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.
Friends of the Boundary Waters Wilderness
401 North Third Street, Suite 290
Minneapolis, MN 55401
612-332-9630

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, longlasting 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 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.
Friends of the Boundary Waters Wilderness
2
401 North Third Street, Suite 290
Minneapolis, MN 55401
612-332-9630

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 companys 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.

Friends of the Boundary Waters Wilderness

401 North Third Street, Suite 290
Minneapolis, MN 55401
612-332-9630

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.
Friends of the Boundary Waters Wilderness
401 North Third Street, Suite 290
Minneapolis, MN 55401
612-332-9630

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 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 (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
Friends of the Boundary Waters Wilderness
401 North Third Street, Suite 290
Minneapolis, MN 55401
612-332-9630

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 EAs 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
Friends of the Boundary Waters Wilderness
6
401 North Third Street, Suite 290
Minneapolis, MN 55401
612-332-9630

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 Bs 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 EAs
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 projects 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
Friends of the Boundary Waters Wilderness
7
401 North Third Street, Suite 290
Minneapolis, MN 55401
612-332-9630

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 beTherefore, 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 EAs 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:
Friends of the Boundary Waters Wilderness
401 North Third Street, Suite 290
Minneapolis, MN 55401
612-332-9630

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 projects impacts as it is connected to lease renewals,
Friends of the Boundary Waters Wilderness
9
401 North Third Street, Suite 290
Minneapolis, MN 55401
612-332-9630

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 projects 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 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 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 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?
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
Friends of the Boundary Waters Wilderness
10
401 North Third Street, Suite 290
Minneapolis, MN 55401
612-332-9630

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
betsy@friends-bwca.org

Friends of the Boundary Waters Wilderness

401 North Third Street, Suite 290
Minneapolis, MN 55401
612-332-9630

11