the Superior
NF Federal Hardrock Mineral Prospecting Permits Draft EIS. It
includes Public Concern statements that summarize an issue brought
up by the public, and quotes from comments that identify this
issue.
This document is not a part of the Final EIS. It is a draft copy
posted on the Superior NF website in response to a request to
review public comment on the project. The final document displaying
comments and Forest Service responses will be available when the
Final EIS is made available.
Summary of Public Comment: Superior NF Federal Hardrock Mineral
Prospecting Permits DEIS 11/17/2011
2 Preliminary Draft
Subject: Special Areas - BWCAW Category: 2500
Public Concern 93 The Forest Service should consider that mineral
exploration activities in and adjacent to the BWCAW are
inappropriate and should not be allowed because:
A) It will degrade the wilderness character and destroy solitude as
required by the Wilderness Act;
B) It would affect tourism; C) Temporary road will increase the
potential for illegal motorized intrusion; D) It is vulnerable to
run-off problems; E) It is inconsistent with Forest Service policy,
goals, and mandates; and F) Cumulative effects for all past,
present, and foreseeable activities for mining,
exploration activities, and large land altering projects (land
exchanges, timber sales, etc.) on federal, state, and privately
owned lands have not been considered.
Sample Public Comment(s) for PC 93:
Subconcern # A
I am not against mining - but I do not think this location (far too
close to the BWCAW) is right for this type of mining. The BWCAW
represents a unique paddle-only roadless area too special to
potentially put in harm’s way. (Ltr# 10, Cmt# 2)
Subconcern # A
I am writing to comment on the exploratory mining DEIS for the area
south of the BWCA near MN Highway 1. I was volunteering cleaning
campsites (I do this every spring on behalf of the Friends of the
Boundary Waters and Northeastern Minnesotans for Wilderness for the
Forest Service) from the evening of May 6 through the morning of
May 8. This year I went in at Entry Point #32 on the South
Kawishiwi River and maintained sites on the South Kawishiwi,
Eskwagama Lake, Clear Lake, and Bruin Lake. When I drove along
Spruce Road to the put-in, I noticed a drill site just off the road
fairly close to Highway 1 where a vehicle was parked. When I drove
out on Sunday, a different vehicle was parked there. The weather
was relatively calm Saturday and Sunday. When I was south of
campsite #6 on the South Kawishiwi River (including when I was on
Bruin Lake) I could clearly hear the steady drone of what I
presumed to be drilling equipment coming from the southwest. This
would be the direction of the previously mentioned drill site. It
would have been coming from about 5 miles away. I found the noise
very disturbing in the wilderness. This was a single drilling
operation, and from the DEIS I gather 1920 exploratory sites are
planned over 20 years. My ears are not any better than average, so
I'm sure I wouldn't be the only one bothered by this activity,
especially when it is multiplied by many sites being explored
simultaneously. The thought of hearing this kind of noise going on
in the wilderness (especially at night) gives one pause, and I
think the Forest Service should reconsider its analysis in the DEIS
when it comes to noise pollution. If I had not been on a mission
cleaning campsites this weekend I would have moved out of the area
and stayed out. Noise like this degrades the character of the
wilderness and destroys the solitude I seek in the BWCA. (Ltr# 11,
Cmt# 1)
Subconcern # A
I am very concerned about the proposal to develop sulfide mining
near BWCAW. I know jobs and commerce are important for the
immediate future but so are natural resources like the Boundary
Waters. Please leave us something for the next generation! I have
read through the proposal and I am not convinced that this project
can be developed without impacting the natural park in that area.
(Ltr# 15, Cmt# 1)
Subconcern # A
I've been canoeing and camping in what is now the BWCAW since the
early 1950s, when I went with my parents. They had gone years
before with my grandparents, and I always loved that we were able
to experience the lake country essentially unchanged since they
were there. The lack of civilization noise is one thing special
about the
Summary of Public Comment: Superior NF Federal Hardrock Mineral
Prospecting Permits DEIS 11/17/2011
Preliminary Draft 3
wilderness area - it's a no fly zone. It should also remain a
no-heavy equipment noise zone. Please preserve this area as close
to wilderness as possible. (Ltr# 19, Cmt# 1)
Subconcern # A
I have taken canoe camping trips to the BWCAW annually since 1966.
It is always a magical experience. Just being there is like being
with a master psychologist. It always clears the mind just to be in
the presence of such a place! It is a unique place. . .nothing else
like it. . .drinkable water from the lakes and streams. . .no
mechanized noise, just the sounds of nature!! My concern with the
proposed project is that there will be infringement upon those
qualities that make the BWCAW so special. We cannot allow short
term financial gain to ruin this area for future generations that
will need this master psychologist even more than I/we do!! (Ltr#
27, Cmt# 1)
Subconcern # A
The proposal is a step-in-the-door for dangerous sulfide mining.
Mineral exploration and development activities are not appropriate
activities for this area due to the proximity with BWCAW which has
a focus of ecological preservation and recreation. (Ltr# 29, Cmt#
1)
Subconcern # A
Hardrock fails to protect the Boundary Waters Canoe Area Wilderness
(“BWCAW”). My special concern is the BWCAW. USFS is required by the
Wilderness Act to provide “outstanding opportunities for solitude
or a primitive and unconfined recreation.” This requirement was
upheld by the court in the 2007 S. Fowl Snowmobile Trail case, and
applied to agency actions outside the BWCAW as they have impacts
within the BWCAW. (Ltr# 32, Cmt# 2)
Subconcern # A
We do a poor job of mining our trash and garbage for the valuables
contained therein. Stories about recycling often reveal that some
of those efforts are wasted by landfilling. What would make anyone
think that we should mine for metals in areas near the BWCAW? Keep
the mining companies far away from our wilderness areas. (Ltr# 33,
Cmt#
1)
Subconcern # A
The proposed plan for more copper-nickel mining exploration at the
edge of the Boundary Waters Canoe Area Wilderness is a terrible
idea. I urge you to do everything in your power to kick it to the
curb. The BWCAW is one of our state's (and nation's) last pristine
wild areas. The thought of allowing something that even has a
remote possibility of harming it and/or it's wild inhabitants is
not good stewardship. Water pollution/air pollution/noise
pollution...it doesn't get much worse than that. I know it's just
"exploration" at this point, but there would be no reason to
"explore" if the ultimate goal wasn't to move forward with mining.
Please do your part to keep this treasured area safe. (Ltr# 47,
Cmt# 1)
Subconcern # A
The proposal to mine near the Boundary Waters appears reckless and
dangerous. Today's world desperately needs a place of clean water,
beautiful scenery and peaceful quiet. Please, please do not
desecrate this beautiful area of wildlife, one of the few remaining
in this country. (Ltr# 50, Cmt# 1)
Subconcern # A
Only in the few places like BWCA can we find perspective on life
and explore values lying deeper than those motivating this
rapacious commercial/industrial and increasingly inhumane world.
Our very soul depends on drawing a line here. The Forest Service
unquestionably has the authority to reject this project and protect
the incomparable values of the BWCA. There are plenty of reasons to
do so that will more than satisfy any legal requirements
enforceable by a reviewing Court. (Ltr# 58, Cmt# 1)
Subconcern # A
This is not the Appropriate Place. I've been known to say that "God
isn't making anymore wilderness." Why on earth are we trying to do
mineral exploration, which could of course lead to mineral
development, right next door to the BWCAW. We run the risk of
polluting waters that would be very difficult to reclaim, and for
which many people rely on for recreation, including many tourism
dollars for State businesses. In addition, mineral exploration and
development in this area will create noise from drilling and large
equipment that will be heard in the Wilderness. This is not what
wilderness users expect when visiting the BWCAW, and the Forest
Service should protect this important resource. (Ltr# 69, Cmt#
1)
Subconcern # A
Summary of Public Comment: Superior NF Federal Hardrock Mineral
Prospecting Permits DEIS 11/17/2011
4 Preliminary Draft
Most significant of all is for us to appreciate the value of a
scarce ecosystem. Wilderness areas are continually decreasing in
size and quality throughout the world, no less here than in the
“developing” world. In an increasingly degraded and crowded world,
must we not preserve the inherent value of these scarce
environments, both for their own sake and for the health of the
planet? Not only do they provide innumerable “ecosystem services”
to us (and other species), but they provide unexcelled recreation
and enjoyment for many and other non-quantifiable benefits. The
BWCAW and its surrounding forests are invaluable to our planet, but
the BWCAW cannot survive as an isolated “island” amidst ceaseless
exploration and exploitation. Its loss will accrue to us all; as we
will have sacrificed an irreplaceable resource for short-term
economic “gain” of others. (Ltr# 70, Cmt# 4)
Subconcern # A
It would truly be a shame to see something as great as the BWCAW
ruined by short-term mining prospects. The true goal of the
national park system should be maintained. I wanted to quickly
voice my opinion, as someone who uses this wonderful park, in
opposition of the current drilling prospects. Please keep the
following in mind in an effort to weigh any potential economic
gains that may come from such drilling. In 1969 the IUCN
(International Union for the Conservation of Nature and Natural
Resources) declared a national park to be a relatively large area
with particular defining characteristics.[4] A national park was
deemed to be a place with one or several ecosystems not materially
altered by human exploitation and occupation, where plant and
animal species, geomorphological sites and habitats are of special
scientific, educative and recreative interest or which contain a
natural landscape of great beauty, the highest competent authority
of the country has taken steps to prevent or eliminate as soon as
possible exploitation or occupation in the whole area and to
enforce effectively the respect of ecological, geomorphological or
aesthetic features which have led to its establishment, visitors
are allowed to enter, under special conditions, for inspirational,
educative, cultural and recreative purposes. (Ltr# 83, Cmt#
1)
Subconcern # A
it's not appropriate to conduct mining exploration within a few
miles of designated wilderness. This activity has the potential to
cause serious acid and dissolved metal water pollution. --noise
intrusion into the BWCAW is acknowledged and is counter to
wilderness standards. It is destructive to the experience of many
of the 250000 annual visitors. (Ltr# 85, Cmt# 1)
Subconcern # A
It is crucial to keep the BWCAW a wild and pristine place. Building
roads and allowing mineral exploration diminishes the wilderness,
and peoples' enjoyment of it. This is in direct violation of the
Wilderness Act. We need further information regarding limits on
density per acre of drilling, where will construction of roads,
drill pads, and landings be. What about water withdrawals - and
impacts to the Wilderness from this activity? Are there seasonal
limits and sound level limits in proximity to the BWCAW? (Ltr# 94,
Cmt# 8)
Subconcern # A
The Hardrock Minerals Prospecting Permits Project fails to protect
the Boundary Waters Canoe Area Wilderness (BWCAW). The BWCAW is
identified by the Forest Plan as “Semi-primitive Non-motorized
Wilderness.” The USFS is required by the 1964 Wilderness Act to
provide “outstanding opportunities for solitude or a primitive and
unconfined recreation.” This requirement was upheld by the court in
the 2007 S. Fowl Snowmobile Trail case, and applied to agency
actions outside the BWCAW as they have impacts within the BWCAW.
