twin metals well ea comments, 11/2015

Friends of the Boundary Waters Wilderness 401 North Third Street, Suite 290

Minneapolis, MN 55401 612-332-9630

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Brenda Halter, Forest Supervisor Attn: Matt Judd; TMM Hydrogeologic Study EA Comments Superior National Forest 8901 Grand Avenue Place Duluth, MN 55808 November 2, 2015 Dear Supervisor Halter, Please accept these comments on behalf of Friends of the Boundary Waters Wilderness (“the Friends”) regarding the Twin Metals Hydrogeological Study, Special Use Permit Environmental Assessment (EA). The Friends appreciates this opportunity to provide input. The mission of the Friends of the Boundary Waters Wilderness is to protect, preserve and restore the wilderness character of the Boundary Waters Canoe Area Wilderness and the Quetico-Superior Ecosystem. We have about 3,000 members in Minnesota and across the United States, and regularly communicate with about 25,000 supporters through our communications channels. The Special Use Permit (SUP) sought by Twin Metals for this study would involve the construction of up to 13 hydrogeologic well pads for the purpose of collecting baseline environmental information about groundwater and surface water flow, quality and connectivity. But as the scoping documents note, the project includes construction of additional well pads on adjacent lands under the authorization of the State of Minnesota and the Bureau of Land Management (BLM). Together, Twin Metals proposes drilling nearly 400 wells, most within the area between Birch Lake and the Boundary Waters Canoe Area Wilderness. As we noted in our comments on the scoping materials for this proposed project, the Friends values the collection of important information to better understand environmental conditions and functions before resource extractive projects move forward. We agree that a good understanding is lacking about groundwater and surface water conditions, connectivity and flow in the South Kawishiwi area of interest to Twin Metals.


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Nevertheless, the Friends has significant concerns about this project which we outline in this letter. In particular, we find this EA fails to address two critical issues raised in our scoping comments:

1. The project is designed to gather and study information that is intended to lead to the development of a mine. The appropriateness of a mine in this location has not been evaluated. Indeed, the Friends and many others who commented during scoping raised significant concerns about developing a mine in this location.

2. Cumulative effects from this project in conjunction with other past, current and anticipated drilling in the area, including the entire Twin Metals’ well drilling program, have not fully been evaluated in this EA.

Given these and the other issues we outline in this letter, we believe the Superior National Forest should select the “No Action Alternative” (Alternative C) for this proposed project. I. Project Is A Connected Action To A Future Mine Before approving this study or additional mineral exploration, the Forest Service should review whether a sulfide mine is even appropriate for this location. Were it not for the interest Twin Metals has in developing a copper-nickel sulfide mine, this project would not be proposed. The area proposed for the hydrogeological drilling currently has a recreational emphasis. The Forest Service itself has designated portions of the area to be managed in ways radically different from mineral development. The Hydrogeological project area includes Forest Service campgrounds, a wilderness outdoor camp, private cabins, tourist resorts, and wilderness guide businesses. In addition, the Boundary Waters Canoe Area Wilderness (BWCAW) is adjacent to the proposed project/potential mine. And yet, the Forest Service has not analyzed the long-term potential impacts from extracting ore in this location. Mineral development in this area, whether underground or open pit, will bring significant, long-lasting changes to an area valued for its natural conditions, clean water, and quiet setting. Surface waters in the area flow into the BWCAW. Sulfide mining has a track record across the nation of polluting surface and ground waters, even in areas far drier than the Superior National Forest. While the Friends appreciates Twin Metals’ stated commitments to preventing water pollution, mineral development of this region brings the risk of contaminating waters that are valued for recreation and fishing, and that flow into the most popular wilderness area in the country (more than 250,000 visitors per year visit the BWCAW from across the country and world). Polluted waters and drilling and blasting noises from mines are not what visitors to the area and to the Wilderness expect. The Forest Service needs to determine what general impacts would occur from establishing a mining district in the heart of this recreation area before approving activities for the expressed purpose of facilitating that development. It needs to assess if mineral development is compatible with or in the best interests of the area’s tourism and recreation economy or the preservation of wilderness character and recreation values. While evaluating the detailed impacts of a Twin Metals mine is not possible until a mine plan has been developed, the Forest Service can assess existing uses and values, wilderness adjacency and potential impacts, and the known and expected mining activity impacts from other forests in other states. The U.S. Environmental Protection Agency’s evaluation of the proposed Pebble Mine in its “Assessment of Potential Mining Impacts” is an example of how this more general analysis, using available data, can be done.


