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Brenda Halter, Forest Supervisor Attn: TMM Hydrogeologic Study Comments Superior National Forest 8901 Grand Avenue Place Duluth, MN 55808 November 20, 2013 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 Application scoping process in preparation of an 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 10,000 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. 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.

Nevetheless, we have concerns about this project, both specific to its implementation, and related to a mine to which the study is intended to lead. Below we outline issues we believe the Forest Service should address in its analysis and offer recommendations.

Analysis of Sulfide Mine Location Needed: The hydrogeological study proposed by Twin Metals is intended to provide important information to be used in developing a sulfide mine proposal for the South KawishiwiBirch Lake area. Should a mine be developed, a much better understanding of ground and surface water issues is essential. However, the Forest Service has not analyzed the long-term potential impacts from extracting ore in this location. Before approving this study or additional mineral exploration, the Forest Service should review whether a sulfide mine is even appropriate for this location. 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 Boundary Waters Canoe Area Wilderness (BWCAW) is adjacent to the proposed project/potential mine. The 1964 Wilderness Act defines wilderness as:
A wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain. An area of wilderness is further defined to mean in this Act an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and managed so as to preserve its natural conditions and which (1) generally appears to have been affected primarily by the forces of nature, with the imprint of man's work substantially unnoticeable; (2) has outstanding opportunities for solitude or a primitive and unconfined type of recreation; (3) has at least five thousand acres of land or is of sufficient size as to make practicable its preservation and use in an unimpaired condition; and (4) may also contain ecological, geological, or other features of scientific, educational, scenic, or historical value (1964 Wilderness Act).

Pollution and noise are real risks to the BWCAW from mineral-related activities and development near the Wilderness. These impacts degrade wilderness character and threaten the protections the Act sought to confer. Portions of the area outside the BWCAW are designated as "Recreation Use in a Scenic Landscape." In the Federal Hardrock Prospecting Permit EIS, an analysis that examined mineral exploration in this same area, the Forest Service noted that "Dispersed recreation activities occur on most lakes, roads, and trails. Popular dispersed recreation activities in the Project Area include fishing, camping, boating, hunting, scenic driving, hiking, canoeing, berry picking, all terrain vehicle use, skiing, dog sledding and snowmobiling...There is a research and natural area and a unique biological area..." (Federal Hardrock Prospecting DEIS; page 74). The Hydrogeological project area includes Forest Service campgrounds, a wilderness outdoor camp, private cabins, tourist resorts, and wilderness guide businesses.

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 carries the very real 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 preparing for that development. It needs to assess if mineral development is compatible with or in the best interests of the areas 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 Agencys 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. Recommendation: The Forest Service needs to conduct an analysis of the appropriateness of a sulfide mine in the area covered by the hydrogeological study before approving this proposal or other mining development-related activities.

Cumulative Effects Analysis Historic and Proposed Drilling 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 holesas 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. Recommendation: The Forest Service needs to conduct a cumulative effects analysis of past and proposed drilling in the South Kawishiwi area to determine what the capacity of the region is for additional drilling. This should include drilling that has or is taking place on lands not under Forest Service jurisdiction.

Water Consumption and Wetlands The projects scoping documents note that for drilling, Appropriations of groundwater or surface water may require a water appropriations permit from the MDNR (Special Use Permit Application; page 64). The documents note that water may be taken from streams or water bodies in the area. It is not clear from the scoping materials what the anticipated amount of water need is for the project. The Federal Hardrock Prospecting Permit EIS noted that exploratory drilling well pads can use as much as 2,000 gallons of water a day. The Forest Service should insist on knowing how much water is expected to be taken from local sources, and which water bodies those are. A complete understanding of potential wetlands impacts is needed. Without more information, neither the Forest Service nor the public can know if multiple drilling plans would pull from the same water source or result in wetlands impacts. Additionally, a robust monitoring effort will be needed to ensure water sources are not being depleted. Recommendation: The Environmental Assessment needs to analyze potential impacts from using local water sources for drilling operations, how much water will be used, and which water bodies will be used. Impacts to wetlands should be assessed. The EA needs to provide a plan for sufficient monitoring efforts to prevent water body drawdowns or other impacts.