The Hardrock Project fails to address noise impacts adequately,
especially in the BWCAW. Substantial noise impact from sources
outside the BWCAW, but under the authority of a federal agency, is
impermissible under the Wilderness Act. In S. Fowl, the Court noted
that, “agency activity that results in noise that is louder, more
constant, more frequent, or of a different quality is more likely
to degrade the wilderness character from its present condition and
thus violate…” (The Wilderness Act).Each winter brings more and
more visitors to the BWCA that come to enjoy the amazing thrill of
winter camping, along with dog sledding, snowshoeing, and skiing.
This is true also of year round residents, like us, who enjoy these
Wilderness activities. What then of the constant drilling noise we
will be subjected to? Our expectations and the expectations of the
area visitors are one of total solitude and quiet in a primitive
area. Where is the “outstanding opportunity for solitude”?Noise
analysis in Hardrock is deficient in part because instead of
promoting “outstanding opportunities,” which would address worst
case scenarios especially, Hardrock instead relies on
generalizations, primarily based on distance from the sound source.
In order to evaluate the potential impact that Hardrock could have
on any given visitor's wilderness experience, USFS should consider
the loudest- case scenario. This would assist in an assessment of
the maximum impact noise would have on the BWCAW from each of the
proposed actions. A worst-case analysis is compelled by the
Wilderness Act's emphasis on outstanding opportunities for
solitude.The DEIS provides no qualitative or quantitative
assessment which differentiates between the natural soundscape and
man-made sounds. Natural sounds, regardless of their decibel level,
are acceptable and
Summary of Public Comment: Superior NF Federal Hardrock Mineral
Prospecting Permits DEIS 11/17/2011
Preliminary Draft 5
welcome features of the wilderness; even low-level man-made sounds
can degrade wilderness character. By the logic of the Wilderness
Act, ambient level human sounds (DEIS, p.67) are noise that need to
be defined as such. The Forest Service should not permit mineral
exploration if it results in new auditory noise pollution in the
Wilderness with the potential for a full-scale mine with ever
greater noise pollution looming. Exploratory drilling should be
prohibited now. (Ltr# 97, Cmt# 27)
Subconcern # A
The DEIS fails to adequately protect the BWCAW from impacts of
exploration and mining. (Ltr# 98, Cmt# 2)
Subconcern # A
Location – This, the Boundary Waters Wilderness, is the largest,
most desirable wilderness area in our country, visited by thousands
of U.S. citizens as well as international visitors each year. They
come here to experience creation at its best: Clear, refreshing air
to breathe. Skies, viewing countless stars and Northern Lights.
Clear, cool waters to drink and be refreshed. Noise, absent –
wonderful, acceptable silence. Natural local trees and fauna.
Wildlife, living and seen in their natural environment. Fish, the
sport of fishing and fish safely eaten. Recreation – The above
mentioned gifts are available to all who come to this area annually
or for the first time “to get away from it all” and enjoy an
unforgettable vacation. Our family, parents, children and now
grandchildren have been campers and canoeists here since 1951. In
early 1980’s we built a cabin in the north woods to be closer to
the land and experiences we love. Environmental impacts if the
above not protected: Polluted air. Skies obstructed by cranes and
other machinery. Water (ground) tainted orange by copper leaching.
Water (well) requiring testing annually for unwanted minerals.
Noise –Drilling continually 24 hours a day. Destruction of trees
and forests to make new roads. Absence of wildlife due to noise and
destruction of habitat. Fishing –deleted because of polluted
waters. (Ltr# 102,
Cmt# 1)
Subconcern # A
I love the BWCAW and visit at least once a year with my family. I
have introduced many others from all over the state of MN and from
out of state to the BWCAW. I always support local businesses -
hotels, outfitters, restaurants - when I visit. It is a very
special, unique place and I have serious problems with sulfide
mining near by. I have serious problems with the EIS. I have
serious problems with the ways that mining companies in MN have
behaved in the past and do not trust them to do what is right in
the future. I have been unhappy with how opportunities for public
input on this issue have been handled. Do not ruin such an
important area for recreation, nature, wildlife. Do not taint it
with noise and other pollution. (Ltr# 105, Cmt# 1)
Subconcern # A
Some of the proposed exploration borders the BWCAW. Since these
metals would not be used for strategic national interests—in fact
the metals would be exported to our international competitors—any
exploration adjacent to the BWCAW (Ltr# 111, Cmt# 21)
Subconcern # A
Not the Appropriate Place - The Forest Service should select
Alternative 1 – the No Action Alternative – for this project.
Mineral exploration will lead to mineral development – which has
the real risk of polluting waters that people rely on for
recreation – and are waters that flow into the Wilderness. Mineral
exploration and development in this area will create noise from
drilling and large equipment that will be heard in the Wilderness.
This is not what wilderness users expect when visiting the BWCAW,
and the Forest Service should protect this important resource. The
Boundary Waters Canoe Area Wilderness is the nation’s most popular
wilderness area, with over 250,000 visitors coming from all over
the nation and world. Establishing a mining district in the heart
of this recreation area is not a wise decision. (Ltr# 116, Cmt#
1)
Subconcern # A
It is crucial to keep the BWCAW a wild and pristine place. Building
roads and allowing mineral exploration diminishes the wilderness,
and peoples' enjoyment of it. (Ltr# 117, Cmt# 3)
Subconcern # A
Now is the time to step up and save our million acre wilderness the
pride and joy BWCA. There is no other place like it on the planet.
Please keep it that way. (Ltr# 121, Cmt# 6)
Subconcern # A
I believe it is ok to do prospecting for minerals on the SNF. It
just should not be done in historical site/Indian mounds or the
BWCA. (Ltr# 184, Cmt# 1)
Summary of Public Comment: Superior NF Federal Hardrock Mineral
Prospecting Permits DEIS 11/17/2011
6 Preliminary Draft
Subconcern # A
I am extremely opposed to issuing permits to allow hardrock mining
companies from doing exploratory drilling or any permanent drilling
in the Superior National Forest for the following reasons: It is
crucial to keep the Boundary Waters Wilderness Area a wild and
pristine place. Building roads and allowing mineral exploration
diminishes the wilderness and everyone’s enjoyment of it. (Ltr#
244, Cmt# 2)
Subconcern # A
It is crucial to keep the BWCAW a wild and pristine place. Building
roads and allowing mineral exploration diminishes the wilderness,
and peoples' enjoyment of it. (Ltr# 246, Cmt# 3)
Subconcern # A
The Superior National Forest and BWCA are national treasures. There
are very few places left in the lower 48 that offer the type of
habitat, beauty, and ecology that the Superior National Forest
offers. There is no place in the lower 48 that offers what the BWCA
does. Surely, these places are worthy of comprehensive protection.
I believe it to be in the long term financial interest of the area
to preserve these places. These areas are forever profitable as
tourist draws. As a source of minerals they are "profitable" one
time only. Finally, it is important to note that the BWCA is
exceedingly unique and exceedingly vulnerable. People come to the
BWCA from around the county to find a true wilderness experience.
This true wilderness experience is becoming too rare. It only takes
the whirl of one helicopter in the distance, or one polluted
stream, to take away that amazing final element that makes for a
true wilderness experience. I feel it very important that we
preserve such places and experiences for our citizens. It is part
of what we owe the future and part of our national history as well.
