INTERNATIONAL JOINT COMMISSION
INTERNATIONAL LAKE OF THE WOODS BASIN WATER QUALITY PLAN OF STUDY (“Final Report,
November 2014”)
Comments Respectfully Submitted by
Reid Carron
3100 Hartley Point Road
Ely, Minnesota 55731
(Member, Community Advisory Group, International Rainy-Lake of the Woods Watershed Board)
Thanks to the Plan of Study Team for preparing a very good and useful Water Quality Plan of Study, and
thanks to the International Joint Commission for this opportunity to comment on the WQPOS Final
Report.
My comments are as follows:
P. iv—Recommendations for Immediate Action. I suggest that Project 24, Vulnerability Assessment of
Border Waters to Contamination from Mining, be added to the Recommendations for Immediate Action.
Among the many threats to the water quality and ecological integrity of the Basin, the threat posed by
hard-rock, sulfide-ore mining for copper, nickel, gold, and other metals is particularly potent because
the damage such mining causes (e.g., destruction of terrestrial watershed areas; disruption of
groundwater flow; release of acid mine drainage, heavy metals, and sulfates into groundwater and
surface waters) is largely irreversible within any reasonably comprehensible period of time. A number
of mining projects are proposed in the Basin and in the adjacent Lake Superior Basin. A Vulnerability
Assessment at an early date is important so that citizens are not presented with a fait accompli before
the full environmental, economic, and social impact of such mining is understood.
I believe it is important to emphasize that a mere monitoring regime, no matter how sophisticated, is
inadequate. Monitoring simply tells us that the horse is out of the barn. Massive, long-lasting,
irreparable, unstoppable damage to ecosystems may occur before even a sophisticated monitoring
regime issues an alert.
P. 89—Project 21 Synthesis Report on Contaminants in Water, Aquatic Sediment, and Fish.
In the third paragraph under “Methodology,” the listing of mining contaminants should include acidity
as well as metals and sulfates. Increased acidification of waters resulting from sulfuric acid runoff from
exposed sulfide-bearing rock is particularly detrimental to game fish.
Pp. 89-92— Project 21 Synthesis Report on Contaminants in Water, Aquatic Sediment, and Fish. This is
a relatively minor point, but one I believe to be worth raising. The discussion of sulfates seems to
compartmentalize separately airborne sulfates (“deposition”) and sulfates entering water as a result of
mining or other activity. In isolation, some language seems to suggest that the problem is diminishing
(“Reductions in acid rain pollutants (sulfate and hydrogen ion) likely reduce the amount of mercury
methylation within aquatic ecosystems, thus potentially less methylmercury is available for
bioaccumulation in the food web . . . .” p. 90). However, sulfates continue to enter the Basin as a result
of mining activity. My understanding is that sulfates from whatever source are detrimental because of
their contribution to the methylation of mercury and their deleterious impact on wild rice. If it were
possible to make it clearer that total sulfate load is the issue I think it would be helpful.
Pp. 96—3.4.2 Assessment of Potential Contamination from Mining and Petroleum Transport. The
second paragraph in this section begins with this sentence: “Both provincial/state and federal
governments impose stringent requirements for proposed mining projects to minimize potential
environmental impacts.” Some may question whether this statement is entirely correct with respect to
the State of Minnesota’s regulation of mining. It is reported that every taconite mine in Minnesota is
either in violation of its water discharge permit or has received a variance to allow discharges in excess
of its permit. Minnesota withdrew from a St. Louis River mercury study with the United States EPA, the
State of Wisconsin, and the Fond du Lac Band of Lake Superior Chippewa because, some believe, the
study would make clear that taconite mining is largely responsible for elevated levels of sulfates and,
thus, methylmercury in that river. Other examples also exist.
P. 97—Project 24, Vulnerability Assessment of Border Waters to Contamination
from Mining. This section contains the following:
It is emphasized that although this project will examine the cumulative effects of basinwide mining activities, the focus of the cumulative effects (impairments) will be on
international border waters—that is, the large border lakes and Rainy River. Other
agencies have jurisdiction over waters contained entirely within one nation’s border,
and this project will not attempt to assess the potential for impairment of waters that
are not international border waters.
I believe that I understand the intent of this language, and I respectfully suggest that the second
sentence quoted does not accurately state the intent of the Plan of Study Team. For example,
Basswood Lake is a large border lake lying partly within the Boundary Waters Canoe Area Wilderness in
Minnesota and partly within Quetico Provincial Park in Ontario. Basswood would likely be impaired by
acid mine drainage, heavy metals, and sulfates if copper/nickel mining were to be allowed, as proposed,
along the South Kawishiwi River and Birch Lake, both of which lie entirely within Minnesota. To evaluate
the potential impairment of Basswood, one would need to assess the potential for impairment of the
South Kawishiwi and Birch Lake, as well as White Iron Lake and Fall Lake, all of which lie entirely within
Minnesota but which are also directly upstream from Basswood. That is, it is not possible to know the
potential for impairment of Basswood without knowing the potential for impairment of certain waters
that do not happen to be international border waters. Perhaps this language could be added to the
second sentence quoted: “except to the extent that such waters are upstream from large border lakes.”
Pp. 97-98—Project 24, Vulnerability Assessment of Border Waters to Contamination
from Mining. Any contributions to the Vulnerability Assessment by the Natural Resources Research
Institute of the University of Minnesota-Duluth should be intensively scrutinized, because some
elements of NRRI have received very significant financial support from the mining industry, including
organizations and companies proposing sulfide-ore copper nickel mining.
P. 100—Project 26, Mining Effects Science Workshop.
Stakeholder group: I recommend that the stakeholder group be expanded to include parks and
wilderness user groups (e.g., Voyageur Outward Bound School, Wilderness Inquiry) and park and
wilderness-edge businesses (e.g., outfitters, resorts, lodges, fishing guides, dogsledders).
Advocacy: I understand the reason for the Plan of Study Team’s admonition that advocacy should be
kept out of the Workshop process, but I fear that is an unrealistic goal. Any information that the mining
industry presents will be couched in terms most favorable to the industry, and other stakeholders will
also undoubtedly seek to present their information in the best light to support their position. I think a
more realistic and ultimately more useful admonition would be to remind participants that different
stakeholders have different interests, and to demand that information presented be accurate.