How to write a public comment!

How to write a unique public comment that makes a difference!

Personalized, unique comments submitted during the formal public comment period carry even more weight than signing a form/petition. It takes 5-10 minutes to tell the Bureau of Land Management why the Boundary Waters is not worth risking for a sulfide-ore copper mine.

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Topic ideas for your comment:

• Tell the Bureau of Land Management not to renew Twin Metals' old mining leases next to the Boundary Waters.

• Include your personal experience in the Boundary Waters region for business, recreation, hunting, fishing, etc.

• The BLM's study of lease renewal does not adequately examine the immense risks from copper mining next to the Boundary Waters, such as economic and environmental impacts.

• If you have expertise in an area like geology, botany, law etc., feel free to include your perspective and knowledge in those areas especially!

• Ask the BLM to extend the public comment period (which began right over the Christmas holidays) by at least 60 days to allow for more public and expert input.

Outline for your comment:

I strongly oppose renewal of two federal mineral leases in the Superior National Forest. I urge you to deny renewal.

[Personal story about your Boundary Waters or why the Wilderness is important to you!]

The Boundary Waters Canoe Area Wilderness, Voyageurs National Park, and the Superior National Forest are priceless to the American people and must not be exposed to damage and pollution from sulfide-ore copper mining that would be inevitable if copper mining were to occur on public lands in the watershed of the Boundary Waters.

[Facts about the Boundary Waters.]

[The negative impacts sulfide-ore copper mining would have on the Boundary Waters and the surrounding communities. See below for facts and resources.]

We urge you to:

• Not renew federal mineral leases
• Provide an extension on the comment period of 62 days to Monday, March 25th.
• Provide public meetings in Duluth, Minneapolis-St. Paul, and Washington, DC
• Prepare a full Environmental Impact Statement to analyze and assess the full range of potential negative impacts to the environment, the economy and to the American people if federal mineral leases were renewed
• Stop all mining approvals, including the renewal of federal mineral leases, until the Superior National Forest Mineral Withdrawal Environmental Assessment is completed
• Base all decisions on the best available science

Thanks,
[Your name]

Facts and resources to use in your comment:

GENERAL BOUNDARY WATERS FACTS:

• 1.1 million acres of unique canoe country

• 1,100 lakes with over 2,000 designated campsites

• 1,200 miles of canoe and kayak routes and 237.5 miles of overnight hiking trails

• Several sensitive wildlife species make the Wilderness their home, including the gray wolf, moose, Canada lynx and loon.

• Top fishing and hunting destination

SCIENCE FACTS:

• 19  SCIENTIFIC STUDIES - The Trump Administration claims that after an “extensive review,” there was no new “scientific information.” However, public record shows that 19 new studies, reports, and scientific journal articles were submitted to the Forest Service on this issue. See them here: Earthworks' Boundary Waters repository of scientific and economic studies.

• NOT ONE COPPER MINE HAS OPERATED SAFELY - In the history of sulfide-ore copper mining, no copper mine has ever operated and been closed for at least 10 years without polluting surrounding surface water or groundwater. The copper mining industry has a long and continuing history  of severe water pollution including acid drainage, heavy metals contamination, sulfates, and exceedingly high specific conductance, as well as increasingly frequent catastrophic accidents such as tailings dam failures. And even state-of-the-art mines are at risk for major infrastructure disaster. “Research shows that mines with high acid generating potential and in close proximity to surface and groundwater are at highest risk for water quality impacts.” US Copper Porphyry Mines Report, Bonnie Gestring; Earthworks.

• 500+ YEARS OF POLLUTION - Conservative models of pollution show that waterways would carry contaminants into the Wilderness. A single mine in this watershed will continually pollute the wilderness for at least 500 years¹. Tom Meyers, Ph. D. said in one of his reports, “If the sulfide mines are developed in the Rainy Headwaters, it is not a question of whether, but when, a leak will occur that will have major impacts on the water quality of the Boundary Waters Canoe Area Wilderness.”
  Learn more about the scientific research pertaining to sulfide-ore copper mining near the Boundary Waters Canoe Area Wilderness here.