(Ltr# 281, Cmt# 1)
Subconcern # A
The BWCAW experience is supposed to be removed from the sound,
sights, and effects of industry. Mining in the Superior National
Forest will violate this peaceful experience. Please do not let
this permit be approved. (Ltr# 285,
Cmt# 1)
Subconcern # A
Mining exploration and operations will make wide areas unable to
meet the standards set by the Forest Plan for management areas such
as non-motorized, semi-primitive, wild and scenic river candidates,
and the Boundary Waters. None of these areas should be within
earshot of mining operations, as this noise would compromise their
character. (Ltr# 287, Cmt# 2)
Subconcern # AB
Any potential risks of noise, water, air, and non-native-plant
(spread through temporary and permanent access roads) pollution
becomes magnified by proximity to the BWCAW as the effect of the
pollution is greater, due to the contrast to the relatively
pristine environment in the BWCAW. Also, mining right outside of
the BWCAW harms the public perception of the area with possible
impact to the tourist trade. Any pollution would have lasting
impact beyond the spot polluted and the mere presence of it has
negative impact just from it's existence. Proximity to the BWCAW
should always be a weighted factor in permit analysis in the
future. (Ltr# 9, Cmt# 1)
Subconcern # AB
How will drilling noise and mining operations affect the integrity
of the BWCAW? I guess that also goes for all the other
water/fish/wildlife/ecosystem aspects that mostly likely will be
negatively impacted to some degree by sulfide mining in that area
should it occur. The BWCAW is a fragile, unique, legally protected
gem of NE MN. It also supports numerous businesses and brings major
tourism dollars to the region. Sulfide mining could have a very
detrimental impact on that resource, which would adversely affect
many businesses and tourism $$. (Ltr# 16, Cmt#
4)
Subconcern # AB
The Boundary Waters are a unique and precious area. I have spent
the summer there every year since I was born, 19 years ago. I
cannot imagine life without it. Furthermore, in my years there I
have become aware of just how rich and important the ecosystem(s)
there are. I cannot believe that this mining operation can outweigh
the value of the wilderness both to the many sensitive species that
live there, but also to the millions of people who either live in
or come to visit the boundary waters each year. Any EIS's that act
as though mining would not have a huge, wide- reaching and damaging
impact cannot be trusted--I can tell from personal observation.
Also, if all you care about is the financial component, consider
the appalling visual/physical damage this mining would have on the
land, and how that would impact tourism over the years--I have
spent a good deal of time by Ely, MN a big tourist town and know
how much of the economy is fed by tourists. I think the net loss of
tourism would cause a bigger financial
Summary of Public Comment: Superior NF Federal Hardrock Mineral
Prospecting Permits DEIS 11/17/2011
Preliminary Draft 7
impact than not creating a not-yet-"constructed" mine. Please, we
need to prevent the destruction of the BWCAW! (Ltr# 46, Cmt#
1)
Subconcern # AB
The Boundary Waters Canoe Area Wilderness is the nation’s most
popular wilderness area, with over 250,000 visitors coming from all
over the nation and world. Establishing a mining district in the
heart of this recreation area is not a wise decision. Although
mining may have a positive impact on the Northern MN economy, it
will be short term; protecting the wilderness for recreation
purposes will have a long term impact on the economy for future
generations. A wilderness area, if protected, can bring people and
money into an area for hundreds of years. Mining is short term and
can pollute the wilderness area leaving nothing for the future
generations. We owe it to the future generations to protect the
BWCAW; mining in close proximity to this area will not only ruin
the serenity of the wilderness for current users, but will also
hurt the potential use for the future generations. (Ltr# 80, Cmt#
1)
Subconcern # AB
This is not the appropriate place for drilling. The Forest Service
should not approve exploration in the area identified by the 33
prospecting permits. They are simply too close to the Boundary
Waters Canoe Area (BWCAW). Where is the common sense in the fact
that over 2000 exploratory holes have already been drilled and the
mining companies want to keep drilling even more? The minerals are
there…everyone knows that. In our opinion, we believe that the
mining executives want to continue drilling as a marketing ploy,
both in the regional newspapers and on their websites, so that
their investors do not sell off their stocks. Showing them that
progress with more exploratory drilling is being made raises the
“hope” for their investors that full fledged mining operations will
surely follow. However, this may be fine for the investors in
mining endeavors. But, is more exploratory drilling, with the
obvious goal of establishing full scale sulfide ore metal mines in
the water-rich environment of this area, in the public’s best
interest? The answer to us is an obvious no. This area is a natural
recreational area. Continued exploratory drilling will lead to
mineral development, which has the very real risk of polluting the
very waters that our business and others in the business of tourism
and recreation depend upon, and these are the same waters that flow
into the Wilderness of the Boundary Waters. Our business alone
generates roughly 4,000 visitors to Birch Lake and the Boundary
Waters Canoe Area each year. Combine that with all the other
tourism and recreational businesses in the area, including the
Forest Service maintained and operated South Kawishiwi and Birch
Lake Recreational Campgrounds, and the numbers of people from all
over the world that comes to this “jewel” of Minnesota to recreate
is staggering. We have had to buffer countless questions related to
the one drill rig on Birch Lake a few summers back, especially
since the drill rig proudly brandished a pirate’s flag. Not one of
our guests or casual visitor to the lake thought that it was in the
public’s best interest to allow drilling in such an irreplaceable
Wilderness Area. What then of the 40 some water access drill sites,
with the potential to destroy countless acres of federal wilderness
shoreline along scenic Birch Lake with over 90% of it being federal
shoreline that belongs to all the public. If this occurs the
shoreline will never be rehabilitated. Why? Built into the
Prospecting Permits Project is a proposed 20 year period of
drilling with a 10 year period to look back at the drill holes.
Thus, for the next 30 years anyone who recreates or lives in the
area will attempt to do so with an albatross hanging over their
collective heads…the advent of more prospecting drilling. Hundreds
of questions will be queried should this occur. In our Registration
Office dozens of informational flyers related to sulfide mining are
available to the guests and visitors that frequent River Point
Resort & Outfitting Co. Each person, to a one, shares total
disbelief that there is a real prospect that this most pristine
Wilderness Area could be adversely affected by the onset of
increased exploratory drilling with the real danger of a full
fledged sulfide mine, whether underground or open-pit, in operation
in the near future. To a one, they consider it a travesty on one of
the country’s most pristine and natural Wilderness Places. A
Wilderness Area that is highly valued for its natural scenic
surroundings, its clean water, and quiet, peaceful setting will
have long- lasting changes to it should continued and additional
exploratory mineral drilling be permitted. Creating an exploratory
mining district in a lakes district is wrong…dead wrong. These are
not appropriate activities for this area. The Boundary Waters Canoe
Area Wilderness and the Kawishiwi watershed is the nation’s most
popular wilderness area with over 250,000 visitors from all over
this nation and the world. It is not in the best interest of the
public to allow further exploratory drilling. The US Forest Service
should be protecting this important natural resource, as it is not
the appropriate place for continued exploratory drilling. (Ltr# 97,
Cmt# 20)
Subconcern # C
Summary of Public Comment: Superior NF Federal Hardrock Mineral
Prospecting Permits DEIS 11/17/2011
8 Preliminary Draft
The greater the mileage of temporary roads near the wilderness, the
greater the degree to which there may be the potential for illegal
motorized intrusion.” (Project, p. 105). (Ltr# 12, Cmt# 2)
Subconcern # D
Please don't approve the mining exploration requests adjacent to
the Boundary Waters canoe area. That entire region is so vulnerable
to run-off problems. The toxins associated with a mining project
could devastate that economic and environmental region. Approval of
the exploration begs approval of a mining plan and to my knowledge
no mining company has ever been able to limit environmental damage
to the finite and specific areas of their "dig". Mining companies
do not have a good citizenship track record. Minnesota has a
treasure in the BWCA and valuable clean water resource in Lake
Superior, the natural run-off dumping basin. Please think forward
and safe guard the region for future generations. (Ltr# 20, Cmt#
1)
Subconcern # E
Finally, the Forest Service should ensure that the Boundary Waters
is protected from any and all impacts from prospecting activity.
The Forest Service should consider restricting not only the time
and manner in which prospecting takes place, but also denying
permits in locations in which prospecting is inconsistent with
Forest Service policy goals and statutory mandates. (Ltr# 65, Cmt#
19)
Subconcern # F
Some of the permit applications are for tracts of land that abut
the BWCAW, and many others are for tracts in the watershed leading
directly into the BWCAW. A hard look should be taken at the
environmental consequences of exploratory drilling so close to the
BWCAW. The Forest Service, public officials, and the general public
should be able to consider a full picture of the environmental
consequences of the cumulative effects of exploratory drilling and
foreseeable mining on the BWCAW before decisions on these permit
applications are made or further actions are taken. By failing to
produce this full picture, the DEIS is inadequate. (Ltr# 71, Cmt#
8)
Summary of Public Comment: Superior NF Federal Hardrock Mineral
Prospecting Permits DEIS 11/17/2011
Preliminary Draft 9
Subject: Climate Change Category: 500
Public Concern 10 The Forest Service should address additional
stresses to the environment, plants, and wildlife based on climate
change, which is exacerbated by carbon emissions released during
exploration and mining operations, and the destruction of wetlands.
Contingency plans should be created to prevent exploration in
specific areas or during seasons of erratic weather patterns.
Sample Public Comment(s) for PC 10:
This document does not address additional stresses to the
environment, to plants, and to wildlife based upon climate change,
which is exacerbated by carbon emissions released during
exploration and mining operations, and the destruction of wetlands.