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In the response to scoping comments attached to the EA, the Forest Service notes that it does not believe this project is a connected action to a future mine, given that a mine proposal has not yet been developed. We believe this argument undercuts sound resource planning and management. We also believe it is inconsistent with how the Center for Environmental Quality (CEQ) regulations define what a connected action is:

(a) Actions (other than unconnected single actions) which may be: (1) Connected actions, which means that they are closely related and therefore should be discussed in the same impact statement. Actions are connected if they: (i) Automatically trigger other actions which may require environmental impact statements. (ii) Cannot or will not proceed unless other actions are taken previously or simultaneously. (iii) Are interdependent parts of a larger action and depend on the larger action for their justification. (2) Cumulative actions, which when viewed with other proposed actions have cumulatively significant impacts and should therefore be discussed in the same impact statement. (3) Similar actions, which when viewed with other reasonably foreseeable or proposed agency actions, have similarities that provide a basis for evaluating their environmental consequences together, such as common timing or geography. An agency may wish to analyze these actions in the same impact statement. It should do so when the best way to assess adequately the combined impacts of similar actions or reasonable alternatives to such actions is to treat them in a single impact statement. 40 CFR 1508.25

Parts (a)(1)(iii) and (a)(3) describe conditions which apply to this proposed project and its connection to the development of a mine. This project is intended to be part of a larger action and is dependent upon the larger action (the development of a mine) for its justification. So too, the development of a Twin Metals mine could be seen as a reasonably foreseeable action, given the presence of a Twin Metals office in Ely, the company’s extensive drilling program, and the publication of its prefeasibility study. The Forest Service should evaluate and determine if mineral extraction at this location is sustainable and in the best interests of the public and the resource before deciding on activities intended to lead to the development of a mine. We ask the Forest Service to reconsider this project as a connected action to the development of a future mine and conduct the appropriate evaluations. Recommendation: Consider this project a connected action to the development of a future mine in this location, and evaluate whether this area is appropriate for a mine and the potential impacts from mineral development. The evaluation of these as connected actions should be conducted as part of an Environmental Impact Statement.


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II. Renewal of Twin Metals’ Mineral Leases Not Approved Twin Metals ability to contemplate mineral development in this area is based upon their acquisition of two historic mineral leases (MNES-1352 and 1353) from the Bureau of Land Management (BLM) dating back to 1966. But these leases expired January 1, 2014, almost two years ago. The BLM is currently evaluating the renewal request, but has not yet issued a decision. In addition, the BLM is evaluating whether a decision to renew the leases would also involve conducting environmental review for potential impacts. These leases have never been evaluated for their potential environmental impacts, having been issued prior to the requirements of the National Environmental Policy Act. Such leases today would be subject to environmental review. CEQ regulation definitions of connected actions suggest that this proposed project must be seen as linked to the renewal of the Twin Metals leases (40 CFR 1508.25). The decision being deliberated by the BLM regarding the Twin Metals leases is a reasonably foreseeable action by a federal agency. And, the well drilling project is justified by Twin Metals’ claim on retaining the leases. A decision about proceeding with the proposed hydrogeological well drilling project should not be made before it is determined that Twin Metals’ leases will be renewed and/or the potential impacts from leasing the minerals in this location. Recommendation: Decisions about this project should not move forward until the BLM has determined if Twin Metals’ leases will be renewed, if new stipulations will apply to these leases, and until any required environmental review has taken place for the lease renewals. The hydrogeologic well drilling project and the renewal of the Twin Metals leases should be considered connected actions and evaluated together. III. Incomplete Cumulative Effects Analysis The project EA notes that while this proposal is for 13 hydrogeologic wells pads, the entire Twin Metals well drilling project, much of which is on non-Forest Service land, includes 116 new well pads. This represents nearly 400 individual wells that would be drilled in the area. The EA emphasizes that the Forest Service has taken this broader drilling program into account in its cumulative effects analysis:

1. “…the Forest Service does consider the impacts of Twin Metals’ entire hydrogeologic program activities on other ownerships and on State or private minerals within the project area in the cumulative effects analyses under each resource section of chapter 3” (EA page 6).

