Thanks to the Midwest Environmental Activists and the Sierra Club for their assistance.
Good Morning:
On behalf of the Penokee Hills Education Project (PHEP) and Savethewatersedge.com I want to submit the following comments regarding the GTac Sample Permit. PHEP and Savethewatersedge.com truly appreciates the efforts of the DNR staff to respond to the many issues that have raised and we acknowledge and appreciate the many experts and organizations that have contributed to these requests for base line studies.
Surface Water
• Location, names and baseline water quality and aquatic habitat data for all surface waters (streams, rivers, wetlands) within 1,000 feet of site footprint
• Location of any springs within 1,000 feet of site footprint
• Location of any drainage divide
• Details of any wetland mitigation proposed
• Provisions for erosion prevention and drainage control
• Plans for collection, treatment and discharge of any water resulting from mining
• Map demonstrating water sources, flow paths, flow rates, storage volumes, and release points
• Identification of aquatic and terrestrial ecosystems such as stream orders and classifications
• Surface water hydrological computer modeling including contaminant transport
Groundwater
• Elevation of the water table
• Groundwater flow net, including horizontal and vertical groundwater flow patterns
• Any groundwater divides
• Groundwater recharge and discharge areas
• Groundwater management techniques
• Baseline groundwater quality
• Identification of all aquifers used by all public and private wells within at least 1,200 feet of the proposed mining waste site
• Groundwater modeling including contaminant transport
Air qualiy
• Plans for protecting air quality under ch. 285
• Background air quality
• Regional air quality modeling that includes mine sources such as processing, energy use and wastes
Socioeconomics
• Present socioeconomic conditions in the area
• Anitcipated socioeconomic impacts of the proposed mining project
Include tourism, employment, schools and medical care facilities, private and public social services, the tax base, and the local economy
Climate
• Climatology
• Precipitation chemistry from outside sources and from ore processing, energy use and wastes
Mining Site
• Surface topography
• Soil types
• Depth to bedrock
• Geology of underlying bedrock and unconsolidated deposits
• Existing land uses with emphasis on known recreational, historic, archaeological, scientific, cultural or scenic significance
• Nature, extent, and final configuration of the proposed excavation and mining site
• Total estimated production of tailings, waste rock, other refuse
• Nature and depth of overburden
• Sequence of mining operations
• Handling of overburden
• Production, handling, and final disposition of tailings
• Milling, concentrating, refining and other processing of ferrous minerals
• Storage, transportation and loading of final product
• Surface facilities associated with the mining site
• Geological and geotechnical investigation including geochemical characterization of wastes both short and long term
• Contaminant transport modeling for both surface and groundwater
• Plan for monitoring environmental changes at the mining site
• Risk assessment for accidental health or environmental hazard at mining site
• Where blasting is proposed and how it will be done
• Characterize and asses risk of reagents, mine mill chemicals, and processing reagent wastes
• Central location for collection and treatment of all liquid effluents for treatment and discharge
• Reclamation plan, including economic analysis of total cost and any ongoing costs
• Proposed changes to forest designations
• Alternatives to the proposed mining project and to proposal for waste disposal
• Archaeological sites
• Identification of adjacent landowners
• Proposed methods of leachate control
• Potential area to be affected in event of failure, considering land use and surrounding environment
Impacts to consider
Air: air pollution impacts, direct and indirect (from processing) – both contaminants and visibility impacts;
Water: supply issues, impacts on surface water, ground water quality and quantity, wetlands, navigable waters
Land: impacts on agricultural uses, on forest production (and secondary or indirect impacts of changes to land use – deforestation, erosion, flashiness of waters, impacts on fisheries, etc)
Impacts on tourist land uses, etc.
Transportation infrastructure needs and impacts
Energy: infrastructure needs and impacts, infrastructure (gas pipelines, transmission lines, corridors related to both)
Indirect and Cumulative impacts
Economic impacts – jobs, discouraging tourism, discouraging more sustainable development, etc.
Socioeconomic impacts - including Title VI Civil Rights issues - who benefits and who is harmed; disproportionate adverse impacts on minority and low income communities
Tribal rights – on reservation, off reservation; consultation
Cultural, historical, archeological impacts
Wildlife, endangered species
Impacts on public lands, recreational resources, other unique features – impact on prior state and federal spending to preserve some of these and other resources
Noise What will be the decibel range for the explosives that may be used during the Bulk Sampling process? How will these compare to the actual mining if it is permitted?
Visual impacts What are the plans to restore the Bulk Sample sites? If GTac uses older Bulk Sample sites, will GTac be required to restore these sites?
Meteorological impacts – (Penokee hills may alter the temperate fog forest nature and extremely high forest productivity of the lower forestlands north of the hills)
Thank you,
Frank Koehn