Moose are an iconic Minnesota animal that have declined dramatically over the last decade. Only 4,000 moose remain in Minnesota, a 50% decrease since 2005. Minnesota suspended the moose hunting season and added moose to its “Special Concern” list in 2013. This is a species that “has unique or highly specific habitat requirements and deserves careful monitoring of its status.”
That listing should trigger analysis of Polymet’s impact on moose habitat, but that analysis is lacking. Thousands of acres of moose habitat would be destroyed at the PolyMet mine site, and moose have been observed there. Protecting moose is a particular concern for tribal members, and there is no analysis of the cumulative impact on moose from the PolyMet project and other habitat disruptions.
Wild rice is Minnesota’s state grain, and a significant resource for Minnesota tribes. Even low levels of sulfates are proven to kill wild rice stands, a fact recognized by Minnesota’s protective wild rice sulfate standard. There are wild rice beds downstream of PolyMet. PolyMet must show it would not increase sulfate concentrations in these areas. However, it fails to do so.
The mine plan inaccurately describes wild rice waters, understating the area that supports stands of wild rice. In addition, the mine plan claims to reduce sulfates, but that assumes that expensive water treatment will continue for hundreds of years. Millions of gallons of untreated polluted water will escape every year, and the mine plan predicts an increased chance that water exceeding the sulfate standard will be released at times, years after closure.
Taxpayers have been saddled with huge cleanup bills when sulfide mining companies have declared bankruptcy or walked away from closed, polluting mines. Minnesota law requires PolyMet to put up “financial assurance,” a damage deposit that is supposed to cover the costs of cleaning up the site and treating pollution. However, in the PolyMet mine plan, there are no details of the amount and type of damage deposit adequate to cover the cost of treating polluted water for hundreds of years.
Minnesota has never permitted a mine that would require hundreds of years of expensive water treatment. This public comment period is the best chance for the public to weigh in on whether the financial assurance required of PolyMet would be adequate, but there is only a brief mention of it in the mine plan.
PolyMet is proposing something Minnesota has never allowed before. The company’s own computer models show that hundreds of years after the mine closes, water seeping into groundwater and flowing into streams and rivers at the site will be polluted with heavy metals and sulfates. Unless all of this water is captured and treated, the mine will pollute surrounding waters.
Minnesota law requires that a closed mine site be “maintenance free,” but PolyMet’s mine plan calls for hundreds of years of monitoring and expensive water treatment. Worse, these models don’t even show that the pollution stops after 500 years. They just stopped modeling at 500 years. In other words, the pollution could go on for even longer.
Asbestos-like fibers are in the rocks at PolyMet. The nearby Northshore Mine was required to stop dumping their tailings in Lake Superior in the 1970’s due to similar fibers. Studies show miners who worked in the Northshore and LTV mines have higher levels of mesothelioma. Extremely small fibers from asbestos-like minerals are being studied by the University of Minnesota to see if they caused some of the higher levels of mesothelioma.
PolyMet would produce mineral dust smaller than what is regulated and has been studied. It is not known if these fibers would cause harm to workers or nearby residents since they haven’t been studied adequately. PolyMet admits that “the potential exists for the release of amphibole mineral fibers from the proposed operations, which could pose a potential public health risk of uncertain magnitude.”
A computer model is at the heart of predictions about water pollution from PolyMet. A water model is a representation of how water moves around a site. The PolyMet water model assumes that there is little groundwater moving through the site. The result is that the model shows water moving very slowly, and pollutants sticking to soil instead of moving with the water.
DNR hydrology data show that the PolyMet water model significantly understates the amount of water flowing in the nearby Partridge River. If this information is wrong, predictions about water pollution are in question. If the model is incorrect, and there is more water flowing through the site than it assumes, the polluted water from pits and waste rock will move more easily through the soil, and reach lakes and rivers more quickly. The water could also carry more pollutants than the PolyMet model predicts.
PolyMet has never operated a mine before, and is dependent on their largest investor and “strategic partner” Glencore for much of their revenue. Glencore currently owns 25% of PolyMet, with the option to increase their stake to 33%. Glencore also owns the first five years of minerals produced by PolyMet if it opens.
Glencore is the world’s largest commodities company, and one of the largest global mining companies. It has a long history of environmental pollution, human rights violations, and anti-labor practices. The interim chairman of Glencore’s board is Tony Hayward, the former CEO of British Petroleum. He led BP during one of the largest oil spills in history.
