On Friday, August 15, at 9:00 AM the International Lake of the Woods Basin Water Quality Plan of Study Team will hold a public meeting at the Vermilion Community College Theater in Ely to take comments on the Draft Water Quality Plan of Study (“POS”). The International Joint Commission (“IJC”), which is a body created by the governments of Canada and the United States to advise on issues affecting the boundary waters from coast to coast, ordered the preparation of the POS. Please attend the meeting and provide comments on the POS to the Study Team. The Study Team intends to create the best-possible POS, and views thoughtful public comments and criticism to be essential.

The POS proposes many research and information-gathering projects to deal with three major challenges to the water quality in the Rainy River-Lake of the Woods Basin: (1) nutrient enrichment and harmful algal blooms; (2) aquatic invasive species; (3) surface and groundwater contamination, including heavy metals and other contaminants. Our concerns about the impact of sulfide-ore mining in the watershed of the Boundary Waters Wilderness relate to item 3.

We have provided below a link to the POS. Part 3.4 of the POS, beginning at page 72, deals with contamination. We suggest that you consider the following issues in preparing comments:

–Copper nickel mining in sulfide ores is proposed along and under the South Kawishiwi River and Birch Lake, and in other areas within the Superior National Forest in the Rainy Headwaters (most of the U.S.-side watershed of the Boundary Waters Wilderness–including the extensive potential mining areas south and southeast of Ely–lies within the Rainy Headwaters). At least nine different projects are in various stages of exploration and other work preliminary to mining.

–Time is of the essence. Mining company activity is already having an impact within the Rainy Headwaters. Exploratory drilling activity, including the clearing of forested drill sites and associated road-building, has impacted groundwater and the terrestrial landscape that sustains groundwater. Withdrawal of surface waters for use in drilling impacts aquatic ecosystems.

— At various points, with respect to mining the POS refers to monitoring; safeguards; and treatment, mitigation, and reclamation technology. It is important that the study team avoid the implication that mining is an acceptable activity as long as monitoring, safeguards, and the rest meet some as-yet-undetermined standard. The study team and the work forwarded to policy-makers should acknowledge the possibility that sulfide-ore mining, even if performed to the highest standards in all respects, is an inherently dangerous activity that should not be allowed in the Basin. The recent Mount Polley Mine tailings basin disaster is a case in point.

–The POS should include a recommendation that the IJC ask the United States Forest Service (in the Department of Agriculture) and the United States Bureau of Land Management (in the Department of the Interior) to conduct broad environmental analysis, in the form of a programmatic environmental impact statement, on the impact that multiple copper/nickel sulfide-ore mines in the watershed of the Boundary Waters Wilderness in the U.S. would have on water in the Rainy River Basin. The POS should also ask the IJC to seek similar environmental analysis from the appropriate provincial and Canadian governmental entities.

–Major mining projects require vast amounts of electricity. The POS should consider the impact of additional power plants in the region.

–The POS uses the word “balance” to describe the work of the “Annual Mining Effects Science Workshop” (p. 79). The concept of “balance” is perilous. Accuracy and effectiveness are far more important than balance. All legitimately interested organizations and persons should have an opportunity to provide information, but the team should not fall into the trap of assigning equal value to all information presented. Not all “science” is of equal merit; experience and judgment must be used to consider the quality and completeness of the work, and the underlying motivation of the presenter.

–The POS should emphasize action based on its work. The POS should not just dispassionately report to the IJC the results of the projects; it should include a mechanism for specific recommendations to the IJC.

In addition to attending the public meeting, please consider submitting written comments as follows:

Online, at the Study’s website: ijc.org/en_/LWBWQPOS

In writing, to the Lake of the Woods Basin Water Quality Plan of Study Team:

Canadian Section Office
International Joint Commission
234 Laurier Ave. W.
22nd Floor
Ottawa, ON
Canada K1P 6K6

United States Section Office
International Joint Commission
2000 L Street NW, Suite 615
Washington, DC
USA 20440

Link to Study: ijc.org/en_/LWBWQPOS