2. “This EA does consider and disclose the cumulative impacts of the entire hydrogeologic study in chapter 3. Twin Metals hydrogeologic program is described in appendix A” (EA page 9).

3. Referring to impacts to threatened or endangered species: “The impacts of these activities, however, are considered in the cumulative effects analysis for the SUP EA” (Biological Assessment page 6).

But the cumulative effects analysis is either incomplete or inadequately described in the EA, particularly for effects on wildlife and groundwater.


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Inadequacy of Chapter 3 The EA identifies Chapter 3 as the place where cumulative effects of the entire Twin Metals hydrogeologic well drilling program are described – under each resource section. But one of the Friends’ biggest concerns about impacts is not addressed in this chapter at all. In our scoping comments, the Friends noted that:

“The proposed project, including the portions under the authority of the State of Minnesota and the BLM, would result in almost 400 new wells drilled into the bedrock of this area. This would be a significant amount of drilling in an area that has experienced large-scale drilling since the 1960s, particularly in recent years. The 2005 Natural Resources Research Institute (NRRI) Technical Report, “A History of Copper-Nickel and Titanium Oxide Test Pits, Bulk Samples, and Related Metallurgical Testing in the Keweenawan Duluth Complex, Northeastern Minnesota” (attached with these comments) describes this significant drilling history. “Over 2,100 holes have been drilled into the Duluth Complex....” (page 11). The report notes that in the South Kawishiwi area, “there were about 780 drill holes…as of this writing” (page 11). Subsequent to this report, extensive drilling in the South Kawishiwi area has continued. In 2007, the Superior National Forest approved the Kawishiwi Minerals Exploration Project, authorizing drilling on up to 74 sites, with each site potentially containing multiple drill holes. In 2012, the Superior National Forest approved the Federal Hardrock Prospecting Permit Project, authorizing drilling on 29 sites, with each site potentially containing multiple drill holes. At the same time, extensive drilling in the area on state and private lands has occurred. The number of drill holes in the South Kawishiwi area is now much higher than 780, potentially significantly higher.

The Forest Service does not know what impacts may result from so much drilling in this targeted area. Has the drilling resulted in additional bedrock fracturing, and if so, how much? What is the capacity of the region to sustain additional drilling? The cumulative effects of past and proposed new drilling need to be analyzed before approving more” (Friends of the Boundary Waters Wilderness 2013 Scoping Comments).

Chapter 3 contains no analysis of the potential impact to groundwater from past drilling or the proposed plan in combination with Twin Metals’ entire hydrogeologic well drilling program. The EA asserts that “the proposed well drilling activity would have less effect than these core holes because drilling methods have less impact than the coring method” (EA page 88). This is not an evaluation of cumulative impacts, only a comparative assessment. The EA notes that the Minnesota Department of Health has not received reports of groundwater problems in the area, and uses this to conclude that drilling has not had a cumulative impact. However, the absence of reported groundwater quality problems to the Minnesota Department of Health is not a substitute for a cumulative effects analysis. Additionally, the Forest Service dismisses concerns about the cumulative impacts of historic and current drilling in its responses to comments in Appendix H. “No evidence nor expertise from the Forest Service indicate drilling has caused bedrock fracturing” (Appendix H page 28). But the Forest Service does not reveal if they have engaged expertise or collected evidence that suggests bedrock fracturing has not occurred and should not be a concern. The Friends is unaware of any scientific investigation that has explored this question. The EA should either reveal the information the Forest


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Service is using to eliminate this issue as a concern, or conduct the investigation to assess if fracturing bedrock from drilling has occurred or is likely to occur. Chapter 3 also contains no cumulative effects discussion for terrestrial or aquatic wildlife species. Some terrestrial species are evaluated in the Biological Assessment (BA) and the Biological Evaluation (BE) (Appendices F and G), but there is no discussion in the EA’s Chapter 3. And, as we note below, the BA and BE also fail to adequately describe cumulative effects. Recommendation: Address the concern of past, present and future drilling for its potential to fracture bedrock and create a broader impact than the 13 well pads in this proposal. Chapter 3 should contain discussion about cumulative effects for wildlife species, even if it is a summary of what can be found in the BA and BE. Biological Assessment and Biological Evaluation Are Inadequate When the Friends turned to the BA and BE to understand the cumulative effects analysis for wildlife species, we had a difficult time finding this information as well. The BA indicates that it included an analysis of the entire Twin Metals hydrogeologic well-drilling program, beyond just the 13 well pads under consideration in this EA.

