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	<title>Comments for Save the Wild UP</title>
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	<link>http://www.savethewildup.org/blog</link>
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	<pubDate>Mon, 15 Mar 2010 17:33:36 +0000</pubDate>
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		<title>Comment on Kennecott Attempts to Sidestep the EPA: Seeks permit amendment by Jeffery Loman</title>
		<link>http://www.savethewildup.org/blog/kennecott-attempts-to-sidestep-the-epa-seeks-permit-amendment/comment-page-1/#comment-9163</link>
		<dc:creator>Jeffery Loman</dc:creator>
		<pubDate>Sat, 13 Mar 2010 18:52:25 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1409#comment-9163</guid>
		<description>This is nothing more than a strategic tactic to eliminate the Federal government's oversight, including the Federal trust responsibility to Indian tribes and specifically the Keweenaw Bay Indian Community (KBIC) and it's members, of which I am proud to say I am a member.

Without involvement by the US EPA and other Federal agencies, there will be no cumulative affects analysis, no human health impact assessment, no real consideration of the damage to threatened and endangered species and their habitat, no preservation of historic properties, archeological sites, or view sheds. More importantly, there will be no economic analysis that demonstrates that what Kennecott initially proposed isn't economically viable. Kennecott will expand their activities until 90% of the entire Upper Peninsula of Michigan is nothing more than a massive mine site. It's no secret that this is what it will take for Rio Tinto to make the kind of money they demand from these operations. There isn't one single example of any of their involvement anywhere on the planet that demonstrates differently. That's a fact!

The Kennecott Eagle Project will not survive Federal environmental regulatory scrutiny. How do I know? In addition to the 20-years I served in the US Navy as an Aquanaut and Explosive Ordnance Disposal Mobile Unit Diver, I have worked in the environmental field for Federal agencies for almost 20-years. I have extensive experience in natural resource damage assessment and restoration under CERCLA and OPA - the Federal laws by which trustees for natural resources hold responsible parties liable for damages. It is noteworthy that Rio Tinto is among those responsible for extensive damages to Federal, State and tribal trust resources in other states. One would hope that now that corporations are citizens they would be held to the same standards as you and I but unfortunately they are not. But they'll tell you that won't happen here. They will tell you that they are "outdoorsmen" and they "appreciate" the Upper Peninsula just like you do. Don't believe a single word of it - the only thing they appreciate is having money squirting out of every orifice of their bodies - including your tax dollars with the unethical investment of EPA's Super Fund dollars that are invested in Rio Tinto holdings.

With this latest act Rio Tinto/Kennecott now exhibits the unfounded sense of entitlement and breathtaking arrogance they've become famous for as they side step Federal regulatory oversight and use the deplorable economic situation of the State of Michigan to their advantage to forge ahead with a plan that's quickly shaping up to take over the entire Upper Peninsula of Michigan, destroy it's environment, take control of local governments, and make a ton of money, the majority of which will leave the area. 

Say goodbye to your groundwater. This will be the first to go. Next will be fish, as the 300 pound explosive charges they'll use to blast underground rock rupture fish eggs and fish bladders. Then say hello to red water - acid mine drainage that stinks, kills the birds, carries toxic chemicals that make what fish, birds and animals are left - unfit to eat. 

At some point you can say goodbye to the snowmobilers, skiers, hunters, sport fishing crowd and other tourists who will go to Northern Wisconsin and Minnesota instead of the UP. After all, who wants to play in the worlds largest superfund site?

If you don't think this is true, do a little online research and see what kind of tourist opportunities they have at the Tar Creek Superfund Site in the former Tri-State mining District...

Write and/or call Mr. Bharat Mathur, the US Environmental Protection Agency Acting Regional Administrator for Region 5. Let him know you demand that EPA issue an order to Kennecott to stop their construction activities immediately. Contact Ms. Ignacia S. Moreno, Assistant Attorney General, Environment and Natural Resources Division, and let her know that EPA's failure to act thus far constitutes a breach of trust to a Federally recognized Indian tribe and to the broader public. The resources that Rio Tinto/Kennecott are already damaging are YOUR trust resources. Today, the UP is your home not theirs. The tribal trust resources belong to Indian people who can be one of two things to you. They can be your National Treasure, or the poster child for your national trash campaign. The choice is yours. But not for long if you don't stand up with savethewildup.org and others and fight now.</description>
		<content:encoded><![CDATA[<p>This is nothing more than a strategic tactic to eliminate the Federal government&#8217;s oversight, including the Federal trust responsibility to Indian tribes and specifically the Keweenaw Bay Indian Community (KBIC) and it&#8217;s members, of which I am proud to say I am a member.</p>
<p>Without involvement by the US EPA and other Federal agencies, there will be no cumulative affects analysis, no human health impact assessment, no real consideration of the damage to threatened and endangered species and their habitat, no preservation of historic properties, archeological sites, or view sheds. More importantly, there will be no economic analysis that demonstrates that what Kennecott initially proposed isn&#8217;t economically viable. Kennecott will expand their activities until 90% of the entire Upper Peninsula of Michigan is nothing more than a massive mine site. It&#8217;s no secret that this is what it will take for Rio Tinto to make the kind of money they demand from these operations. There isn&#8217;t one single example of any of their involvement anywhere on the planet that demonstrates differently. That&#8217;s a fact!</p>
<p>The Kennecott Eagle Project will not survive Federal environmental regulatory scrutiny. How do I know? In addition to the 20-years I served in the US Navy as an Aquanaut and Explosive Ordnance Disposal Mobile Unit Diver, I have worked in the environmental field for Federal agencies for almost 20-years. I have extensive experience in natural resource damage assessment and restoration under CERCLA and OPA - the Federal laws by which trustees for natural resources hold responsible parties liable for damages. It is noteworthy that Rio Tinto is among those responsible for extensive damages to Federal, State and tribal trust resources in other states. One would hope that now that corporations are citizens they would be held to the same standards as you and I but unfortunately they are not. But they&#8217;ll tell you that won&#8217;t happen here. They will tell you that they are &#8220;outdoorsmen&#8221; and they &#8220;appreciate&#8221; the Upper Peninsula just like you do. Don&#8217;t believe a single word of it - the only thing they appreciate is having money squirting out of every orifice of their bodies - including your tax dollars with the unethical investment of EPA&#8217;s Super Fund dollars that are invested in Rio Tinto holdings.</p>
<p>With this latest act Rio Tinto/Kennecott now exhibits the unfounded sense of entitlement and breathtaking arrogance they&#8217;ve become famous for as they side step Federal regulatory oversight and use the deplorable economic situation of the State of Michigan to their advantage to forge ahead with a plan that&#8217;s quickly shaping up to take over the entire Upper Peninsula of Michigan, destroy it&#8217;s environment, take control of local governments, and make a ton of money, the majority of which will leave the area. </p>
<p>Say goodbye to your groundwater. This will be the first to go. Next will be fish, as the 300 pound explosive charges they&#8217;ll use to blast underground rock rupture fish eggs and fish bladders. Then say hello to red water - acid mine drainage that stinks, kills the birds, carries toxic chemicals that make what fish, birds and animals are left - unfit to eat. </p>
<p>At some point you can say goodbye to the snowmobilers, skiers, hunters, sport fishing crowd and other tourists who will go to Northern Wisconsin and Minnesota instead of the UP. After all, who wants to play in the worlds largest superfund site?</p>
<p>If you don&#8217;t think this is true, do a little online research and see what kind of tourist opportunities they have at the Tar Creek Superfund Site in the former Tri-State mining District&#8230;</p>
<p>Write and/or call Mr. Bharat Mathur, the US Environmental Protection Agency Acting Regional Administrator for Region 5. Let him know you demand that EPA issue an order to Kennecott to stop their construction activities immediately. Contact Ms. Ignacia S. Moreno, Assistant Attorney General, Environment and Natural Resources Division, and let her know that EPA&#8217;s failure to act thus far constitutes a breach of trust to a Federally recognized Indian tribe and to the broader public. The resources that Rio Tinto/Kennecott are already damaging are YOUR trust resources. Today, the UP is your home not theirs. The tribal trust resources belong to Indian people who can be one of two things to you. They can be your National Treasure, or the poster child for your national trash campaign. The choice is yours. But not for long if you don&#8217;t stand up with savethewildup.org and others and fight now.</p>
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		<title>Comment on March 11 - DNRE to Host Public Meeting on Modifications to Kennecott Groundwater Permit by Jeffery Loman</title>
		<link>http://www.savethewildup.org/blog/march-11-dnre-to-host-public-meeting-on-modifications-to-kennecott-groundwater-permit/comment-page-1/#comment-9161</link>
		<dc:creator>Jeffery Loman</dc:creator>
		<pubDate>Sat, 13 Mar 2010 17:25:57 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1412#comment-9161</guid>
		<description>It is unconscionable that this project continues to move forward with zero meaningful regulatory oversight by any Federal agency, including and especially the US Environmental Protection Agency. 