Nor does it address increasingly erratic weather patterns involving
flooding, drought, and temperature extremes. For example, during
this comment period, various states have been deluged by flooding,
or ravaged by tornadoes or wild fires. What contingency plans have
been created to prevent exploration in specific areas or at
times/seasons of environmental stress? (Ltr# 52, Cmt# 15)
Subject: Soils Category: 2410
Public Concern 92 The Forest Service should consider the following
regarding soils:
A) Soils do not recover within a few years from mineral exploration
activities (see photos in comment letter #12);
B) The Forest Service lacks the authority to impose restrictions to
such; C) The information in the Ecological Land Type
Mapping-Investigation and
Findings report; D) The Forest Plan sufficiently addresses any
necessary soil restrictions any
additional restrictions will result in conflict with the Forest
Plan and other legal guidance;
E) Assess the stipulations on a case-by-case basis based on the
site characteristics, changing weather conditions, land conditions,
overlapping Ecological Land Types, and the imprecision in the
Ecological Land Types mapping;
F) Ecological Land Type stipulations are too restrictive and would
restrict and/or prohibit exploration activities on 79 percent of
the forest and therefore, should be removed;
G) Ecological Land Types were not designed to address mineral
exploration activities, they are broad designations that do not
accurately represent on the ground conditions, and they are not
necessary in light of past effects to soil from exploration
activities; and
H) Explain the purpose for the Ecological Land Type restrictions
and how they would affect noise.
Sample Public Comment(s) for PC 92:
Subconcern # A
Picture 7 shows a typical drill site off of FR 1900. I visited a
site just off MN Hwy 1, ¼ mile from the South Kawishiwi River,
nearly four years ago, shortly after drilling had occurred. See
Picture A, which I previously submitted in 2007. Pictures 1 and 2
show a photo of the same site taken a few weeks ago. The site is
more degraded and worthless than it was four years ago. This is
contrary to claims made: “Soils on the Superior National Forest
have typically recovered from management activities within a few
years. Vegetation is usually re-established within
Summary of Public Comment: Superior NF Federal Hardrock Mineral
Prospecting Permits DEIS 11/17/2011
10 Preliminary Draft
the first growing season after ground disturbing activities and
becomes more prevalent after a few freeze-thaw cycles have restored
any soil functions that may have been altered by the effects of the
equipment operations”. (Project, p. 130) and “More recent
advancements in equipment and improved project mitigation measures
have resulted in substantial reductions in the impacts associated
with mechanical activities.” (Ltr# 12, Cmt# 3)
Subconcern # BC
The USFS’S soils analysis and stipulations relating to soils are
flawed. As with its attempts to impose other stipulations and
restrictions as part of this programmatic EIS, the USFS lacks the
authority to impose any restrictions or stipulations relating to
soils. With that said, MiningMinnesota submits as Exhibit 5 to its
Comments the Ecological Land Type Mapping – Investigation and
Findings (“ELT Report”), authored by Kelly Henry and Bryan Tolcser
of Short Elliott Hendrickson, Inc. Rather than repeating the
details of ELT Report, which are incorporated herein by reference,
MiningMinnesota submits the following comments relating to the
proposed soil stipulations and summarizes below a few key points
from the ELT Report, including comment regarding the flawed
Stipulations relating to Ecological Land Types that are contained
within the DEIS. (Ltr# 100, Cmt# 44)
Subconcern # BFG
The Forest Service has failed to consider reasonable alternatives
and has instead prepared a DEIS replete with uninformed,
unnecessary and excessive restrictions on prospecting and
exploration activities on the SNF. To resolve these issues in the
DEIS, the Forest Service must: Remove the restrictions based on
Ecological Land Types (“ELTs”) in the FEIS. There is no indication
that the restrictions are necessary based on past and expected
effects from prospecting and exploration activities on the SNF. The
proposed restrictions were designed for timber activities, not
mineral activities, and there is no legal basis for application of
the restrictions to mineral activities. Further, the ELTs do not
accurately represent on-the-ground conditions. (Ltr# 101, Cmt#
4)
Subconcern # D
The Forest Plan for the SNF sufficiently addresses any necessary
soil restrictions, and additional restrictions will result in
conflict or inconsistency with the Forest Plan. When, and through
what distorted mechanism, did the USFS confer rights to soils?
(Ltr# 242, Cmt# 3)
Subconcern # DE
The USFS’S soils analysis and stipulations relating to soils are
flawed. The Forest Plan for the SNF Sufficiently Addresses Any
Necessary Soil Restrictions, and Additional Restrictions Will
Result in Conflict or Inconsistency with the Forest Plan And Other
Legal Guidance. In the DEIS, potential impacts are identified, such
as soil compaction and displacement, as well as possible sediment
delivery to nearby wetlands and waterways. DEIS at 126-7. Unlike
other EISs, such as the Glacier FEIS, this DEIS (alternatives 2, 3
and 4) propose additional restrictions on the timing of activities
on certain ELTs so as to further reduce soil impacts. Id. For
example, activity on lowland ELTs (39% of the project area) would
be limited to frozen soil so that no rutting or compaction will
occur. Id. And fine textured and shallow soil ELTs would only
support activity during frozen or dry conditions (40% of project
area) while a small area (2% of the total project area) would allow
no activity at all due to extremely shallow soil and/or gravel
conditions. Id. The disparate treatment of soils by the USFS in
this EIS is arbitrary and capricious.
Correctly, though, the identified impacts are characterized as
“short term” and proposed efforts to minimize the impacts include
the use of existing corridors, as well as the implementation of
BMPs and Forest Plan standards and guidelines. DEIS at 127. Indeed,
many of the contemplated Stipulations rely upon the SNF Forest Plan
as the Source for the requirement. DEIS at 56. Simply put, the
imposition of additional restrictions beyond those detailed in the
SNF Forest Plan will result in conflicting directives for
MiningMinnesota members. For purposes of consistency, clarity and
ease of administration for the USFS, MiningMinnesota respectfully
submits the SNF Forest Plan sufficiently addresses any soil
restrictions and that further restrictions are unnecessary and
unwarranted.
Similarly, the DEIS seeks to impose additional, generalized soil
restrictions for mineral exploration activities for wetlands. DEIS
at 56. As with the soil stipulations relating to the ELTs
identified on page 56 of the DEIS, existing restrictions such as
those set forth in the 2004 Forest Plan sufficiently address any
restrictions as they apply to wetlands, and any additional
restrictions will likely result in conflicting directives. See,
e.g., Forest Plan at 2-15, and G-WS-12 and G-WS-13. Once again,
there is a risk of conflicting directives leaving MiningMinnesota
members with unnecessary exposure to inadvertent violations. To the
extent that any additional stipulations relating
Summary of Public Comment: Superior NF Federal Hardrock Mineral
Prospecting Permits DEIS 11/17/2011
Preliminary Draft 11
to soils or wetlands are being evaluated, as set forth below, they
must only be done on a case-by-case basis taking into consideration
the site-specific characteristics at issue. (Ltr# 100, Cmt#
45)
Subconcern # E
The USFS’S soils analysis and stipulations relating to soils are
flawed. The Soil Restrictions Identified in the DEIS Must Only Be
Applied On A Case-by-Case Basis And Based Upon The Particular Site
Characteristics So As To Take into Account Changing Weather
Conditions, Land Conditions, Overlapping ELTs, and The Inherent
Imprecision in ELT Mapping, All Of Which Creates The Risk Of
Inadvertent Violations of ELT Standards.
As detailed in the ELT Report, there is inherent imprecision in the
mapping of ELTs. Id. at 1-2. Of the 30 site locations visited by
the ELT report authors, there were seven that were mapped
incorrectly (23% error rate). Id. at 2. Of those seven areas, five
sites were in a field verified ELT adjacent to the mapped ELT and
the boundaries appeared to be misplaced, with such boundary
discrepancies ranging from five to twenty-five meters. Id. Three
sites identified were located within a transition zone between two
mapped ELTs where neither was dominant. Id. Of equal, if not
greater concern, two sites were incorrectly mapped altogether with
no mapped ELT nearby that matched the field verified ELT. Id. The
significant risk, of course, is that due to such imprecision in the
mapping used, there is a increased likelihood of inadvertent
violations of ELT standards.
Indeed, as the authors detail in their Report, to the extent that
the Final EIS imposes regulatory restrictions based upon the ELT
classifications noted, there is a need for site-specific evaluation
due to the degree of variance in the ELTs noted and given the scale
at which the ELT assessments were made. Id. Indeed, blanket
stipulations, such as those being considered in the DEIS, do not
take into account the imprecision in the methodologies used, nor do
they take into account changing weather and land conditions. Id.
This is especially the case where, as in the DEIS, there are
alternating and recurring ELTs in landscapes. Id. at 2-3.
Similar concerns arise where, as noted and observed by the authors,
the ELT boundaries are not distinct and transition zones exist with
merged characteristics of two ELTs. Id. at 3. In addition, because
the contemplated mineral exploration is expected to occur at small,
localized levels, what appears to be minor discrepancies between
the GIS-based ELTs relied upon in the DEIS and the actual ELT
classifications observed on a site-specific field investigations
“could be significant.” Id.