“In addition to the proposed hydrogeologic activities authorized under the SUP, TMM will conduct hydrogeologic field activities on other portions of the SNF and on State and private lands within the Birch Lake/Kawishiwi River area… The impacts of these activities, however, are considered in the cumulative effects analysis for the SUP EA. Additional details about these activities can be found at: http://www.fs.usda.gov/project/” (BA pages 5-6).

But when we read the BA and look at the data presented, it appears to the Friends that the evaluation is limited to just the potential impacts from the 13 well pads. When we clicked on the link provided for more details, it took us back to the list of EA documents, rather than to a specific document that outlined the cumulative effects analysis for Twin Metals’ entire hydrogeologic program. The EA refers readers to Appendices A and B for an understanding of the entire Twin Metals’ program and actions relevant to the cumulative effects analysis. These too failed to provide the information. Appendix A provides a list of all of Twin Metals’ well pads, but no information to understand what their collective impacts might be. Appendix B describes minerals management on National Forest System lands, but seemed to us to omit the other 103 hydrogeologic wells in Twin Metals’ plan. The only mention of these wells was, “Twin Metals hydrogeologic program activities outside of the proposed action will occur on leases, prospecting permits, State and private lands pending authorizations (if required). A full description of this project is contained in Appendix A and is considered in Chapter 3 cumulative effects sections” (Appendix B page B-5). But, as noted, Appendix A does not provide cumulative effects information, and Chapter 3 fails to describe cumulative effects for wildlife species at all. In the Biological Assessment, under a heading marked “Cumulative Effects” for Canada Lynx, the BA notes, “The addition of the proposed hydrowells to currently forested areas would not result in a


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significant cumulative increase in the fragmentation of lynx habitat” (BA page 25). This statement seems to refer solely to the 13 well pads. The BA also notes, “It can be reasonably expected that the addition of 13 well pads, 1.52 miles of temporary access roads, as well as the temporary nature of the activities associated with the proposed construction and monitoring of wells, will likely have a temporary and negligible negative effects on lynx and on the Primary Constituent Elements of lynx habitat” (BA page 26). This is not an evaluation of the cumulative effects of Twin Metals’ whole program, but of the impact of this limited 13 well pad project. In addition, as noted below, the BA discussion for the Gray Wolf, contradicts this assertion that road building and forest fragmentation has no cumulative effect on habitat. The data shown in the BA also appear to evaluate just the 13 proposed well pads. Other than a map that shows Lynx Analysis Units and Twin Metals’ drilling program, the BA does not discuss or present data that include an evaluation of the entire 116 well pad program. If the BA conducted this analysis, it is not presented for the public to evaluate or understand. The same is true for the other species discussed in the BA. There does not seem to be a true cumulative effects analysis for the entire Twin Metals drilling program for the Northern Long-eared Bat or the Gray Wolf. The BA discusses the potential for future mineral prospecting on federal lands to impact habitat for the Northern Long-eared Bat, but it does not reveal data or analysis for the Twin Metals program as a whole or cumulative impacts when this program is evaluated with past drilling. The Biological Evaluation of Regional Forester Sensitive Species (BE) makes no mention that we could find of evaluating impacts of Twin Metals’ entire drilling program. The discussion in this document seems to be limited to assessing the impact of the 13 well pad project alone. The BE refers to Appendix B’s list of minerals management projects to take into consideration, but it seems to the Friends this list does not include the Twin Metals full hydrogeologic well drilling program. If the BE involved a full evaluation of this entire program, it is not clear to the Friends or to the general public. Recommendation: The EA asserts that the cumulative effects analysis of this project includes an assessment of Twin Metals’ entire hydrogeologic well drilling program. It is not clear from the EA or its supporting documents that this evaluation has been done. If it has not, the cumulative effects evaluation is incomplete and should be conducted before further decisions are made about this project. If the work has been done, this needs to be presented clearly so that the public can evaluate its results. The EA’s cumulative effects analysis should also include an evaluation of the Twin Metals program (entire) when combined with past and foreseeable future projects. Without that evaluation, it is impossible for the public to understand how this limited project’s impacts may combine in significant ways with other drilling. Noise Impacts Analysis Incomplete The EA does not adequately describe the cumulative effects analysis for impacts to wildlife and human use from noise due to drilling activities. The EA acknowledges that the broader drilling taking place on federal, state and private lands may combine and overlap in time to create a larger impact: “It is likely that sounds from drilling on reserved and private minerals on Federal land, and drilling on State and private land, may occasionally overlap with sounds from drilling for Federal minerals on Federal land. When drilling sites are very close together, up to 3 to 4 dBA may be added