Freshly victorious from the administrative process (nothing more than a bad joke) facilitated by the State of Michigan, Rio Tinto/Kennecott takes three steps:

1. Asserts that the EPA UIC Permit they previously seemed to agree they needed is no longer necessary.

2. Increase construction activity to commence operations almost immediately.

3. Modifies the State issued permits so they actually resemble what they really intend to do.

Once again, Rio Tinto/Kennecott demonstrates their unfounded sense of entitlement and breathtaking arrogance they've come to be famous for as they destroy half the planet. 

To every person in the north central area of the UP I say this - say goodbye to your groundwater. It's going to be the first of many things to go...</description>
		<content:encoded><![CDATA[<p>It is unconscionable that this project continues to move forward with zero meaningful regulatory oversight by any Federal agency, including and especially the US Environmental Protection Agency. </p>
<p>Freshly victorious from the administrative process (nothing more than a bad joke) facilitated by the State of Michigan, Rio Tinto/Kennecott takes three steps:</p>
<p>1. Asserts that the EPA UIC Permit they previously seemed to agree they needed is no longer necessary.</p>
<p>2. Increase construction activity to commence operations almost immediately.</p>
<p>3. Modifies the State issued permits so they actually resemble what they really intend to do.</p>
<p>Once again, Rio Tinto/Kennecott demonstrates their unfounded sense of entitlement and breathtaking arrogance they&#8217;ve come to be famous for as they destroy half the planet. </p>
<p>To every person in the north central area of the UP I say this - say goodbye to your groundwater. It&#8217;s going to be the first of many things to go&#8230;</p>
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		<title>Comment on March 11 - DNRE to Host Public Meeting on Modifications to Kennecott Groundwater Permit by cheap generic drugs</title>
		<link>http://www.savethewildup.org/blog/march-11-dnre-to-host-public-meeting-on-modifications-to-kennecott-groundwater-permit/comment-page-1/#comment-9147</link>
		<dc:creator>cheap generic drugs</dc:creator>
		<pubDate>Sun, 07 Mar 2010 12:44:18 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1412#comment-9147</guid>
		<description>I added your blog to bookmarks. And i'll read your articles more often!</description>
		<content:encoded><![CDATA[<p>I added your blog to bookmarks. And i&#8217;ll read your articles more often!</p>
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		<title>Comment on Woodland Road - Written Comment Accepted Until 20th by BC</title>
		<link>http://www.savethewildup.org/blog/woodland-road-written-comment-accepted-until-20th/comment-page-1/#comment-9126</link>
		<dc:creator>BC</dc:creator>
		<pubDate>Sun, 28 Feb 2010 08:00:28 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1385#comment-9126</guid>
		<description>I have hiked the area between Silver Lake, Dishno Lake, Voelker's Creek and Wildcat Canyon for years.  Other than the McCormick Tract (which enjoys Federal protection for its trees and waters)there is nothing else like this area North of US-41 that is open to the public. The Dead River and Wildcat Creek areas to the SW of Silver Lake are just dense with swamps, bogs, rocks, pines, etc. Think about this: The streams and rivers that originate in this amazing upland watershed crown flow into Lake Michigan at Escanaba (via Log Lake), Marquette (Dead River), Big Bay (Yellow Dog River), and Skanee (Huron River).  
  Its interesting that in the currently popular movie Avatar the audience is generally unsympathetic to the mining operation that destroys a giant tree which the indigenous population use as a home. In this work of fiction the justification of such an action is that it will expedite the mining operation.  It's not an exact metaphor, but as a private citizen of this state and county, and one who has enjoyed the Upper Peninsulas wilderness, I didn't see this one(Woodland Road) coming.  
  It's easy to toss the idea of watersheds and wetlands around like so many interchangeable store brand bottled water's.  If this exact acreage is supplanted, or plowed under, or paved over, the environment can be compensated through the creation of these conditions somewhere else in the local vicinity. 
  This is a fallacy. The next time you drive down 41-South look closely at the cedar swamps between the Carlshend road spurs.  Living on one side of the road.  Dead on the other side of the road.  In fact in your travels, if you are observant, you will note these conditions in a watershed whose disseminated flow has been blocked entirely by the the highway sub-base or concentrated ineffectually by  culverts.  Unless the Michigan DNR and the road builders are really willing to work at mitigating this consequence of sub-basing the impact to wetlands will more realistically run into the hundreds and possibly thousands of acres.
  Lets all face the facts.  The whole area is full of bogs and swamps and will require the deepest road construction possible.  The bogs and ponds that originate all the feeder streams to the Dead River system SW of Silver Lake are usually located between massive seams of granite.  Cut the bogs off by a road and the water has no where to go. Make the culverts to large and dry out filter bogs that should be relatively damp throughout the year. 
   If an alternative route cannot be established (such as to the East and then South of Silver Lake--existing Red Pine plantations on sand and alluvial soil, joining the Wolf Lake juncture on well established logging roads) perhaps it would be cost and environmentally effective to suspend critical segments of the road on pilings.
  Ultimately, in my heart, I don't want a turnpike built through yet another significant portion of what we all, mythically, consider to be the "paradise" aspect of the Upper Peninsula.</description>
		<content:encoded><![CDATA[<p>I have hiked the area between Silver Lake, Dishno Lake, Voelker&#8217;s Creek and Wildcat Canyon for years.  Other than the McCormick Tract (which enjoys Federal protection for its trees and waters)there is nothing else like this area North of US-41 that is open to the public. The Dead River and Wildcat Creek areas to the SW of Silver Lake are just dense with swamps, bogs, rocks, pines, etc. Think about this: The streams and rivers that originate in this amazing upland watershed crown flow into Lake Michigan at Escanaba (via Log Lake), Marquette (Dead River), Big Bay (Yellow Dog River), and Skanee (Huron River).<br />
  Its interesting that in the currently popular movie Avatar the audience is generally unsympathetic to the mining operation that destroys a giant tree which the indigenous population use as a home. In this work of fiction the justification of such an action is that it will expedite the mining operation.  It&#8217;s not an exact metaphor, but as a private citizen of this state and county, and one who has enjoyed the Upper Peninsulas wilderness, I didn&#8217;t see this one(Woodland Road) coming.<br />
  It&#8217;s easy to toss the idea of watersheds and wetlands around like so many interchangeable store brand bottled water&#8217;s.  If this exact acreage is supplanted, or plowed under, or paved over, the environment can be compensated through the creation of these conditions somewhere else in the local vicinity.<br />
  This is a fallacy. The next time you drive down 41-South look closely at the cedar swamps between the Carlshend road spurs.  Living on one side of the road.  Dead on the other side of the road.  In fact in your travels, if you are observant, you will note these conditions in a watershed whose disseminated flow has been blocked entirely by the the highway sub-base or concentrated ineffectually by  culverts.  Unless the Michigan DNR and the road builders are really willing to work at mitigating this consequence of sub-basing the impact to wetlands will more realistically run into the hundreds and possibly thousands of acres.<br />
  Lets all face the facts.  The whole area is full of bogs and swamps and will require the deepest road construction possible.  The bogs and ponds that originate all the feeder streams to the Dead River system SW of Silver Lake are usually located between massive seams of granite.  Cut the bogs off by a road and the water has no where to go. Make the culverts to large and dry out filter bogs that should be relatively damp throughout the year.<br />
   If an alternative route cannot be established (such as to the East and then South of Silver Lake&#8211;existing Red Pine plantations on sand and alluvial soil, joining the Wolf Lake juncture on well established logging roads) perhaps it would be cost and environmentally effective to suspend critical segments of the road on pilings.<br />
  Ultimately, in my heart, I don&#8217;t want a turnpike built through yet another significant portion of what we all, mythically, consider to be the &#8220;paradise&#8221; aspect of the Upper Peninsula.</p>
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		<title>Comment on Skip Jones to perform March 2 by Skip Jones</title>
		<link>http://www.savethewildup.org/blog/skip-jones-to-perform-march-2/comment-page-1/#comment-9122</link>
		<dc:creator>Skip Jones</dc:creator>
		<pubDate>Fri, 26 Feb 2010 18:09:18 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1394#comment-9122</guid>
		<description>Hi,