Accordingly, the experts concluded that while the GIS-based
methodology utilized to create the ELT mapping was appropriate, the
USFS’s reliance on this blunt tool for purposes of establishing the
ELT-related restrictions in the DEIS “is not appropriate.” Id. This
is especially cause for concern where the authors found “a nearly
25% rate of discrepancy between the GIS-based mapping and
ground-checked results…were the USFS and BLM to proceed with the
GIS-based restrictions suggested in the DEIS. Id. (Ltr# 100, Cmt#
46)
Subconcern # EF
The resource stipulations relating to soils should be applied on a
case by-case basis so as to take into account overlapping ELTS and
inherent imprecision in ELT mapping. This section incorporates the
Technical Memorandum of Short Elliot Hendrickson, Inc. (“SEH ”),
which is included as Attachment 2 to these comments. This Technical
Memorandum was prepared after SEH completed field work in June 2011
for select ELTs identified within the SNF.
While SEH’s report notes that the DEIS’s references to mapping of
ELTs at a scale of 1:24,000 is generally accurate, it identifies
concerns with the application of Resource Stipulations based on
this ELT mapping as a result of the field investigations recently
performed. SEH concludes that, despite USFS’s use of sound
methodology, the scale and nature of the available GIS-mapping
relied upon by USFS in the DEIS makes the precise identification of
ELT type and boundaries problematic for any particular ELT.
Specifically, SEH’s field work found discrepancies at 23 percent of
the study sites between the actual ELT types or boundaries
inspected and the mapped information contained in the DEIS. Because
of the small geographic areas generally involved in mineral
exploration, deviations of the nature found in the SEH study can be
significant. Potential inaccuracies in the ELT types or boundaries
referenced in the DEIS could result in unnecessary or incorrect
imposition of Stipulations grounded in the GIS- based maps or in
inadvertent violations of the Resource Stipulations for ELTs if
they are not tailored to the site- specific and ground-verified
circumstances of a particular Mineral Authorization.
Moreover, SEH’s field verification work suggests that the ELT
boundaries as indicated in the DEIS may be imprecise in many cases
as a result of transition zones between two adjacent ELTs. Such
difficulties are inherent in the GIS-based mapping methodologies
and data utilized in the DEIS. Rather than impose blanket, and
potentially inappropriate, Resource Stipulations without regard for
such transition zones, the DEIS should acknowledge the existence of
such issues and adopt a case-by-case approach to Resource
Stipulations for ELTs.
Summary of Public Comment: Superior NF Federal Hardrock Mineral
Prospecting Permits DEIS 11/17/2011
12 Preliminary Draft
A third concern identified by SEH in its field work was the
existence of overlapping ELTs. SEH identified several areas in
which smaller ELTs may exist within a larger ELT, and the smaller
ELT has the potential to not be revealed in the GIS-based maps in
the DEIS. By using a case-by-case approach to ELT stipulations, the
USFS can ensure that these smaller ELTs are adequately protected
or, if such ELTs are areas in which mineral exploration will not
adversely impact the soils, can allow mineral exploration to
proceed without imposing unnecessary Resource Stipulations.
Finally, SEH’s study demonstrates that the scale of the USFS’s
GIS-based mapping makes the ELT classifications in the DEIS an
inappropriate foundation for the broad (non-site specific) Resource
Stipulations. This concern is particularly important because
approximately 80 percent of the SNF would be subject to ELT-based
restrictions (primarily allowing prospecting only in frozen
conditions) under the DEIS. Winter-only authorizations and other
requirements should be applied only on a site-specific basis, after
project sites are identified and ground verified, so an appropriate
evaluation of actual ELT classification, potential impacts, and
available mitigation or avoidance options can be dete rmined. (Ltr#
107, Cmt# 36)
Subconcern # FG
The Blanket Ecological Land Type Restrictions Imposed by the DEIS
are Unrealistic and Excessive. The DEIS proposes stipulations on
exploration activities according to Ecological Land Types (“ELTs”).
These stipulations would restrict exploration activities on 79% of
the SNF and completely prohibit operations on additional areas of
the SNF. The ELT restrictions are unrealistic and excessive for
several reasons. First, the restrictions were originally designed
to minimize the impacts to the soil resource from timber activities
in the SNF Forest Plan and were not designed to address mineral
exploration activities. Second, the ELTs are broad designations
that do not accurately represent on-the-ground conditions. Third,
there is no evidence that the ELT restrictions are necessary in
light of past effects to the soil resource on the SNF from
exploration activities. Thus, the Forest Service must remove the
ELT restrictions in the FEIS. (Ltr# 101, Cmt# 10)
Subconcern # FG
The ELT Restrictions are Not Designed to Minimize Impacts to the
Soil Resource from Exploration Activities. The ELT stipulations in
the DEIS are derived from limitations placed on timber activities
in the SNF Forest Plan. The Forest Plan, with regard to watershed
health, riparian areas and soil resources, requires the Forest
Service to “[f]ollow the limitations on management activities
specified in Table G WS-8.” Management activities in Table G WS-8
do not include mineral exploration activities; rather, they include
activities related primarily to timber production. Those timber
production activities are limited based on ELT. The DEIS provides
no justification for correlating timber production activities and
mineral exploration activities in order to adopt similar ELT
restrictions for both.
The Forest Plan restrictions for timber production are designed to
reduce erosion. The restrictions assume extensive equipment use and
broad surface disturbance. These concerns do not apply to
exploration activities, which involve minimal erosion potential,
utilize limited equipment, and result in little surface
disturbance. In addition, the ELT restrictions would limit mineral
exploration activities in contravention of the SNF Forest Plan,
which establishes the SNF’s Forest-wide management direction. With
regard to minerals on the Forest, desired condition D-MN-1 states:
“[e]xploration and development of mineral and mineral material
resources is allowed on National Forest System land . . . .”
Desired condition D-MN-2 provides: “[e]nsure that exploring,
developing, and producing mineral resources are conducted in an
environmentally sound manner so that they may contribute to
economic growth and national defense.” For federal minerals outside
the Boundary Waters Canoe Area Wilderness (“BWCAW”) and Mineral
Protection Area (“MPA”), there is no further direction, including
an absence of standards and guidelines, restricting mineral
exploration activities on the Forest. Certainly, there are no
restrictions in the SNF Forest Plan on mineral exploration
activities according to ELT. There is no justification for the
Forest Service’s imposition of restrictions on mineral exploration
activities based on ELT. None are directed by the Forest Plan and
imposition of ELT restrictions meant for timber production
activities on mineral exploration activities on the SNF is
arbitrary and capricious. As a result, in the FEIS, the Forest
Service must remove the ELT restrictions on mineral exploration
activities. (Ltr# 101, Cmt# 11)
Subconcern # FG
The ELTs are Broad Designations that Do Not Accurately Represent
On-The-Ground Conditions. Restricting exploration activities
according to ELT ignores the possibility that certain on-the-ground
conditions within individual ELTs, such as previously impacted
areas, roads, gravel pits, etc., may provide favorable conditions
for mineral exploration activities. ELTs on the SNF were mapped
from 1969 to 2003 and compiled through a
Summary of Public Comment: Superior NF Federal Hardrock Mineral
Prospecting Permits DEIS 11/17/2011
Preliminary Draft 13
combination of field investigations and aerial photo
interpretation. The ELT mapping it is at best, rudimentary. There
is no assurance the ELTs that are mapped actually represent the
ELTs in each specific area on the Forest. Moreover, because ELTs
can vary widely even in a small area, the Forest Service’s broad
mapping effort undoubtedly mischaracterizes and generalizes ELTs
across the Forest. The FEIS must analyze and explain the
shortcomings of the ELT mapping effort. Instead of relying on
imprecise and limiting ELT restrictions, the Forest Service should
consider the alternative of providing ELT restrictions on a
case-by-case basis rather than applying them broadly and
excessively and thereby restricting or prohibiting exploration
activities on areas of the Forest that may not be in need of such
protection. (Ltr# 101, Cmt# 12)
Subconcern # FG
There is No Evidence that ELT Restrictions are Necessary in Light
of Past Effects to the Soil Resource from Exploration Activities.
The Forest Service acknowledges that prospecting and exploration
activities are not likely to result in adverse impacts to the soil
resource on the SNF. Nonetheless, the Forest Service proposes
cumbersome ELT restrictions to combat certain unknown and
unexplained adverse impacts to the soil resource from prospecting
and exploration activities. In light of the known past and
potential future impacts to the soil resource on the SNF from
mineral exploration activities, however, the ELT restrictions
proposed in the DEIS are unnecessary. In the DEIS, the Forest
Service recognizes that mechanical equipment has been used for
decades on portions of the SNF for non-mining related activities
and that such activities have caused rutting, compaction and soil
displacement. However, there is no discussion in the DEIS regarding
how reuse of these portions of the SNF for exploration activities
would produce any significant new effects to the soil resource.
Focusing exploration activities in areas with existing ruts,
compacted and displaced soil, would be possible on many areas of
the SNF, thereby negating the need for extensive ELT
restrictions.