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to the total level of sound” (EA page 51). But then, in the next sentence, it refers once again to just the 13 well pad proposal, noting that “However, no SUP drilling sites are located within 500 feet of other proposed drilling, nor are they likely to be…Therefore, cumulative increases in sound level are very unlikely to occur” (EA page 51). After stating that simultaneous drilling on multiple ownerships in the same area might increase the noise experienced, the EA once again dismisses the potential for cumulative effects by only focusing on the 13 well pads proposed – and since none of them will be close to each other, the EA concludes there is little risk of cumulative impacts. The cumulative effects analysis should, instead, assess the potential for close and simultaneous drilling on all ownerships, and then analyze what this impact may have for recreation, businesses in the area, private landowners, and certainly wildlife. But the analysis for wildlife is not to be found. The BA assessment for Canada lynx concedes noise from drilling activities is expected:

“One of the disturbances resulting from the implementation of the SUP is noise. Noise would be produced by a variety of vehicles and machinery during the installation of roads, pads, hole drilling, and hydrological testing…. The effects of noise on lynx and their prey are not known but given that lynx generally avoid areas with human activity, it can be reasonably assumed that lynx will avoid areas with persistent human-caused noise” (BA page 25).

But the BA, rather than analyzing what this impact might be from close and simultaneous drilling in a geographic area that is part of designated lynx critical habitat, once again focuses on the impacts from the more limited 13 well pad program:

“It can be reasonably expected that the addition of 13 well pads, 1.52 miles of temporary access roads, as well as the temporary nature of the activities associated with the proposed construction and monitoring of wells, will likely have a temporary and negligible negative effects on lynx and on the Primary Constituent Elements of lynx habitat” (BA page 26).

Given that, as the BA notes, lynx will avoid areas with human activity, it is important to understand what persistent and proximate drilling across multiple ownerships might mean for lynx and other listed wildlife species. While the 13 well pads drilled in isolation might not result in negative impacts, when combined with other past and current drilling in the same area, it may result in unacceptable cumulative effects. It is not clear in this EA that this evaluation has been conducted. Recommendation: The EA’s noise evaluation must assess the cumulative impacts from drilling across multiple ownerships, including the entire Twin Metals hydrogeologic program, on wildlife and human use of the area. Roads-Fragmentation Analysis Incomplete The EA does not adequately analyze the cumulative effects of temporary road building and forest fragmentation on wildlife, particularly on Canada Lynx and Gray Wolf. The EA concedes that extensive road building has occurred in the project area already, and the rate of road building is outpacing forest regeneration:


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“The growth in the network of temporary roads, particularly east of Birch Lake, is readily visible on a time series of aerial photographs. While habitat continuity is restored by forest regeneration about 10 years after temporary roads are decommissioned, aerial photographs show that the addition of temporary roads for mineral exploration and logging exceeds the rate of forest regeneration resulting in an apparent net increase in forest disturbance and habitat fragmentation. These roads increase human activity in the forest which may have detrimental effects on wildlife, especially for gray wolves that are particularly vulnerable to poaching and road mortality” (BA page 29).

While this wolf discussion starts an important evaluation of this project in the context of broader drilling and road building in the area, the discussion for the lynx reverts back to the limited scope of the 13 well pad project: “The addition of the proposed hydrowells to currently forested areas would not result in a significant cumulative increase in the fragmentation of lynx habitat” (BA page 25).