Looking forward to sng and sharing news with folks and celebrating the coming of spring... 

For the music lovers check out:

Singing for the Hard Times a tribute to Utah Phillips &amp; and search "Playing for Change" at www.YouTube.com  Enjoy

Skip</description>
		<content:encoded><![CDATA[<p>Hi,</p>
<p>Looking forward to sng and sharing news with folks and celebrating the coming of spring&#8230; </p>
<p>For the music lovers check out:</p>
<p>Singing for the Hard Times a tribute to Utah Phillips &amp; and search &#8220;Playing for Change&#8221; at <a href="http://www.YouTube.com" rel="nofollow">http://www.YouTube.com</a>  Enjoy</p>
<p>Skip</p>
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		<title>Comment on Author Eric Hansen to do U.P. Slide Shows March 4, 6 by Michele Bourdieu</title>
		<link>http://www.savethewildup.org/blog/author-eric-hansen-to-do-up-slide-shows-march-4-6/comment-page-1/#comment-9112</link>
		<dc:creator>Michele Bourdieu</dc:creator>
		<pubDate>Fri, 26 Feb 2010 05:50:40 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1404#comment-9112</guid>
		<description>The links mentioned in your press release on Eric Hansen are not visible.</description>
		<content:encoded><![CDATA[<p>The links mentioned in your press release on Eric Hansen are not visible.</p>
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		<title>Comment on Woodland Road - Written Comment Accepted Until 20th by Frank Jeff Verito</title>
		<link>http://www.savethewildup.org/blog/woodland-road-written-comment-accepted-until-20th/comment-page-1/#comment-9100</link>
		<dc:creator>Frank Jeff Verito</dc:creator>
		<pubDate>Mon, 22 Feb 2010 21:16:04 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1385#comment-9100</guid>
		<description>First, the mine was proposed with its long list of known uncertainties.  Then came clearing along County Road 550 for heavier-duty power lines, in part to service the unwanted mine.  Now they seek a convenient transportation system through one of the most remote areas east of the Mississippi, regardless of wetlands or the majority of us who value natural places.  This illustrates the step-by-step, hurdle approach industry uses to implement their agendas, and the cumulative effects this can have.  Frank Jeff Verito</description>
		<content:encoded><![CDATA[<p>First, the mine was proposed with its long list of known uncertainties.  Then came clearing along County Road 550 for heavier-duty power lines, in part to service the unwanted mine.  Now they seek a convenient transportation system through one of the most remote areas east of the Mississippi, regardless of wetlands or the majority of us who value natural places.  This illustrates the step-by-step, hurdle approach industry uses to implement their agendas, and the cumulative effects this can have.  Frank Jeff Verito</p>
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		<title>Comment on Event to Help Locked-Out Rio Tinto Borax Workers by W</title>
		<link>http://www.savethewildup.org/blog/event-to-help-locked-out-rio-tinto-borax-workers/comment-page-1/#comment-9094</link>
		<dc:creator>W</dc:creator>
		<pubDate>Sun, 21 Feb 2010 03:23:47 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1370#comment-9094</guid>
		<description>I have worked for US Borax for over 25 years.
Prior to the lockout we have been told we are the world class operators, the most valuable resource the company has.  Yet here we are applying for food stamps,unemployment, and accepting food from other union members( Thank you).  If the company really valued us would they not let us work? To unsure quality in the product and to maintain the plant?  The company has shown just how valuable we the worker actually are by this action, nothing to them, we are just miners.</description>
		<content:encoded><![CDATA[<p>I have worked for US Borax for over 25 years.<br />
Prior to the lockout we have been told we are the world class operators, the most valuable resource the company has.  Yet here we are applying for food stamps,unemployment, and accepting food from other union members( Thank you).  If the company really valued us would they not let us work? To unsure quality in the product and to maintain the plant?  The company has shown just how valuable we the worker actually are by this action, nothing to them, we are just miners.</p>
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		<title>Comment on Bright Ideas Category by judi cornfoot-musolf</title>
		<link>http://www.savethewildup.org/blog/welcome-to-the-bright-ideas-category/comment-page-1/#comment-9092</link>
		<dc:creator>judi cornfoot-musolf</dc:creator>
		<pubDate>Sat, 20 Feb 2010 06:52:29 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/welcome-to-the-bright-ideas-category/#comment-9092</guid>
		<description>If there is someone who can help me write a letter to the minimg journal i would appreciate the help. i could come into the office and hel p you compose it. 
i am so fed up with the lack of intelligent legislators in the UP. 
ALl this is about the mines is a job grab nothing more or less. 
i've even told Prusi if they go ahead with the mining and it ruins the water then we can save Millions from the budget on "pure Michigan campaign" as there will be no more pure michigan after the mining .</description>
		<content:encoded><![CDATA[<p>If there is someone who can help me write a letter to the minimg journal i would appreciate the help. i could come into the office and hel p you compose it.<br />
i am so fed up with the lack of intelligent legislators in the UP.<br />
ALl this is about the mines is a job grab nothing more or less.<br />
i&#8217;ve even told Prusi if they go ahead with the mining and it ruins the water then we can save Millions from the budget on &#8220;pure Michigan campaign&#8221; as there will be no more pure michigan after the mining .</p>
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		<title>Comment on Woodland Road - Written Comment Accepted Until 20th by Lynnellen Proeber</title>
		<link>http://www.savethewildup.org/blog/woodland-road-written-comment-accepted-until-20th/comment-page-1/#comment-9091</link>
		<dc:creator>Lynnellen Proeber</dc:creator>
		<pubDate>Wed, 17 Feb 2010 16:41:38 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1385#comment-9091</guid>
		<description>Woodland Road Comments:
Permit Application Review Timing: The timing of the application submittal does not allow for reasonable public review and input. The quantity and spatial distribution of aquatic and terrestrial resources which would be impacted by the proposed project is quite substantial. The remote nature and inaccessibility of the proposed project area during winter limits the ability of the public to verify submitted data and information or to confirm observations recorded.
The DNRE consistently confirms that they value and recognize the need for public participation in the decision making process. Application materials have only recently been made available to the public and only limited data verification is possible. Major revisions were submitted on January 21st 2010 and only made available to the public on January 25th. Not allowing for reasonable public review, public fact checking, and public input into a permit review process only degrades the integrity of the process. Consider U.S. EPA insights contained in Stakeholder Involvement &amp; Public Participation at the U.S. EPA; Lessons Learned, Barriers, &amp; Innovative Approaches (January 2001), where they confirm “Often, data credibility depends upon whether the data can be produced or confirmed by an outside source.” “Without a concerted effort to ensure reliable, trustworthy data, the stakeholder process may prove frustrating for all participants involved.”
Additionally, for a project with this degree of potential impact all voices should be heard and input solicited. Again using insight from the U.S. EPA “It can be easy to by-pass certain stakeholders and pull together a group where issues can be resolved with relative ease. However, lack of adequate participation or lack of effective means for participation can result in agreements or policies that do not necessarily reflect the interests of communities or constituencies that will be most impacted by them. “(Stakeholder Involvement &amp; Public Participation at the U.S. EPA; Lessons Learned, Barriers, &amp; Innovative Approaches January 2001)
The Project review is out of context which leads to regulatory uncertainty and potential financial liability to the State of Michigan.
The applicant’s project is one portion of their entire planned Yellow Dog Eagle Mine project and should be considered under the context and framework of Part 632 of NREPA. Considering this project outside that framework will potentially lead to both regulatory and liability uncertainties in the future for the State of Michigan if the project is approved. Mine haul roads are commonly found to be sources of environmental contamination of watersheds and groundwater, as storm water runoff carries heavy metals, oils, gas, sulfates, salts, and other contaminants into area aquifers, wetlands, and surface water bodies. Considering this proposed project outside the regulatory framework of Part 632 leads to uncertainty over what jurisdictional authority Michigan might have to require the applicant to address contamination problems when they develop in the future. Outside of the framework of Part 632 this proposed
road and affected area will not necessarily be considered as part of the mining affected area as it should be. If this project is not considered as part of the Yellow Dog Plains mining project then the financial burden for cleanup and mitigation will likely fall upon the State of Michigan when environmental contamination problems develop.