Where previously disturbed areas can not be utilized, impacts on
the soil resources from exploration activities are expected to be
minimal. The Forest Service acknowledges that modern mechanical
equipment has resulted in substantial reductions in the impacts
associated with mineral exploration activities in recent years. The
Forest Service points out, “[n]o discernable impacts to long-term
soil productivity have been identified as a result of past mineral
exploration activities with the Forest,” and that, in general,
“[p]ast resource management activity has had minimal effects to the
soil.” “Soils on the Superior National Forest have typically
recovered from management activities within a few years. Vegetation
is usually re-established within the first growing season after
ground disturbing activities and becomes more prevalent after a few
freeze-thaw cycles have restored any soil functions that may have
been altered by the effects of equipment operations.” The Forest
Service has thus concluded that there are very few likely adverse
impacts to the soil resource on the SNF from exploration
activities. Thus, there is no need for excessive ELT restrictions
to protect the soil resource on the SNF from exploration
activities. Those restrictions must be removed in the FEIS. (Ltr#
101, Cmt# 13)
Subconcern # H
The Purpose For and Effects of the ELT Restrictions are Not
Adequately Explained in the DEIS. The Forest Service fails to
analyze in the DEIS how the ELT restrictions would affect the one
issue identified in the DEIS: noise. Implementing the ELT
restrictions would actually exacerbate noise impacts on the Forest.
The Forest Service explains that ambient background noise varies
between seasons (likely increasing in the summer and dissipating in
the winter) and that sound decay is much more rapid in the summer
than in the winter. Thus, noise impacts are expected to be greater
in the winter than in the summer. By providing seasonal exploration
restrictions, the Forest Service is increasing overall noise
impacts. Likewise, by providing seasonal exploration restrictions,
the Forest Service is increasing the overall duration of noise
impacts on the Forest. Because exploration would be so restricted,
it would take longer to complete, thereby lengthening the overall
time that exploration would take place on the Forest. In the FEIS,
the Forest Service should discuss the effects of more limited
short-term noise impacts (fewer years of impacts) versus more
continual long-term noise impacts (more years of impacts), and
remove the ELT restrictions because they increase impacts overall.
If the ELT restrictions are not removed, the Forest Service should
acknowledge the prohibitions and limitations imposed by the ELT
restrictions, and narrow its effects analysis for other Forest
resources, including noise, to account for those restrictions.
(Ltr# 101, Cmt# 14)
Summary of Public Comment: Superior NF Federal Hardrock Mineral
Prospecting Permits DEIS 11/17/2011
14 Preliminary Draft
Subject: Vegetation - General Category: 2800
Public Concern 98 The Forest Service should consider the following
regarding vegetation:
A) Ensure protection of the vegetation as a result of prospecting
activities; B) The effect to vegetation will be temporary and not
large in scale; and C) Development of a debris management plan for
all downed vegetation resulting
from road construction and consider how it will be staged, where
will it be chipped or burned, who will dispose of it, and how it
will affect air quality.
Sample Public Comment(s) for PC 98:
Subconcern # A
In the same vein as item 4. , building roads through forests does
destroy trees which require years to mature. Already, according to
some, climate change threatens the arboreal forests. Fires and
insects threaten our forests. Is this the time to add more threats
to forest ecology? Are not road construction and drilling an
assault on the trees and other flora of the forests? What is worth
protecting---the forests’ flora and fauna or the profligate profits
of industry? To whom does the national forest system belong---to
the taxpayers and future generations or to short-term global
investors? (Ltr# 36, Cmt# 5)
Subconcern # A
In the same vein as item 4., building roads through forests does
destroy trees which require years .to mature. Already, according to
some, climate change threatens the arboreal forests. Fires and
insects threaten our forests. Is this the time to add more threats
to forest ecology? Are not road construction and drilling an
assault on the trees and other flora of the forests? What is worth
protecting-the forests' flora and fauna or the profligate profits
of industry? To whom does the national forest system belong---to
the taxpayers and future generations or to short-term global
investors? (Ltr# 130, Cmt# 6)
Subconcern # B
This document does not address additional stresses to the
environment, to plants, and to wildlife based upon the potential
for increased disruption and interference through a network of new
forest openings that will provide access to the forest throughout
the year. “Temporary” exploration roads need to be large enough in
size to accommodate considerably large equipment. The footprint of
mining exploration will not be “small.” (Ltr# 52, Cmt# 13)
Subconcern # C
What is the debris management plan for all the downed vegetation
resulting from road construction? It is against the law to burn
debris in a wetland. Burning debris is a Clean Air Act issue. How
is debris to be staged and where will it be chipped or burned? What
happens to the ash? Here again you need EPA or State DEQ permits
and also need to consult the SHPO and Tribes. Whose homes and
communities will the smoke effect? Any environmental justice
issues? (Ltr# 114, Cmt# 9)
Subject: Vegetation - Non-Native Invasive Species Category:
2810
Public Concern 99 The Forest Service should consider the following
regarding invasive species:
A) The spread of invasive species by ATVs due to the length of time
that roads are likely to be open (up to 20 years); and
B) The cumulative effect of roads opening up areas that were not
previously open to the import of invasive species even though it is
a small area.
Sample Public Comment(s) for PC 99:
Subconcern # AB
Summary of Public Comment: Superior NF Federal Hardrock Mineral
Prospecting Permits DEIS 11/17/2011
Preliminary Draft 15
The DEIS underestimates the likelihood of the spread of invasive
species. The DEIS accepts that there will be invasive plant species
imported into the forest as a result of drilling activities. It
then spends a great deal of effort to show why these species once
imported cannot survive in the forest. Absent an equivalent effort
to elaborate the arguments as to why the invasives could reasonably
be expected to survive and spread, no rational weighting of the
evidence is possible. On the face of it, the analysis is at best
insufficient and at worst misleading. ATVs are a primary, perhaps
the largest, source of transport of invasive plant species into the
forest. The DEIS dismisses the likelihood of ATV use out of hand,
ignoring this most likely frequent source of the spread of new
invasives to the drilling areas of the SNF. The DEIS states that
the roads constructed for access to the drill sites will be
reclaimed, thus preventing use by ATVs. However, many of the roads
will remain open for many years for many of the sites. Return
visits for additional drilling can be undertaken at any time over
the life of the drilling episode for any wells not closed
permanently after initial drilling. It is further noted in the DEIS
that most of the roads are short and do not make loops which the
ATVers prefer. However, in many locations, the drilling access
roads connect with “native trails” or other roads that form the
equivalent of loops. Examples of loop-like trails occur on maps 3.5
and 3.6 in the Birch Lake area in sections 7, 18, 19; and most
egregiously in maps 3.12 and 3.13, sections 7, 6, 30, 31, 32, and
29. Even if the shorter roads to specific drill sites are “rapidly”
reclaimed, the main access trail which forms the loop in
conjunction with other trails (shown in maps 3.12 and 3.13) would
remain open for many years and be an open invitation to ATVs to
spread invasive species. This is, moreover, the drilling area
closest to the Boundary Waters. The life of the access roads can be
very long indeed. Due to the length of time that the roads are
likely to be open despite being labeled “temporary” the ATV’ers are
likely to have made their own trails as they often do which will
survive after the access road is reclaimed. It is misleading to
assume that these roads, classed as “temporary” in bureaucratic
nomenclature, will in fact be temporary. Temporary in this context
can mean up to 20 years! The cumulative import of invasive species
will be much larger than is suggested by the “temporary” label
attached to the road. It is argued that the total area of the roads
and sites is small compared to the total area assessed. This
position ignores the fact that this small area is at the same time
distributed in many different areas thus opening up many areas not
previously open to the import of invasives. It is simply inadequate
to attempt to diminish the threat of invasives on the basis that
the acreage of the roads and the drill sites is small. It is
further argued that the expected influx of invasives cannot survive
in forest areas with heavy shade. The fact of repeated introduction
of invasives perhaps over many years while cover is more or less
continually kept open garners no comment. The argument appears to
be based on the average experience with invasives connected with
logging activities. Some logging areas remain open for long periods
of time as logging proceeds on adjacent parcels. Others return to
closed cover forest more rapidly once logging is complete. The
proper comparison to drilling activities is not the average
experience, but that experienced on those areas left open for
whatever reason for longer periods. (Ltr# 62, Cmt# 39)
Subconcern # AB
Natural forest vegetation will be cleared and often seeded. These
disturbed lands are also exposed to non-native invasive species. We
currently know our greatest hope for slowing the spread of many
nondesirable species is by not providing them the opportunity to
become established. This project is yet another blueprint on how to
spread and establish non-natives; provide a plethora of
disturbance, equipment, operators and roads into a landscape that
has plentiful sources for thistles, tansies, leafy spurge,
knapweed, etc. Invasive species are a serious issue and although we
spend millions attempting to control them ... we are unwilling to
avoid many obvious pitfalls leading to their further establishment
and the degradation of our diminishing native plant communities.
The project will further degrade the SNF by contributing to the
spread invasive species. (Ltr# 175, Cmt# 6)
Subconcern # B
At a time when the USFS is doing an EIS on possible treatment
options for invasive species in the BWCAW, the agency is preparing
to approve multiple prospecting permits near the BWCAW- and tier
unknown additional mineral exploration off of the FEIS.