The BA discussion for both lynx and wolf conclude with disappointing statements that make it clear a cumulative effects analysis for these species was not conducted and was not considered part of the scope of work for this EA:

“…it should be noted that at some future point the addition of mineral development infrastructure to the landscape may exceed forest regeneration of decommissioned temporary roads and mineral exploration pads, resulting in cumulative net increase in lynx habitat fragmentation and loss” (BA page 25).

“While it is beyond the scope of this document to quantitatively analyze these changes in the landscape and their potential impacts on wolves, such an analysis is warranted in order to better predict the impact of large scale mineral exploration on wolves” (BA page 29).

The Friends believes such an analysis is warranted and should be part of the scope of work within this EA. Without it, the public and Forest Service resource managers cannot know if this project will combine in a significant, negative fashion to impact lynx, wolves and other wildlife. Recommendation: The EA needs to evaluate the cumulative effects of temporary road building and forest fragmentation on wildlife from this proposed project when combined with recent, current and anticipated mineral activities in the area. Wilderness Protection Needed From Connected Actions The lack of a complete cumulative effects analysis puts the Boundary Waters Canoe Area Wilderness at greater risk for impacts. If smaller, isolated actions are not analyzed as part of a more comprehensive assessment of related actions, the risk is that each action by itself fails to reveal significant impacts, when together they might. The EA does not help the public discern if water quality issues or noise impacts from past, current and expected mineral activities separate from this proposed project could impact the BWCAW when combined with this project. Court decisions have recognized the need to evaluate cumulative impacts from many separate actions rather than focus solely upon the impacts of each single action (e.g. Conner v. Burford, Bob Marshall Alliance v. Watt). The Forest Service needs to assess this project’s impacts as it is connected to lease renewals,


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other hydrogeologic well drilling, and other exploratory drilling for potential impacts they have collectively on the BWCAW. Recommendation: Conduct a comprehensive analysis of mineral activities (past, current, expected) of potential impacts to the BWCAW, instead of viewing and analyzing each of these activities separately. IV. Selection of Alternative B While the Friends believes it is premature to advance this project, we do believe that if it should proceed, the best efforts to minimize this project’s disturbance should be taken. Alternative B outlined in the EA does a much better job at mitigating noise disturbance to the surrounding area than does Alternative A. The mitigation approaches in Alternative B should be implemented. Recommendation: Noise mitigating efforts outlined in Alternative B should be implemented if this project proceeds. The EA provides evidence that human noise has impacts on protected species that justify the additional noise mitigation measures described in Alternative B. V. Project Information and Conditions Necessary The hydrogeologic project’s goal is to collect information that will lead to a better understanding of water movement, quality and connectivity. An extensive drilling effort is proposed. The Forest Service should insist that more details about the project and its rationale are provided by Twin Metals. For example, is this number of wells necessary to answer the company’s questions or could fewer still meet the goals? Will the locations of the wells, the well designs and the tests adequately answer the company’s questions? In addition, the Forest Service should require that Twin Metals make the hydrogeological data publicly available. These are public minerals being extracted under public lands, with potential impacts to other public resources. It is reasonable to ask the company to share the information gleaned from the project with the public. Recommendation: The Forest Service should require explanations from Twin Metals for the scope of the proposed project and how the project will meet its goals. The Forest Service should require that the data collected from this proposed project be made publicly available. VI. Monitoring

Monitoring efforts and resources are needed if significant impacts from this project and projected future projects are to be avoided. Monitoring details are needed for use of local water sources, noise impacts, impacts to sensitive and federally listed species, soil and water impacts, and non-native invasive species introductions and spread. Appendix D notes that, “Monitoring of activities would be


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implemented while the special use permits are active, during and after reclamation where specifically stated. Monitoring would occur as permitted by personnel, budget and time available” (Appendix D page D-21). The Forest Service will need to commit to consistent, regular monitoring to ensure resources are not being significantly impacted.

Recommendation: The Forest Service needs to commit adequate resources to a monitoring effort to ensure negative impacts do not occur and that operations are conducted as planned. The Friends appreciates this opportunity to comment on this project. We urge the Forest Service to view and analyze this project as a component of a mineral development initiative, and not as an isolated, unrelated effort. Please let me know if you have any questions about our comments. Sincerely,

Betsy C. Daub Policy Director Friends of the Boundary Waters Wilderness 401 North Third Street, Suite 290 Minneapolis, MN 55401 [email protected]

twin metals well ea comments, 11/2015

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