The project purpose statement is presumptive. The DNRE is under no obligation to accept the applicant’s project purpose statement as the defacto statement of project purpose.
The applicant’s primary goal is to provide a route for transportation of ore from the planned Eagle Mine in the Yellow Dog Plains. Alternatives to the proposed project transport route are available for that purpose. Other partners of Woodland Road LLC have little to no interest in alternatives examined in this analysis. What interest will Mr. Jilbert or Lindbergs have in the Dishno Road or the AAA-550 alternative? Since the answer is likely none, then why are these alternatives examined? Why is John Cherry the signatory to all Woodland Road LLC documents?
Timber companies have been transporting timber from areas in the Yellow Dog and Mulligan Plains, and the Michigamme Highlands for many years following existing routes. Recreation access is provided for through these same routes.
The DNRE is the agency with the authority to examine materials submitted and determine the primary purpose of the project and make a decision accordingly.
Public support incorrectly presumed; The applicant claims public support for this project based upon negative reaction to their other mining plan related project transportation proposals. Proper public input should be directly related to the issue being considered. This is a common mistake made by entities with little experience of working with the public. Concern expressed about a Great Lakes invasion by the silver carp can not be considered an expression of support for the big-head carp.
Lack of primary data with which to evaluate impact
The applicant has not provided any detail regarding numbers and type of vehicles anticipated. Numbers and types of vehicles anticipated is logically a primary piece of information necessary for a road construction project permit application and related environmental assessments. Certainly such basic information should be provided.
Necessary data is missing; Data that is crucial for evaluation of this proposed project is missing. Some key data not included is as follows:
• Proposed construction schedule and activities are not provided.
• Wildlife corridors are not considered. Disruption of corridors will occur.
• Amphibian data other than frog and toad survey is missing.
• Anticipated traffic types and loads. References are made to 40 ton trucks and 100 ton trucks. Clarification is necessary.
• Public use seems unlikely with the anticipated traffic types and truck tonnages. Public use will be unlikely if the applicant is running 100 ton trucks. Clarification is needed.
• Chemical loading of the surrounding environment will occur and will include heavy metals, herbicides, salts, sulfates, petroleum products, blasting compounds including nitrates, and other contaminants. No data or information regarding these materials is included. This is a very significant omission without which the environmental impact of the project can not be determined.
• Anticipated ambient air quality impacts resulting from road traffic are not determined or discussed. No data is provided. Ambient air quality degradation will occur and negative resource impacts will result. Additional data and information is needed.
• Chemical composition and sources of fill is not clear.
ALTERNATIVES ANALYSIS
Transportation regulatory risks stated are not substantiated or likely; The applicant states that the City of Marquette, Ishpeming, and Negaunee, along with townships the County and Michigan Department of transportation have been actively planning for traffic levels in their jurisdictions. Any evaluations these entities are making has no unique relationship to Kennecott activities. Traffic evaluation and planning is part of the normal course of business for these entities. At between 2,000 – 50,000 vehicles per day on existing major routes through Marquette, Negaunee, and Ishpeming there is no conceivable situation in which truck traffic would be banned through these municipalities.
Selected alternative need is presumed and not substantiated; A number of statements made by the applicant can not be supported by any data or information. The applicant states that mining activity is on the increase in northern Marquette County. This is incorrect. Currently there is no mining activity in northern Marquette County. The applicant has expressed a desire to develop a mining operation in the Yellow Dog Plains, however this plan is currently being contested. Considering the uncertainty of any mining project moving forward in the Yellow Dog Plains the potential value of mining is presumptive and speculative.
Potential Woodland Road benefits are unsubstantiated; The applicant states that school children will be safer if Woodland Road is constructed but does not substantiate this with any supporting documentation or data. Appropriate data would include accident rates at their other facilities, safety records, vehicle maintenance records, and other such data. Claims of
necessity for protection of children should not be made lightly and should not be made without supporting documentation. Failure to demonstrate such claims lessens the integrity of an application.
The applicant states that construction of the Woodland Road will provide benefit through noise reduction on existing traffic routes but does not substantiate this with any supporting documentation or data. Many consultants are qualified to conduct noise studies. Failure to demonstrate such claims or provide data lessens the integrity of an application.
The applicant suggests that construction of the Woodland Road will provide benefit for elderly persons and those with respiratory illnesses living along current existing routes by not exposing them to emissions from the mining truck traffic, but does not substantiate this with any supporting documentation or data. Emissions level and type can be predicted by modeling and with detailed traffic prediction analysis. Emissions level and impact should also be modeled for the proposed Woodland Road. Human health risk is a serious matter and any such health risk analysis should be supported by providing data and information used during the analysis. This is necessary for both regulators reviewing permit applications and for the general public.
The applicant mentions that accidents will be reduced or prevented on existing routes if the Woodland Road is constructed but does not substantiate this with any supporting documentation or data. What is the applicant’s accident rate? What accident rates do they have at other facilities they operate? Anticipated accident rates for the Woodland Road should also be determined from existing data. This claim can not be evaluated without any data.
The applicant states that the demand for emergency services has increased in the project area, but provides no data or information to support this claim. Supporting data should be provided such as 911 calls, emergency service vehicle traffic rates, specific examples, etc. This data and information is available if requested and should be required if this is used as to support presumed public benefit. Protection of human health and public safety is a serious matter and to properly evaluate needs supporting documentation is necessary. Failure to demonstrate such claims lessens the integrity of an application.
Improved landowner access is claimed as a benefit, but is not supported by data or information, such as petitions, or descriptions of public meetings held to collect public input specific to this project. The applicant briefly states that there is support from numerous entities for the project but supplies no supporting data or information. Again, additional data and information is necessary to support such claims in the application.
Benefits presumed and not substantiated; Public access is unlikely and should be discounted when considering this project. This proposed road would be privately owned with no
guarantee of public accessibility. The applicant has a history of restricting public access to public lands in the Yellow Dog Plains. Security guards have been hired to prevent people from accessing CFR lands, the applicant has at times blocked off vehicle access to the Northwest Road, which it does not own, and the applicant has informed people that access to its own CFR lands is trespassing and requires written permission. Current and past behavior can be used to predict future behavior and actions, or at least establish the lack of certainty for public access. This uncertainty regarding the potential for public access is sufficient to remove public access potential as a consideration when reviewing potential public benefits.
Greenhouse Gas Reduction Benefits; The applicant claims that the greenhouse gas reduction benefits and savings are substantial enough that by themselves they justify the project.
Stated Greenhouse Gas Savings are Incorrect; Greenhouse gas accounting is a complex and evolving science and thus it is no surprise that the applicant has incorrectly determined that their project will result in greenhouse gas savings. When the project is examined properly greenhouse gas emissions become a neutral or negative issue if considered in the decision. Greenhouse gas balance calculations for this particular project would require considerations of construction, land clearing, maintenance, and use. Also associated with project would be sequestration loss of forests and understory through maintenance of cleared land for the Woodland Road. Of the four main factors necessary to consider for determining a carbon balance for the proposed Woodland Road, the applicant has only examined one – road use.