Additionally, the road openings that accompany mineral exploration
will open the forest to invasive plant species and this threat to
the forest, including the Superior National Forest and BWCAW, and
is inadequately addressed in the Draft EIS. (Ltr# 111, Cmt#
15)
Subject: Vegetation - TES Species Category: 2830
Public Concern 100 The Forest Service should consider the following
regarding TES species:
A) Address impacts to state listed species;
Summary of Public Comment: Superior NF Federal Hardrock Mineral
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B) Include stipulations for avoidance of known occurrences of rare
species; C) Conduct RFSS plant surveys and include in the analysis;
and the public given
the opportunity to review and comment on them; D) Conduct Minnesota
County Biological Surveys; E) Conduct a single high quality ground
based geophysical survey paid for by the
permittees to reduce impacts; and F) Disclose who, when, where, and
how they surveys have been conducted.
Sample Public Comment(s) for PC 100:
Subconcern # AB
State-listed plant and animal species are not addressed in the
draft EIS. There are several state-listed endangered or threatened
species in the area. The USFS has a copy of the Rare Features
Database through a license agreement with the MNDNR. This data
should be used to address potential impacts to state-listed species
in the EIS. For state leases, the MNDNR requires botanical surveys
if a state-listed threatened or endangered species have been
documented in the vicinity of the project and suitable habitat for
this species occurs within the project boundary. Minnesota’s
endangered species law (Minnesota Statutes, section 84.0895) and
associated rules (Minnesota Rules, Parts 6212.1800 to 6212.2300 and
6134) prohibit the taking of threatened or endangered species
without a permit. Permit stipulations may also include avoidance of
known occurrences of rare species. (Ltr# 39, Cmt# 4)
Subconcern # C
The DEIS explains that this project could affect sensitive plant
species. “Ground disturbance associated with the project, including
temporary road construction/reconstruction, drill pad construction,
and drilling activities, could impact suitable habitat for RFSS
plants. Resource stipulations specify that RFSS plant surveys would
be conducted in suitable habitat before project activities take
place, and that project operations would avoid known RFSS plant
occurrences” (63). “No surveys for RFSS plants have taken place yet
for the Federal Hardrock Mineral Prospecting Permit DEIS” (BE, 3).
These planned plant surveys should be included in the DEIS. The
public needs to see the results of these surveys and be given the
opportunity to review them and then submit comments. It is critical
for surveys to be conducted so that the Agency can protect known
occurrences of sensitive species. No surveys for plants or animals
have occurred thus far. “ No specific animal surveys were conducted
for this project but surveys were completed for vegetation
management projects located across the Superior National Forest and
the data from those projects is incorporated into the Monitoring
and Evaluation Report” (BE, 2). Surveys need to be conducted and
appropriate environmental review and analysis completed. The public
needs the chance to see survey results, with adequate discussion by
agency personnel, and then have the ability to make meaningful
comments that can be incorporated into the final plans. The DEIS
promises that surveys will be conducted prior to the start of
exploration activities. “Because all listed plant locations or nest
and/or den sites are not known, survey needs shall be determined by
a SNF biologist, using approved protocols in suitable habitat, to
determine occupancy in the areas where exploration activities are
planned” (53). “No Surface occupancy will be allowed until adequate
surveys have been completed for the following species: bald eagle,
osprey, great gray owl, boreal owl, and northern goshawk” (BE, 5).
When will these surveys be done? How will the public be given the
opportunity to review and comment on survey results? These surveys
should be included in the DEIS. (Ltr# 62, Cmt# 18)
Subconcern # D
Each time we sought to expand our business operation with the
construction of new cabins, when the land that River Point is sited
on was owned by the federal government (up until 2002), an
endangered plant species survey and EIS had to occur. Thus, we are
quite familiar with this process. This DEIS fails to adequately
address the impact of the proposed mineral prospecting actions on
rare plants. Specifically, the 2009 study by the Minnesota County
Biological Survey ("MCBS"), a program of the Minnesota Department
of Natural Resources showing the location of rare plant species
occurring in Minnesota counties is not included in the DEIS.
Impacts of trails, drill pads and related road construction, and
equipment use on rare plants in the vicinity is not analyzed in the
DEIS. All of these activities will have significant impacts on
these rare species. It is unacceptable to allow mineral exploration
companies to have weak or no standards or regulations to follow
regarding sensitive and rare plants, while other businesses, such
as mine, were critically inspected regarding such. (Ltr# 97, Cmt#
31)
Subconcern # D
The MNDNR County Biological Survey has not been completed in the
area. We do not know what is there. On 6/29/11 I personally
observed the vast diversity of the wetland, including what I
believe to be a fen along the newly cut roadway into Greenwood, and
I believe I observed Botrychium Mormo in one location. And I
believe one
Summary of Public Comment: Superior NF Federal Hardrock Mineral
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Preliminary Draft 17
portion of the area is a fen, but part of determining whether
indeed it is a fen depends on the work done by the Biological
Survey being conducted by the DNR - which is not complete and until
that survey is complete no one knows what we and the authorities
whose job it is to assess the propriety of don't know about the
area, and neither does the forest service. Our group does not have
the resources needed to determine at this point whether what was
observed was indeed Botrychium Mormo – but we are fortunate that
the state of Minnesota has expert botanists engaged in a formal
process of studying the region and determining what biological
species exist in Minnesota. This process is underway and efforts to
engage in large scale and potentially destructive exploration prior
to that process being complete is with regard to time and natural
resources and the best interests of the people and other creatures
living in Minnesota “penny wise and pound foolish” Unless the SNF
has done a study equal or better than that being done by the
state’s County Biological Survey, we ask that the exploration hold
off till it is complete. (Ltr# 103, Cmt# 5)
Subconcern # E
Page 28 says “Geophysical surveys are proposed for all operating
plans. They include narrow (3-6 feet) vegetation clearing along
lines laid out in a grid type fashion”. As stated on page 20, “they
may need to cut vegetation that is too dense to allow them and
their equipment to get through. Normally the vegetation is thick
shrubs and young trees”. There are two issues:It is likely that
different prospectors will each perform their own separate surveys,
resulting in needless duplication of cutting swaths. Suggestion:
Similar to the airborne surveys: Rather than allowing each company
to do its own survey, there should be a single, high-quality
ground-based geophysical survey. Prospecting companies would pay
for the survey. The USFS or BLM or a private company could be the
official steward of the collected data, releasing it at some agreed
cost to prospectors. This approach will greatly reduce the noise
impact of chainsaws in the large area covered by geophysical
surveys, and will also reduce the impact to vegetation. It will
also save the prospectors a lot of money. (Ltr# 106, Cmt# 3)
Subconcern # F
What plant and animal surveys have been conducted and when and
where and by whom were they conducted? (Ltr#
114, Cmt# 15)
Subject: Wild Rice - As Related to Mining Category: 3100
Public Concern 115 The Forest Service should consider the effects
to wild rice harvesting and sales on both natives and non-natives,
including river stands and traditional cultural properties, and
include stipulations to protect the wild rice resource.
Sample Public Comment(s) for PC 115:
Wild rice. Studies have shown that increases in sulfate levels
negatively impact the well-being of wild rice beds. Not only a
fairly large industry, that of wild rice harvesting/sales by both
natives and non-natives, but also an integral cultural component to
our native peoples, considered sacred. (Ltr# 16, Cmt# 10)
A Supplemental DEIS should provide a thorough analysis of potential
impacts on natural wild rice, including river stands, and a
Traditional Cultural Properties analysis; (Ltr# 25, Cmt# 16)
The Prospecting DEIS contains inadequate analysis and mitigation of
water quality impacts, including impacts of brines and toxic metals
on non-degradation requirements and impacts on wild rice. The
Prospecting DEIS recognizes that drill pad construction would
adversely impact natural stands of wild rice, and proposes a
50-foot setback from wild rice lakes. (Prospecting DEIS, p. 16).
However the DEIS neither discusses or limits the impacts of
landings on wild rice; the DEIS also fails to propose any setbacks
for drill pad construction adjacent to streams or rivers containing
stands of natural wild rice. A Supplemental DEIS should analyze the
degree to which proposed permits and operation plans impact stands
of wild rice and should include stipulations to protect wild rice
in lakes, streams and rivers from landings as well as drill pad
construction. (Ltr# 25, Cmt# 53)
The Prospecting DEIS contains inadequate analysis and mitigation of
water quality impacts, including impacts of brines and toxic metals
on non-degradation requirements and impacts on wild rice. The
Prospecting DEIS begins to review the significance of wild rice
stands as Traditional Cultural Properties, suggesting that a wild
rice stand that
Summary of Public Comment: Superior NF Federal Hardrock Mineral
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has been annually harvested historically by a distinct living
community for the past 100 years should be considered a Traditional
Cultural Property heritage resource and that there are 34 known
heritage resources within permit application boundaries.
(Prospecting DEIS, pp. 178, 179). However, the DEIS criteria by
which a wild rice stand would be deemed a Traditional Cultural
Property are overly narrow. Cycles in productivity of natural wild
rice might preclude an “annual” harvest and, in general, a resource
develops cultural significance after 50, not 100 years. (See e.g.