PolyMet would be a huge consumer of electricity, much of it coming from the dirtiest coal power plants in Minnesota. PolyMet’s electricity supplier, Minnesota Power, got 85% of their power from coal in 2013.
PolyMet would emit 707,342 metric tons of carbon dioxide into the atmosphere every year. This would contradict Minnesota’s goal to reduce carbon emissions. The Minnesota Next Generation Energy Act set a goal of reducing Minnesota’s greenhouse gas emissions 15% from 2005 levels by the year 2015, and 30% from 2005 levels by 2025. Minnesota is uniquely vulnerable to climate change, particularly the boreal forest of northern Minnesota.
1 in 10 Minnesota newborns in the Lake Superior basin are born with unsafe levels of mercury in their blood, according to the Minnesota Department of Health. Mercury is a potent neurotoxin with no safe dose, especially for young children. Mercury pollution particularly affects people who rely on fish for a large portion of their diet. The rivers in the area are already on the Minnesota list of impaired waters for mercury, and the scientific understanding of the mercury dynamics of the St. Louis River downstream is very limited.
PolyMet would emit 4.6 pounds of mercury into the air from their operations every year, and the coal power they rely on would add even more. The PolyMet mine plan also increases mercury in the Embarrass River, and sulfate pollution from the site could increase methylmercury, the form of mercury most dangerous to people.
PolyMet proposes the largest permitted destruction of wetlands in Minnesota history. PolyMet would dig up nearly 1,000 acres of high value peat bogs, part of the 100 Mile Swamp, a critical habitat for many plants and animals. This wetland is designated an Area of High Biodiversity Significance by the Minnesota Biological Survey.
In addition, over 6,000 acres of wetlands could be damaged or destroyed by PolyMet changing the water flow. When you dig a deep hole in the ground, it fills with water. That water would come from surrounding wetlands, and could dry out and destroy them. PolyMet is required to replace lost wetlands, but they understate the area of wetlands they would affect, they fail to replace the unique habitat offered by peat bogs, and they propose replacements that are far from the mine site.
The PolyMet project could affect human health in many ways. Some of these ways are direct, such as exposure to air and water pollutants like mercury, asbestos-like fibers, and arsenic. Others are indirect, such as the impact on local communities from increased vehicle traffic and strains on health and social service infrastructure.
Health Impact Assessments (HIAs) are used in Alaska to evaluate the public health impacts of mine proposals like PolyMet. The State of Alaska has adopted HIAs as a best practice in the environmental review of mining proposals, since environmental impact statements often fail to adequately analyze the public health effects of a proposal like PolyMet. Here in Minnesota, HIAs have been used as part of the environmental review of projects like Central Corridor Light Rail.
The Canada Lynx is listed as a threatened species under the federal Endangered Species Act. There are only 200 lynx in Minnesota. Lynx have been tracked on land adjacent to the PolyMet mine site, and lynx sign have been found on the site as well. PolyMet would destroy 1,450 acres of designated critical habitat for the Canada Lynx, habitat essential to the conservation of a threatened species. Fragmentation and loss of habitat puts the survival of the Canada Lynx in jeopardy.
Additionally, an important wildlife travel corridor near the PolyMet proposal risks being lost due to mining activity, and increased truck traffic may kill lynx along the road linking the mine and plant sites. Despite this, the PolyMet mine plan fails to analyze the cumulative impact on lynx from the proposal and other nearby projects. The mine plan also fails to consider ways to mitigate the risk to lynx from road traffic.
One part of the PolyMet mine plan is an estimate of how much in taxes the mine would pay if permitted. The tax estimates in the PolyMet mine plan lack detail, are full of discrepancies and contain explained changes. From one draft of the mine plan to the next the estimated taxes jumped 500% without explanation. This is important, since the state taxes that would apply to a copper-nickel sulfide mine have never been used before.
The copper-nickel mining industry is exempt from several state and local taxes, such as property tax and corporate income tax, and has its own unique tax structure. Therefore, the State of Minnesota should confirm these tax estimates, and not just rely on the company to provide them.
Federal and state law require environmental impact statements like the PolyMet mine plan to consider a range of alternatives. That is done to ensure all reasonable options to protect the environment are considered. The law requires that all practical alternatives must be rigorously explored and objectively evaluated. But the PolyMet mine plan does not consider any alternative to their proposal other than a slightly different version of a land exchange.
There are several alternatives that should be considered and evaluated in the PolyMet mine that are simply discarded. These include whether the PolyMet proposal could operate as an underground mine instead of an open pit, and whether all of the waste rock created by PolyMet should be backfilled into the mine pits after closure.