Precise calculations are complex as stated previously and more project detail is needed. However, approximate green house balance for the project can be determined.
Carbon dioxide generated during project construction and land clearing is approximated at between 65,380 tons and 102,670 tons. Annual carbon dioxide reductions estimated by the applicant from using the Woodland Road versus other alternatives amount to between 7,218 tons and 4,124 tons. Thus somewhere between 17 and 125 years of use are required to put the project into a positive carbon balance situation depending upon which alternative is used for comparison. That’s if the applicant planned on mining for 17 years. Considering they only plan on mining for 7 years, the number of years required to eliminate the carbon deficit created by construction and clearing is extended. If annual carbon sequestration losses from cleared lands are included in the carbon dioxide balance, the minimum time required to put the project into a positive carbon balance situation increases to around 30-40 years.
Wetland Mitigation Determinations not properly considered; The statement that all wetlands have been included whether regulated or unregulated is presumptive. It is not the applicant’s prerogative to make this determination. The regulated versus unregulated determination is the responsibility of the state of Michigan.
Appropriate wetland mitigation not provided for; It appears that much of the applicants mitigation planning includes constructed wetlands, some of which will be constructed in borrow areas constructed for the project. This mitigation goal is convenient as opposed to appropriate. The likelihood of maintaining benefits and ensuring success of mitigation and no net loss of wetland benefits is not included but should be.
Some of the applicant’s mitigation plans include wetlands constructed in watersheds other than that which wetlands will be filled. This is improper and results in loss of watershed specific wetland benefits.
National Research Council's 2001 report entitled Compensating for Wetland Losses under the Clean Water Act.
Notes:
• Constructed wetlands have a high rate of failure and the goal should be for all mitigation wetlands to become self-sustaining.
• Certain types of wetlands should be avoided due to the unlikelihood of suitable replacement
• Current regulatory replacement ratio of 1.5 mitigation:1 acre destroyed is not providing adequate compensation.
• Need to finish reading.
Habitat Fragmentation and Species impacts:
The applicant’s conclusions about likely impact to terrestrial species from road construction contradict scientific research conclusions, current natural resource management knowledge, and current natural resource management and protection policy.
Habitat fragmentation impacts resulting from this project will be substantial and severe. The Michigan Wildlife Action Plan, developed through an intensive outreach and public participation process identified the major natural resource threats to Michigan’s fish and wildlife, and the major concerns of State residents. The two major issues identified as threats include invasive species introductions, and habitat fragmentation. , which is known to degrade fish and wildlife resources. The two major concerns of State of Michigan residents that were consistently raised also included invasive species introductions and habitat fragmentation. The Great Lakes Regional Collaboration and the Lake Superior Lakewide Management Plan (U.S. EPA) also identify and recognize habitat fragmentation as a major threat to sustaining fish and wildlife populations throughout Lake Superior basin.
Plans and policies in which habitat fragmentation are noted as major threats to fish and wildlife population resources.
The Lake Superior Lamp.
Great Lakes Regional Collaboration
Great Lakes Restoration Initiative
Michigan’s Great Lakes Restoration Strategy
Michigan Strategic Framework for the 2010 Great Lakes Restoration Initiative
Michigan Wildlife Action Plan
The applicant states that unbroken habitat is not present in the proposed project area. This is incorrect.
Chemical stressors and ambient air.
The applicant has not included any data or information about likely chemical inputs and stressors or ambient air quality.
Chemical inputs into the surrounding aquatic and terrestrial environments include heavy metals, salts, petroleum products, and likely sulfate.
Copper inputs into the surrounding area are likely and are of particular concern. Copper is toxic to aquatic organisms at very low concentrations.
Wetland acreage and linear footage = actual wetland acreage exposed to degradation from copper.
Need nickel and cobalt toxicity data.
Ambient air quality isn’t addressed or discussed.
Copper
Copper ore dust that will be released along the road is a particular concern. Copper is toxic to aquatic organisms at very low concentrations. All aquatic ecosystems along this road are likely to be negatively impacted by the input of copper. Downstream aquatic habitat will also be impacted by copper toxicity as material naturally migrates downstream.</description>
		<content:encoded><![CDATA[<p>Woodland Road Comments:<br />
Permit Application Review Timing: The timing of the application submittal does not allow for reasonable public review and input. The quantity and spatial distribution of aquatic and terrestrial resources which would be impacted by the proposed project is quite substantial. The remote nature and inaccessibility of the proposed project area during winter limits the ability of the public to verify submitted data and information or to confirm observations recorded.<br />
The DNRE consistently confirms that they value and recognize the need for public participation in the decision making process. Application materials have only recently been made available to the public and only limited data verification is possible. Major revisions were submitted on January 21st 2010 and only made available to the public on January 25th. Not allowing for reasonable public review, public fact checking, and public input into a permit review process only degrades the integrity of the process. Consider U.S. EPA insights contained in Stakeholder Involvement &amp; Public Participation at the U.S. EPA; Lessons Learned, Barriers, &amp; Innovative Approaches (January 2001), where they confirm “Often, data credibility depends upon whether the data can be produced or confirmed by an outside source.” “Without a concerted effort to ensure reliable, trustworthy data, the stakeholder process may prove frustrating for all participants involved.”<br />
Additionally, for a project with this degree of potential impact all voices should be heard and input solicited. Again using insight from the U.S. EPA “It can be easy to by-pass certain stakeholders and pull together a group where issues can be resolved with relative ease. However, lack of adequate participation or lack of effective means for participation can result in agreements or policies that do not necessarily reflect the interests of communities or constituencies that will be most impacted by them. “(Stakeholder Involvement &amp; Public Participation at the U.S. EPA; Lessons Learned, Barriers, &amp; Innovative Approaches January 2001)<br />
The Project review is out of context which leads to regulatory uncertainty and potential financial liability to the State of Michigan.<br />
The applicant’s project is one portion of their entire planned Yellow Dog Eagle Mine project and should be considered under the context and framework of Part 632 of NREPA. Considering this project outside that framework will potentially lead to both regulatory and liability uncertainties in the future for the State of Michigan if the project is approved. Mine haul roads are commonly found to be sources of environmental contamination of watersheds and groundwater, as storm water runoff carries heavy metals, oils, gas, sulfates, salts, and other contaminants into area aquifers, wetlands, and surface water bodies. Considering this proposed project outside the regulatory framework of Part 632 leads to uncertainty over what jurisdictional authority Michigan might have to require the applicant to address contamination problems when they develop in the future. Outside of the framework of Part 632 this proposed<br />
road and affected area will not necessarily be considered as part of the mining affected area as it should be. If this project is not considered as part of the Yellow Dog Plains mining project then the financial burden for cleanup and mitigation will likely fall upon the State of Michigan when environmental contamination problems develop.<br />
The project purpose statement is presumptive. The DNRE is under no obligation to accept the applicant’s project purpose statement as the defacto statement of project purpose.<br />
The applicant’s primary goal is to provide a route for transportation of ore from the planned Eagle Mine in the Yellow Dog Plains. Alternatives to the proposed project transport route are available for that purpose. Other partners of Woodland Road LLC have little to no interest in alternatives examined in this analysis. What interest will Mr. Jilbert or Lindbergs have in the Dishno Road or the AAA-550 alternative? Since the answer is likely none, then why are these alternatives examined? Why is John Cherry the signatory to all Woodland Road LLC documents?<br />