ECONOMIC IMPACTS:

• 4,500 JOBS > 650 JOBS - This year, a first-of-its-kind  independent economic analysis by Harvard economists was published.  It compared the effects of the U.S. Forest Service’s proposed 20-year mining ban near the Boundary Waters, with the consequences of sulfide-ore copper mining in the Boundary Waters watershed. The authors modeled 36 employment scenarios and 72 different income scenarios comparing the proposed 20-year ban versus a Twin Metals mine. In all employment scenarios the 20-year ban produced more jobs over a 20-year period in the Boundary Waters region than the mining scenario. In the best-case scenario, Twin Metals Minnesota would only create 650 jobs versus the 4,500 jobs that will be created over 20 years if copper mining is banned and the Boundary Waters Canoe Area Wilderness is protected.
  Learn more about the Harvard Study.

• $950 MILLION MORE FROM AN AMENITY-BASED ECONOMY THAN A COPPER MINE -A Harvard study showed that a healthy Boundary Waters creates a healthy business boom for the long-haul: a 20-year mining ban would produce far greater economic benefit and diversity than the proposed Twin Metals mine with up to $900 million more personal income to the local area over 20 years if copper mining is banned. Learn more about the Harvard Study.

THE PUBLIC DOESN’T WANT THIS MINE:

• A vast majority of Minnesotans and Americans want the Boundary Waters protected from the threat of sulfide-ore copper mining. Seventy percent of Minnesotans oppose sulfide-ore copper mining near the Boundary Waters, and over 94% of the 125,000 public comments on the proposed mineral withdrawal urged protection.

• An analysis by Key Log Economics found that of the more than 81,000 unique comment letters submitted to the Forest Service in 2017, 98.2%  supported a 20-year ban on sulfide-ore copper mining in the watershed of the Boundary Waters. In addition, the Forest Service received petitions and postcards signed by 41,971 people that support the mineral withdrawal. Altogether, 121,539 people urged the Forest Service to protect the Boundary Waters. This scoping comment period generated the most participation in an environmental review process in Minnesota history.

CORRUPTION AND POLLUTION:

• IVANKA TRUMP’S LANDLORD -It all comes down to one foreign billionaire who happens to be Ivanka Trump's landlord. Ivanka Trump and Jared Kushner are paying $15,000 a month to rent their home in the D.C. from Andrónico Luksic, owner of foreign mining giant Antofagasta, the parent company to Twin Metals Minnesota. The Wall Street Journal reported that the Chilean billionaire bought a Washington, D.C., mansion for $5.5 million, just after the November election on December 22, 2016, and that twelve days after the purchase, Luksic’s company rented the mansion to Ms. Trump and Mr. Kushner.

• Antofagasta has a history of environmental disaster and political corruption in its homeland. Antofagasta was found guilty by the Chilean Supreme Court of harming residents when the mining company located its tailings dam upstream, polluting the groundwater and blocking a critical source of water on which the community depended. They were responsible for the highest number of toxic spills in the region of Coquimbo, including one spill which dumped 13,000 liters of copper concentrate directly into a river. They faced a fine of $23.8 million and closure of its biggest copper mine in Chile over violations of its environmental permit, including water pollution.

• Antofagasta has been implicated in a number of bribery and corruption scandals, including with a high-ranking Chilean cabinet minister, a questionable $10 million dollar loan to the daughter-in-law of the Chilean president, and tax fraud.

CONCERN FOR PUBLIC HEALTH

• Sulfide-ore copper mining could have major impacts on human health. “The World Health Organization lists the ten environmental toxins with greatest concern to human health, and sulfide-ore copper mining releases at least six of these - mercury, lead, arsenic, particulate air pollution, asbestos, and cadmium.  Sulfide-ore copper mining also releases sulfates, which fuel the chemical reactions that transform mercury to its toxic form methylmercury.
  These toxins have known harmful effects to human health including cancer, lung disease, heart disease, and neurodevelopmental diseases (dyslexia and other learning disorders, intellectual disabilities, autism, and ADHD among them).  Babies from gestation through age three are especially vulnerable due to their rapidly growing brains, which have a high affinity for these heavy metals.”

• Learn more from the doctors who visited D.C. to express the concerns of sulfide-ore copper mining impacts on human health.

MORE RESOURCES:

If you want to find more information about this issue to include in your comments, some good resources include our Science Desk or other blog categories and our Factsheets page.

You can read the BLM's "environmental assessment" document on the renewal of these leases (it's only about 30 pages long).