Noise Impacts The SUP Application states that drilling activity will take place over several months, with each borehole requiring approximately two to four weeks of continual drilling at each well pad. Drilling would occur on a 24-hour schedule. The documents do not describe anticipated noise levels from increased traffic from drilling vehicles. The Forest Service needs to understand what the noise impacts will be and what impact this noise would have in the BWCAW and in the rest of the project area where people are recreating. Although temporary, drilling noise differs in important ways from other temporary noises at the edge of the Wilderness (such as a timber harvests): 1). Drilling continues twenty-four hours a day for as weeks at a time, creating noise that is

unrelenting and with greater impact to the listener than would a timber harvest. 2). The intent of drilling is to lead to the development of a mine. A mine would bring a permanent source of noise into the Wilderness and surrounding recreation areas. If noise from this drilling and its associated traffic can be heard in the region, noise from fullscale mining will be worse. Drilling, heavy equipment, helicopters, and blasting are not acceptable noises to be added to a wilderness area. The Federal Hardrock Prospecting Permit Project anticipated 192 mining exploration operating plans over the next 20 years in this region. This is just a calculation of mineral activity on federal land with federal minerals. It is recognized that additional mineral exploration is taking place and will continue to develop on federal lands with non-federal minerals, as well as on non-federal lands in the same area (Federal Hardrock Prospecting Permit DEIS; page 76). Noise from mineral exploration and any future development will become a regular feature in an area valued for recreation, quietness and solitude. Recommendation: The EA needs to include a thorough analysis of the noise impacts from this project, and from simultaneous drilling from other activities on adjacent lands. It needs to include an evaluation of the impacts to the BWCAW and wilderness character. The analysis should include noise anticipated from increased drilling-related vehicles. A robust, detailed noise monitoring plan must be articulated. The Forest Service should identify a target noise decibel level, and enforce that level without providing for a variance. The EA should include a map and a description of the Area of Audibility. And, the Forest Service should not approve this project if it results in new sources of audible noise in the Wilderness given the different nature of this temporary noise and the potential for evolving into full-scale mineral development with longer lasting noise issues. Lynx and Other Wildlife The project area is within designated federal critical habitat for the federally-listed Canada lynx. Scoping documents state that some level of consultation with the U.S. Fish and Wildlife Service will take place regarding potential impacts to lynx and their habitat. The Friends is not sure what is meant by some level of consultation. Given the amount of mineral exploration, well pad road building, drilling noise and traffic that has taken place and is ongoing in this area, a full consultation under Section 7 of the Endangered Species Act is needed for this project. Potential impacts to other wildlife, especially moose, recently added as a state species of concern, will be needed in the EA as well. Risks of vehicle collisions from increased traffic should be analyzed. Recommendation: The EA should include a full Section 7 consultation with the U.S. Fish and Wildlife Service for the Canada lynx. Calculations of habitat disturbance for lynx and moose should include roads as part of that disturbance. Interpretations of why percent disturbance is or is not significant to Lynx Analysis Units should be provided and be supported by relevant research. Impacts to moose and other wildlife should be analyzed, looking at past, ongoing and future mineral-related activities.

Reveal More of Project Details and Rationale The hydrogeologic projects 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 will need to insist that more details about the project and its rationale are provided by Twin Metals and included in the EA. Are almost 400 wells necessary to answer the companys questions, or could fewer still meet the goals? Will the locations of the wells, the well designs and the tests adequately answer the companys questions? Two other conservation organizations, the Center for Biological Diversity and Northeastern Minnesotans for Wilderness, retained hydrologist Dr. Tom Myers to review the projects scoping documents. These organizations have made his reflections available to the Friends, and we include some of his thoughts here, and his full report as an attachment to this letter. Recommendations: 1. The Forest Service should determine what level of changes to the project would trigger a new analysis. Twin Metals has noted that some parts of their project may change depending on how the project unfolds. But, the Forest Service should identify what level of change would necessitate additional environmental review. For example, changes in the number of wells drilled, depth of drilling, drilling in sensitive areas. 2. The rationale for the location of wells and their designs should be provided. It will be impossible for the Forest Service or the public to understand if the wells are sited in such a way as to achieve the desired goals, if this information is not provided. The SUP application does not describe how these goals would be met (Myers; page 1). 3. The Forest Service should insist on a commitment from Twin Metals to conduct all the tests they say they are considering. As Myers notes, The SUP lists five desirable tests which may be run at each well, but does not commit to running them anywhere. Without the tests,Twin Metals will glean little value from the drilling program (Myers; page 2). 4. The Forest Service should ask Twin Metals to provide more details on the pump tests, such as the length of the tests, the pumping rates, and the discharge points for the water. Without this information, it is not possible to determine the specific impacts on the environment or the value of the tests (Myers; page 2). 5. 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. 6. Twin Metals should prepare a preliminary Conceptual Flow Model before drilling to determine if the wells are sited appropriately and that the necessary tests are being conducted. 7. Explanation for the locations of wells 1,000 feet deep need to be provided, in addition to explanations for why they are not deeper, given that the ore deposits extend to several thousand feet below ground level.

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. Recommendation: The EA needs to articulate an appropriate 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 612-332-9630 Attachments: 1. NRRI Technical Report. 2005. A History of Copper-Nickel and Titanium Oxide Test Pits, Bulk Samples, and Related Metallurgical Testing in the Keweenawan Duluth Complex, Northeastern Minnesota. 2. 2013. Myers, Tom. Technical Memorandum: Review of Special Use Permit for Hydrogeologic Field Activities Twin Metals Mining.