Timber companies have been transporting timber from areas in the Yellow Dog and Mulligan Plains, and the Michigamme Highlands for many years following existing routes. Recreation access is provided for through these same routes.<br />
The DNRE is the agency with the authority to examine materials submitted and determine the primary purpose of the project and make a decision accordingly.<br />
Public support incorrectly presumed; The applicant claims public support for this project based upon negative reaction to their other mining plan related project transportation proposals. Proper public input should be directly related to the issue being considered. This is a common mistake made by entities with little experience of working with the public. Concern expressed about a Great Lakes invasion by the silver carp can not be considered an expression of support for the big-head carp.<br />
Lack of primary data with which to evaluate impact<br />
The applicant has not provided any detail regarding numbers and type of vehicles anticipated. Numbers and types of vehicles anticipated is logically a primary piece of information necessary for a road construction project permit application and related environmental assessments. Certainly such basic information should be provided.<br />
Necessary data is missing; Data that is crucial for evaluation of this proposed project is missing. Some key data not included is as follows:<br />
• Proposed construction schedule and activities are not provided.<br />
• Wildlife corridors are not considered. Disruption of corridors will occur.<br />
• Amphibian data other than frog and toad survey is missing.<br />
• Anticipated traffic types and loads. References are made to 40 ton trucks and 100 ton trucks. Clarification is necessary.<br />
• Public use seems unlikely with the anticipated traffic types and truck tonnages. Public use will be unlikely if the applicant is running 100 ton trucks. Clarification is needed.<br />
• Chemical loading of the surrounding environment will occur and will include heavy metals, herbicides, salts, sulfates, petroleum products, blasting compounds including nitrates, and other contaminants. No data or information regarding these materials is included. This is a very significant omission without which the environmental impact of the project can not be determined.<br />
• Anticipated ambient air quality impacts resulting from road traffic are not determined or discussed. No data is provided. Ambient air quality degradation will occur and negative resource impacts will result. Additional data and information is needed.<br />
• Chemical composition and sources of fill is not clear.<br />
ALTERNATIVES ANALYSIS<br />
Transportation regulatory risks stated are not substantiated or likely; The applicant states that the City of Marquette, Ishpeming, and Negaunee, along with townships the County and Michigan Department of transportation have been actively planning for traffic levels in their jurisdictions. Any evaluations these entities are making has no unique relationship to Kennecott activities. Traffic evaluation and planning is part of the normal course of business for these entities. At between 2,000 – 50,000 vehicles per day on existing major routes through Marquette, Negaunee, and Ishpeming there is no conceivable situation in which truck traffic would be banned through these municipalities.<br />
Selected alternative need is presumed and not substantiated; A number of statements made by the applicant can not be supported by any data or information. The applicant states that mining activity is on the increase in northern Marquette County. This is incorrect. Currently there is no mining activity in northern Marquette County. The applicant has expressed a desire to develop a mining operation in the Yellow Dog Plains, however this plan is currently being contested. Considering the uncertainty of any mining project moving forward in the Yellow Dog Plains the potential value of mining is presumptive and speculative.<br />
Potential Woodland Road benefits are unsubstantiated; The applicant states that school children will be safer if Woodland Road is constructed but does not substantiate this with any supporting documentation or data. Appropriate data would include accident rates at their other facilities, safety records, vehicle maintenance records, and other such data. Claims of<br />
necessity for protection of children should not be made lightly and should not be made without supporting documentation. Failure to demonstrate such claims lessens the integrity of an application.<br />
The applicant states that construction of the Woodland Road will provide benefit through noise reduction on existing traffic routes but does not substantiate this with any supporting documentation or data. Many consultants are qualified to conduct noise studies. Failure to demonstrate such claims or provide data lessens the integrity of an application.<br />
The applicant suggests that construction of the Woodland Road will provide benefit for elderly persons and those with respiratory illnesses living along current existing routes by not exposing them to emissions from the mining truck traffic, but does not substantiate this with any supporting documentation or data. Emissions level and type can be predicted by modeling and with detailed traffic prediction analysis. Emissions level and impact should also be modeled for the proposed Woodland Road. Human health risk is a serious matter and any such health risk analysis should be supported by providing data and information used during the analysis. This is necessary for both regulators reviewing permit applications and for the general public.<br />
The applicant mentions that accidents will be reduced or prevented on existing routes if the Woodland Road is constructed but does not substantiate this with any supporting documentation or data. What is the applicant’s accident rate? What accident rates do they have at other facilities they operate? Anticipated accident rates for the Woodland Road should also be determined from existing data. This claim can not be evaluated without any data.<br />
The applicant states that the demand for emergency services has increased in the project area, but provides no data or information to support this claim. Supporting data should be provided such as 911 calls, emergency service vehicle traffic rates, specific examples, etc. This data and information is available if requested and should be required if this is used as to support presumed public benefit. Protection of human health and public safety is a serious matter and to properly evaluate needs supporting documentation is necessary. Failure to demonstrate such claims lessens the integrity of an application.<br />
Improved landowner access is claimed as a benefit, but is not supported by data or information, such as petitions, or descriptions of public meetings held to collect public input specific to this project. The applicant briefly states that there is support from numerous entities for the project but supplies no supporting data or information. Again, additional data and information is necessary to support such claims in the application.<br />
Benefits presumed and not substantiated; Public access is unlikely and should be discounted when considering this project. This proposed road would be privately owned with no<br />
guarantee of public accessibility. The applicant has a history of restricting public access to public lands in the Yellow Dog Plains. Security guards have been hired to prevent people from accessing CFR lands, the applicant has at times blocked off vehicle access to the Northwest Road, which it does not own, and the applicant has informed people that access to its own CFR lands is trespassing and requires written permission. Current and past behavior can be used to predict future behavior and actions, or at least establish the lack of certainty for public access. This uncertainty regarding the potential for public access is sufficient to remove public access potential as a consideration when reviewing potential public benefits.<br />
Greenhouse Gas Reduction Benefits; The applicant claims that the greenhouse gas reduction benefits and savings are substantial enough that by themselves they justify the project.<br />
Stated Greenhouse Gas Savings are Incorrect; Greenhouse gas accounting is a complex and evolving science and thus it is no surprise that the applicant has incorrectly determined that their project will result in greenhouse gas savings. When the project is examined properly greenhouse gas emissions become a neutral or negative issue if considered in the decision. Greenhouse gas balance calculations for this particular project would require considerations of construction, land clearing, maintenance, and use. Also associated with project would be sequestration loss of forests and understory through maintenance of cleared land for the Woodland Road. Of the four main factors necessary to consider for determining a carbon balance for the proposed Woodland Road, the applicant has only examined one – road use.<br />
Precise calculations are complex as stated previously and more project detail is needed. However, approximate green house balance for the project can be determined.<br />