National Register Bulletin, How to Apply the National Register
Criteria for Evaluation, p. 41,
http://www.nps.gov/nr/publications/bulletins/pdfs/nrb15.pdf) (Ltr#
25, Cmt# 54)
The DEIS does not discusses or limit the impacts of landings on
wild rice. The DEIS also fails to propose any setbacks for drill
pad construction adjacent to streams or rivers containing stands of
natural wild rice. What is the degree to which proposed permits and
operation plans impact stands of wild rice? Wild rice harvesting
has occurred over decades and continues to occur throughout this
project area, providing a food source and an annual income to
households. The DEIS should include stipulations to protect wild
rice in lakes, streams and rivers from landings, drill pad
construction, water use and all other prospecting-related
activities. (Ltr# 34, Cmt# 16)
The Band is especially concerned about impacts to manoomin, or wild
rice. While the DEIS maintains that resource stipulations would
protect wild rice waters from impacts related to mineral
exploration, it has come to our attention that current prospecting
activity in the Skibo South and Greenwood Lake South Mineral
Exploration Projects (Encampment Minerals) has resulted in impacts
to wild rice waters (the St. Louis River, which is harvested by
Band members in this area, and Petrel Creek, which connects two
culturally important wild rice lakes). Manoomin is an exceptionally
sensitive species, declining substantially across its historic
range, and as SNF is well aware, one of the most significant
cultural resources to the Ojibwe. The Band would urge SNF to
consider greater protective stipulations in permits for these and
future projects in proximity to wild rice waters. (Ltr# 115, Cmt#
6)
I am a wild ricer and this mining can impact the wild rice. This is
not a risk worth taking nor is it fair to the Native Americans.
(Ltr# 240, Cmt# 2)
Subject: Wild Rice - As Related to Tribal Significance Category:
3120
Public Concern 116 The Forest Service should consider that there
are very specific hydrologic conditions required for wild rice, and
the thresholds for surface water quantity (Table 26) may not be
protective enough and should be evaluated on a project-by-project
basis, with current wild rice inventory data available, to
determine if a prospecting site is near wild rice waters.
Sample Public Comment(s) for PC 116:
Table 26, "Indicators for potential effects on water resources", in
Section 3.6, defines a threshold for surface water quantity of
'reduction of flow in a stream by 10% or drop in water levels in a
basin by more than 1 ft." The Band would call attention to the very
specific hydrologic conditions that wild rice requires, and note
that this threshold may not be protective of critical hydrology for
wild rice. This threshold should be evaluated on a
project-by-project basis, with current wild rice inventory data
available to determine if a prospecting site is near wild rice
waters. (Ltr#
115, Cmt# 7)
Summary of Public Comment: Superior NF Federal Hardrock Mineral
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Subject: Social/Economic - Economic Analysis Category: 2300
Public Concern 87 The Forest Service should consider the following
regarding the economic analysis:
A) Impacts to real estate values; B) It should be bounded by the
same actions used as a basis for the
environmental effects analysis because mining references exaggerate
the economic effects of the proposed action;
C) The information in the University of Minnesota Duluth Labovitz
School of Business and Economics report of March, 2009 titled"The
Economic Impact of Ferrous and Non-Ferrous Mining on the State of
Minnesota and on the Arrowhead Region and Douglas County,
WI";
D) Metal markets and global demand; E) Documented history of mining
company bankruptcies; F) Tax rebates to mining companies; G) The
“Resource Curse” – economic theory that building an economy on
selling
non-renewable resources usually results in an underperforming
economy; H) The discrepancies in average mining wages and average
income; I) Rationale for abstaining from mineral development; J) A
cost-benefit analysis; K) Assessment of effects from restrictions
placed on mineral exploration; L) The long-term environmental
cumulative effects of mineral exploration on the
economy; M) The effects from not issuing prospecting permits as was
done previously; N) Job number estimates directly and indirectly
are low and need to be re-
evaluated to reflect economic data; O) The BBER Report should be
considered; P) Impacts to business reliant on tourism and
recreational opportunities; Q) Economic impacts from allowing
international corporations versus Minnesota
and/or US companies to explore; and R) Assumptions made by the
economic model and subsequent conclusion.
Sample Public Comment(s) for PC 87:
Subconcern # A
Real Estate- and what will happen when more wells start showing up
contaminated? What will residents do? I don't even want to think
about that possibility. Way worse than not being able to sell your
home because the mine closed and there's no work. (Ltr# 16, Cmt#
8)
Subconcern # A
We live in Northeastern Minnesota and our property values are
likely to be affected adversely by even the possibility of
extensive metallic sulfide mining in the area. The amount of noise
generated by exploratory drilling (already), and the potential
damage to water quality, especially to the protected
non-degradation status of many area lakes in the Kawishiwi
Watershed, will affect not only our property values but the quality
of our residential lives and enjoyment of recreational
opportunities. (Ltr# 32, Cmt# 1)
Subconcern # A
My property values are likely to suffer by even the possibility of
extensive metallic sulfide mining in the area. Assurances of safety
planning are not enough. Obviously, accidents are not expected, but
we must, none-the-less plan for worst case scenarios when future
jobs that depend on the environment are placed in jeopardy. No one
who has even a slight familiarity with the problems of sulfide
mining can believe that such mining does not pose a danger to the
environment, particularly concerning water quality. People living
close to the triangle are already being exposed to excessive noise
from by exploratory drilling, the potential damage to water
quality. This is especially
Summary of Public Comment: Superior NF Federal Hardrock Mineral
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true with regard to the protected non-degradation status of many
area lakes in the Kawishiwi Watershed, and will affect not only
their property values but the immediate quality of their
residential lives and recreational opportunities. (Ltr# 43, Cmt#
2)
Subconcern # A
Our property values are likely to be affected adversely by the
possibility of extensive metallic sulfide mining in the area. The
amount of noise generated by exploratory drilling and the potential
damage to water and land will affect not only our property values
but also the present excellent quality of our lives, which is due
in very large part to the relatively pristine environment of the
Superior National Forest. (Ltr# 70, Cmt# 2)
Subconcern # A
Land and property values are being negatively impacted and as these
mining proposals precede private property values and one's ability
to sell their properties will become more limited and devalued.
Having our property bound on three sides by the SNF has always been
a selling point .. a feature with value. This dearly won't be the
case when our SNF lands become more fragmented, noisy, and/or
mined. (Ltr# 175, Cmt# 8)
Subconcern # BC
We recommend that the discussion of economic effects be improved.
In our opinion, the economic analysis wrongly includes actions not
discussed in the draft EIS, specifically mining. The economic
analysis should be bounded by the same actions used as a basis for
the environmental effects analysis— that of exploration. References
to the economic effects of mining exaggerate the economic effects
of the proposed action and possibly leave readers with the
incorrect impression that this document addresses mining. However,
if the USFS believes that the scope of the economic analysis is
correct, then the University of Minnesota Duluth Labovitz School of
Business and Economics report of March, 2009 title The Economic
Impact of Ferrous and Non-Ferrous Mining on the State of Minnesota
and on the Arrowhead Region and Douglas County, WI should be used
in place of the University of Montana report of 2007. The
University of Minnesota report is a better source of information on
mining’s economic impact on northeastern Minnesota. (Ltr# 39, Cmt#
8)
Subconcern # C
The analysis of economic impacts in the EIS understates the adverse
impact the stipulations and noise restrictions will have. Another
“major omission” in the DEIS’s economic analysis is its failure to
include the recent research in the Labovitz Report, the full title
of which is “The Economic Impact of Ferrous and Non-Ferrous Mining
On the State of Minnesota And on the Arrowhead Region and Douglas
County, WI” prepared in 2009 by the Bureau of Business and Economic
Research (“BBER”), Labovitz School of Business and Economics,
University of Minnesota-Duluth (“Labovitz Report”). See footnote 1,
above, and Exhibit 1. The Labovitz Report, using the IMPLAN model
with 2007 data, details the significant direct, indirect, and
induced effects associated with mineral development. Hays Report at
1, 5. (Ltr# 100, Cmt# 52)
Subconcern # C
The analysis of economic impacts in the EIS understates the adverse
impact the stipulations and noise restrictions will have. The EIS
Does Not Adequately Incorporate or Analyze Existing Economic
Studies Regarding Mineral Exploration and Development of Hardrock
Minerals in the SNF. As detailed throughout this Section of our
Comments, the most thorough economic study regarding mineral
exploration and development of hardrock minerals in the SNF, the
Labovitz Report, has all but been ignored. The absence of this
report is a glaring omission that must be considered and addressed.
It details all of the significant direct, indirect and induced
economic and social benefits associated with nonferrous mining in
the SNF, and tells a compelling story. MiningMinnesota. We trust
that the Final EIS will give it thorough consideration. (Ltr# 100,
Cmt# 56)
Subconcern # C
3.14 Economics and Environmental Justice - 3.14.1.1 Analysis area
(pg. 188) The DEIS' discussion of the economic impacts to the local
economy affected by exploration and associated activities does not
consider nor reference the more recent research report "The
Economic Impact of Ferrous and Non-Ferrous Mining On the State of
Minnesota And on the Arrowhead Region and Douglas County, WI"
completed in March of 2009. This is a very significant omission.
This report was prepared by the Bureau of Business and Economic
Research, Labovitz School of Business and Economics, University of
Minnesota-Duluth. The BBER Report used the IMPLAN model with 2007
data which was the most recent data available at the time. The
economic impacts were reported in 2007 dollars. The economic
impacts analyzed were for Minnesota's seven county Arrowhead Region
(Atkins, Carlton, Cook, Itasca, Koochiching, Lake, and St. Louis
Counties) and Douglas County, WI. Implant data is now available for
the year 2009 and would give a more current assessment of the
economic impacts. The BBER Report states that in 2007
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Minnesota's non-ferrous mining (copper/nickel explorati