August 22, 2014
Lake of the Woods Basin Water Quality Plan of Study Team
Via Electronic Mail (IJC Website)
Canadian Section Office
International Joint Commission
234 Laurier Avenue W. 22nd Floor
Ottawa, ON Canada K1P 6K6
United States Section Office
International Joint Commission
2000 L. Street NW, Suite 615
Washington, D.C. 20440 USA
Dear Lake of the Woods Basin Water Quality Plan of Study Team,
My comments are based on the discussion at your public meeting in Ely, MN August 15.
Potential Threats from Copper Nickel Mining
Your Logic Model for Project 27, “Assess Vulnerability of Boundary Waters to Contamination from Mining,
Agriculture and Petroleum Transport” embodies an, “identify potential risks - monitor – mitigate” approach.
Several of us suggested that the basic long term toxic waste drainage threats from copper nickel mining cannot
be mitigated. They can only be prevented by refusing to allow copper nickel mining in the water rich
environment that drains into the international boundary waters of the Lake of the Woods Basin.
Conclusion 1. I request that you develop a logic model for Project 27 based on prevention and that the project
itself follows this logic.
Project 27 also provides for a, “Peer-reviewed report on vulnerability assessment and recommendations on
strategies to mitigate risk.” I, and others, contend the only way to “mitigate risk” from copper nickel mining in
the water rich environment that drains into the international boundary waters of the Lake of the Woods Basin is
to prevent such mining from occurring.
Conclusion 2. I request that Project 27 include a peer-reviewed review of the best available science to address
the question, Can copper nickel mining be done with any firm assurance of environmental protection in the
water rich environment that drains into the international boundary waters of the Lake of the Woods Basin?
Petroleum Transport
Project 27 also concerns Petroleum Transport. You should be aware that Minnesota laws and regulations do not
provide for rejection of a petroleum pipeline project based on environmental considerations. In effect, the least
objectionable route must be chosen (Minnesota Rules, Section 7850).
Conclusion 3. I request that Project 27 efforts on vulnerability assessment address the adequacy of relevant
government laws and regulations to provide environmental protection against the potential threats from
petroleum transport via pipelines, and that recommendations for improvement be made to the relevant
government entities.
Sincerely,
/s/
Bradley Sagen
13667 Deer RD
Ely, MN 55731 USA
hbsagen@frontiernet.net