Carbon dioxide generated during project construction and land clearing is approximated at between 65,380 tons and 102,670 tons. Annual carbon dioxide reductions estimated by the applicant from using the Woodland Road versus other alternatives amount to between 7,218 tons and 4,124 tons. Thus somewhere between 17 and 125 years of use are required to put the project into a positive carbon balance situation depending upon which alternative is used for comparison. That’s if the applicant planned on mining for 17 years. Considering they only plan on mining for 7 years, the number of years required to eliminate the carbon deficit created by construction and clearing is extended. If annual carbon sequestration losses from cleared lands are included in the carbon dioxide balance, the minimum time required to put the project into a positive carbon balance situation increases to around 30-40 years.<br />
Wetland Mitigation Determinations not properly considered; The statement that all wetlands have been included whether regulated or unregulated is presumptive. It is not the applicant’s prerogative to make this determination. The regulated versus unregulated determination is the responsibility of the state of Michigan.<br />
Appropriate wetland mitigation not provided for; It appears that much of the applicants mitigation planning includes constructed wetlands, some of which will be constructed in borrow areas constructed for the project. This mitigation goal is convenient as opposed to appropriate. The likelihood of maintaining benefits and ensuring success of mitigation and no net loss of wetland benefits is not included but should be.<br />
Some of the applicant’s mitigation plans include wetlands constructed in watersheds other than that which wetlands will be filled. This is improper and results in loss of watershed specific wetland benefits.<br />
National Research Council&#8217;s 2001 report entitled Compensating for Wetland Losses under the Clean Water Act.<br />
Notes:<br />
• Constructed wetlands have a high rate of failure and the goal should be for all mitigation wetlands to become self-sustaining.<br />
• Certain types of wetlands should be avoided due to the unlikelihood of suitable replacement<br />
• Current regulatory replacement ratio of 1.5 mitigation:1 acre destroyed is not providing adequate compensation.<br />
• Need to finish reading.<br />
Habitat Fragmentation and Species impacts:<br />
The applicant’s conclusions about likely impact to terrestrial species from road construction contradict scientific research conclusions, current natural resource management knowledge, and current natural resource management and protection policy.<br />
Habitat fragmentation impacts resulting from this project will be substantial and severe. The Michigan Wildlife Action Plan, developed through an intensive outreach and public participation process identified the major natural resource threats to Michigan’s fish and wildlife, and the major concerns of State residents. The two major issues identified as threats include invasive species introductions, and habitat fragmentation. , which is known to degrade fish and wildlife resources. The two major concerns of State of Michigan residents that were consistently raised also included invasive species introductions and habitat fragmentation. The Great Lakes Regional Collaboration and the Lake Superior Lakewide Management Plan (U.S. EPA) also identify and recognize habitat fragmentation as a major threat to sustaining fish and wildlife populations throughout Lake Superior basin.<br />
Plans and policies in which habitat fragmentation are noted as major threats to fish and wildlife population resources.<br />
The Lake Superior Lamp.<br />
Great Lakes Regional Collaboration<br />
Great Lakes Restoration Initiative<br />
Michigan’s Great Lakes Restoration Strategy<br />
Michigan Strategic Framework for the 2010 Great Lakes Restoration Initiative<br />
Michigan Wildlife Action Plan<br />
The applicant states that unbroken habitat is not present in the proposed project area. This is incorrect.<br />
Chemical stressors and ambient air.<br />
The applicant has not included any data or information about likely chemical inputs and stressors or ambient air quality.<br />
Chemical inputs into the surrounding aquatic and terrestrial environments include heavy metals, salts, petroleum products, and likely sulfate.<br />
Copper inputs into the surrounding area are likely and are of particular concern. Copper is toxic to aquatic organisms at very low concentrations.<br />
Wetland acreage and linear footage = actual wetland acreage exposed to degradation from copper.<br />
Need nickel and cobalt toxicity data.<br />
Ambient air quality isn’t addressed or discussed.<br />
Copper<br />
Copper ore dust that will be released along the road is a particular concern. Copper is toxic to aquatic organisms at very low concentrations. All aquatic ecosystems along this road are likely to be negatively impacted by the input of copper. Downstream aquatic habitat will also be impacted by copper toxicity as material naturally migrates downstream.</p>
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		<title>Comment on Woodland Road - Written Comment Accepted Until 20th by Georgia Donovan</title>
		<link>http://www.savethewildup.org/blog/woodland-road-written-comment-accepted-until-20th/comment-page-1/#comment-9087</link>
		<dc:creator>Georgia Donovan</dc:creator>
		<pubDate>Sat, 13 Feb 2010 19:15:34 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1385#comment-9087</guid>
		<description>As we lose more and more habitat many species are stressed. We need to preserve the wetlands of the Yellow Dog Plains before they are damaged by the proposed Kennecott mine! Also the ruling that Eagle Rock is a sacred site should be RESPECTED.
This is not a good or safe location for mining, and the toxic waste that will be created.  - Georgia Donovan, chapter president of Izaak Walton League of America</description>
		<content:encoded><![CDATA[<p>As we lose more and more habitat many species are stressed. We need to preserve the wetlands of the Yellow Dog Plains before they are damaged by the proposed Kennecott mine! Also the ruling that Eagle Rock is a sacred site should be RESPECTED.<br />
This is not a good or safe location for mining, and the toxic waste that will be created.  - Georgia Donovan, chapter president of Izaak Walton League of America</p>
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		<title>Comment on Woodland Road - Written Comment Accepted Until 20th by CRAIG FOSMO</title>
		<link>http://www.savethewildup.org/blog/woodland-road-written-comment-accepted-until-20th/comment-page-1/#comment-9086</link>
		<dc:creator>CRAIG FOSMO</dc:creator>
		<pubDate>Sat, 13 Feb 2010 04:01:43 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1385#comment-9086</guid>
		<description>1/4 east of the wolf lake road,there is a creek that empties into brocky lake.also another mile down the same two track road is a hair pin curve that used to be a beaver dam.this is covered with logging tops so very little of the water shows,but this empties into a very large pond with aprox 5' depth.I REMEMBER BALANCING ON THE EDGE OF THIS AND SEEING WHERE THE OTTERS WERE HAD A SLIDE.WE THE FOSMO FAMILY HAVE HUNTED AND FISHED THIS AREA FOR OVER A HUNDRED YEARS.THIS SHOULD BE TREATED AS A NATIONAL TREASURE AND NOT DISTURBED,</description>
		<content:encoded><![CDATA[<p>1/4 east of the wolf lake road,there is a creek that empties into brocky lake.also another mile down the same two track road is a hair pin curve that used to be a beaver dam.this is covered with logging tops so very little of the water shows,but this empties into a very large pond with aprox 5&#8242; depth.I REMEMBER BALANCING ON THE EDGE OF THIS AND SEEING WHERE THE OTTERS WERE HAD A SLIDE.WE THE FOSMO FAMILY HAVE HUNTED AND FISHED THIS AREA FOR OVER A HUNDRED YEARS.THIS SHOULD BE TREATED AS A NATIONAL TREASURE AND NOT DISTURBED,</p>
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		<title>Comment on South Road - Wetlands Destruction Permit (Public Hearing) by robert maki</title>
		<link>http://www.savethewildup.org/blog/south-road-wetlands-destruction-permit-public-hearing/comment-page-1/#comment-9078</link>
		<dc:creator>robert maki</dc:creator>
		<pubDate>Thu, 04 Feb 2010 04:51:42 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1310#comment-9078</guid>
		<description>rio tinto, owned by the rothschild banking system,controllers of the federal reserve, which is not part of our government, the world bank, international monetary fund, and numerous other businesses including gold,oil,bonds, and all central banks of the world, except five countries, has polluted wherever they have mined around the world, and have have human rights violations apparently. they don't care about pollution, which is beyond understanding because this is a small world and they also have to live on it.</description>
		<content:encoded><![CDATA[<p>rio tinto, owned by the rothschild banking system,controllers of the federal reserve, which is not part of our government, the world bank, international monetary fund, and numerous other businesses including gold,oil,bonds, and all central banks of the world, except five countries, has polluted wherever they have mined around the world, and have have human rights violations apparently. they don&#8217;t care about pollution, which is beyond understanding because this is a small world and they also have to live on it.</p>
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		<title>Comment on All Things Kennecott Considered by Sara  Culver</title>
		<link>http://www.savethewildup.org/blog/all-things-kennecott-considered/comment-page-1/#comment-9076</link>
		<dc:creator>Sara  Culver</dc:creator>
		<pubDate>Sat, 30 Jan 2010 15:05:57 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1359#comment-9076</guid>
		<description>Please email me the most recent news; I am trying to compose letters that I can send to newspapers and legislators.

