Monday, September 29, 2014

An ounce of prevention for Poly?

Have you noticed that both the stock market and Minnesota's temperatures have been on a roller coaster recently? I can't quite figure out which is the leading and which the trailing indicator. Based on this report in Wilderness News Online, there's no such volatility in the public response (98% concerned  about or opposed to some element(s) of the PolyMet NorthMet mine proposal) to the Supplemental Draft Environmental Statement [SDEIS] on that project. Minnesota DNR hasn't even finished categorizing the 58,000 comments yet.

On the one hand, I'm glad I don't have the job of getting that project permitted. On the other hand (no, I'm not an economist), if I were charged with that responsibility, I'd want to see the project proposer be a lot more forthcoming about how the company is actually going to go above and beyond business as usual, "we will meet or exceed all regulatory requirements," and I'd want to see that happen a lot earlier in the process. At least we haven't reached the status of our neighbor to the east, where, according to the Wisconsin Citizen's Media Cooperative, Mining Industry Targets “Prove It First” Law.

Nevertheless, Minnesota has some notable limitations in its own sulfide mining regulatory framework, as described in the report "Sulfide Mining Regulation in the Great Lakes Region: A Comparative Analysis of Regulation in Michigan, Minnesota, Wisconsin & Ontario." Here's a link to the Minnesota Summary, which finds, among other shortcomings:


Minnesota’s policy goal does not necessarily require or aim for “functionality” but rather emphasizes doing the best job possible and returning the environment to the best “practicable” state:
...it is the policy of the Department of Natural Resources that mining be conducted in a manner that will reduce impacts to the extent practicable, mitigate unavoidable impacts, and ensure that the mining area is left in a condition that protects natural resources and minimizes to the extent practicable the need for maintenance.
Minn. Rules 6132.0200. The limitation provided by “to the extent practicable” is in keeping with the general policy of Minnesota’s regulation, which attempts to balance environmental protection with the promotion of economic development:
... it is hereby declared to be the policy of this state to provide for the reclamation of certain lands hereafter subjected to the mining of metallic minerals [...]to control possible adverse environmental effects of mining, to preserve the natural resources, and to encourage the planning of future land utilization, while at the same time promoting the orderly development of mining, the encouragement of good mining practices, and the recognition and identification of the beneficial aspects of mining.
Minn. Stat. §93.44.
As I read the analysis of this particular provision, my concerns about the stringency of financial assurance and long-term environmental protection are heightened. If PolyMet and it's major investors were adamant about having a very proactive environmental management system in place and operating, maybe more than 2% of the 58,000 comments might have been positive. There are enough environmental horror stories associated with international mining that its social license may be close to being expired in many places. What's that old saying about an ounce of prevention being worth a pound of cure? Here's a link to advice on sustainability from Global Mining magazine: 6 Sustainable Initiatives You Need to Implement in Your Mining Operations.

I'm just guessing here, but if the initial DEIS had truly been done proactively, could it have saved 2 or 3 years of environmental review prior to even getting to the permitting? See the Initiative about Transparency.

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