29 November, 2010
James W. Sanders, Forest Supervisor
Superior National Forest
8901 Grand Ave. Place
Duluth, MN 55808
I am concerned about the proposed land exchange between the USFS and PolyMet Mining Inc. This is nothing about a “fair” land swap – but as noted – a “connected action” to a proposed environmentally destructive project. Also, while suggesting otherwise, the proposed exchange does not in any way demonstrate that it meets, let alone exceeds, four of the Forest Service’s Strategic Plan goals.
The present federal lands proposed for exchange are contiguous by definition and in that capacity act as a unit providing ecological and environmental benefits to wildlife, the public and the planet. As it sits immediately adjacent to private tracts with an extensive history of environmental degradation, it serves as an important buffer to the on-going and persistent negative environmental impacts previous land use has created. Removal and conversion into expanded environmental degradation only moves the buffer further out and exponentially subjects additional environmental resources, both public and private, to harm.
Regarding these goals as now exist on the federal lands:
For the goal to “provide and sustain benefits to the American people (desired outcome is forests with sufficient(?) long-term multiple socioeconomic benefits to meet the needs of society), it fails completely – this is a de-forestation action. The present disposition of this tract meets that end, and cannot be improved upon. Any inference to economic benefit cannot be quantified within a forest management paradigm and becomes an equivocation to purposes anathema to the environmental spirit and vision. What economic benefits can be referenced are predetermined – the lion’s share going to outsiders – Minnesota resources, both mineral and environmental – offered up to internationals.
To “conserve open space” – this is a qualitative, not quantitative statement. The present space is already completely open and carpeted with a rich ecologically diverse and living epidermis – a protective skin. This land exchange would create more open space that by definition is erased – non- protective – non-living – to perpetuity.
To “sustain and enhance outdoor recreation opportunities” – this already exists on site. The present conditions are the definition of sustainability and open for public recreation. Exchanging them away is to remove sustainability and no public recreation of higher value is created. It is a self serving presumption that this exchange translates into more people using better land elsewhere.
In “maintaining basic management capabilities of the Forest Service by reducing landlines and mineral conflicts” – this maintains nothing and the small numerical net gain of decreased landlines does not equate into better management capabilities. The site is now under full Forest Service management and should & can basically be kept that way. While everyone should move and live to reduce all conflicts, mineral extraction is inherently conflictual with ecological and environmental goals and should not be pre-empted or avoided. The Forest Service’s mandate by definition lies in management of forest as forest. That private (?)mineral wealth is overlaid by public forest is no imperative for the Forest Service to abrogate its duty to conflict. It is no secret that other potentially rich and exploitable mineral deposits and proposed projects lie under other public forest resources. To acquiesce to this exchange sends an ominous warning to future public forest interests and brings into question the Forest Service’s ability, vision and integrity of securing and managing our forest resources for our children.
Of the non-federal lands offered for exchange:
It cannot be shown that adding a single foot of these private holdings to FS management expands or improves upon FS mission and goals.
By and large all of these pieces of private property are paradoxically irrelevant in their exchange while being intrinsically imperative to the long term FS mission. Whether their ownership has fallen inside or outside the public domain has little impact on their environmental function as it exists today. They are small and relatively underutilized and generally un-exploitable. The regional geography, topography , ecology and economy is necessarily the predominant management template under which they exist. Adding that they mostly lie isolated and scattered between predominantly state, county and federal ownership, present regional public management, pragmatically, is the de facto management strategy implemented. That most are essentially not managed at all, for these reasons any exchange becomes nearly mute in public value. “Enhancement” is theoretical only. The FS cannot demonstrate their incorporation improves their lot significantly. Even what private use or abuse might incur is marginal, and obscene as a comparison to the already highly demonstrated and purposefully intended future corruption of present federal land.
Of the five tracts, the fifth implies more merit than the rest in evoking its proximity to the BWCA. But here too, reality trumps theory. That it is near an important entry point is of no consequence for FS inclusion and cannot be demonstrated to be an area enhancement at all. McFarland lake is and will likely remain mostly outside of federal jurisdiction because it is deemed and desired of higher private value. As ownership and public accessibility presently stand, it has not even been demonstrated that enhancement is required let alone to be realized. If these parcels are of such great consequence and justifiable, another more appropriate and less destructive acquisition strategy can easily be implemented. That being said, the FS to date has not fully demonstrated to my satisfaction that it has either the vision or resources to effectively manage its present holdings.
As a square foot for square foot swap this exchange is unjustifiable and untenable.
Of the other “connected” issues (tissues?):
While the FS would like to separate its self from the greater environmental issues contested in other public arenas, by only considering a narrow numerical management exchange value, in admitting it is a “connected action” it cannot do so. In just the land exchange alone this is a net loss of public forest resources at the greatest conceivable cost. But this great net loss is connected to even greater influences that bear heavily upon this decision.
That mineral owners find a method to take what they have come to possess by their economic means, remove it and leave the rest would greatly solve many problems – they cannot. That the FS would abrogate their mandate and keep the forest would be the end of conflict – they cannot. The FS bears as great of scrutiny for the ultimate consequences of their actions as the mineral owner are to be held for the ultimate consequences of theirs.
Nowhere is a land exchange measured for the waste disposal consequences that the FS cannot separate itself from politically or geographically. Ground and surface water contamination concerns are not extreme and additional nearby public and private holdings will be impacted – both within the vicinity and downstream. There is high risk inferred to federal lands outside of the exchange acreage, both in the present and a very long term future. There is no mitigation in any land exchange for this failing.
Regarding my own personal connection and interest to the Arrowhead region, I am a botanist, ecologist and imaginographer. I have and will travel extensively throughout the region documenting and recording plant species and their rapidly diminishing habitats. The only expansion of my activities this mine would affect would to be an unfortunate witness to the further encroachment of invasive weed species such destructive activity inherently causes. At present the FS is bedeviled with this problem beyond its means already. There is every imperative against this mine, in this place and in this time.
A century old next year, the Weeks Act was a loud public voice of understanding in addressing these concerns and enacted into federal law for that reason. Having spoken once – must it be made to speak again? A FS decision supportive of this land exchange is precedent setting, smears tailings mud on the face of an evolving democratic public ideology and marks a significant de-evolution of public ideals. As great as the depth and magnitude of the permanent physical scar this action will incur on the Earth’s skin, it will also forever call into question the tenure of the USFS’s moral vision and integrity.
Peter M. Dziuk