In order for these letters to be at all effective, I must include not only informatiion, but information that will interest the audience.</description>
		<content:encoded><![CDATA[<p>Please email me the most recent news; I am trying to compose letters that I can send to newspapers and legislators.</p>
<p>In order for these letters to be at all effective, I must include not only informatiion, but information that will interest the audience.</p>
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		<title>Comment on Ballot Initiative Moves Forward by Tom DWYER</title>
		<link>http://www.savethewildup.org/blog/ballot-initiative-moves-forward/comment-page-1/#comment-9070</link>
		<dc:creator>Tom DWYER</dc:creator>
		<pubDate>Sun, 24 Jan 2010 17:15:18 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1212#comment-9070</guid>
		<description>There are alot of people in the lower that want to sign your petition. Keep up the good work. Tom</description>
		<content:encoded><![CDATA[<p>There are alot of people in the lower that want to sign your petition. Keep up the good work. Tom</p>
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		<title>Comment on South Road - Wetlands Destruction Permit (Public Hearing) by Kay Arcand</title>
		<link>http://www.savethewildup.org/blog/south-road-wetlands-destruction-permit-public-hearing/comment-page-1/#comment-9067</link>
		<dc:creator>Kay Arcand</dc:creator>
		<pubDate>Fri, 15 Jan 2010 22:45:03 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1310#comment-9067</guid>
		<description>Please keep me informed about Kennecott's latest escapades.  I highly oppose the approval of "Woodland south road".  Please put my new e-mail address on your list.  Former address was: engstromkay@hotmail.com.

Thanks.</description>
		<content:encoded><![CDATA[<p>Please keep me informed about Kennecott&#8217;s latest escapades.  I highly oppose the approval of &#8220;Woodland south road&#8221;.  Please put my new e-mail address on your list.  Former address was: <a href="mailto:engstromkay@hotmail.com">engstromkay@hotmail.com</a>.</p>
<p>Thanks.</p>
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		<title>Comment on Ballot Initiative Moves Forward by savethewildup</title>
		<link>http://www.savethewildup.org/blog/ballot-initiative-moves-forward/comment-page-1/#comment-9056</link>
		<dc:creator>savethewildup</dc:creator>
		<pubDate>Mon, 04 Jan 2010 02:18:20 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1212#comment-9056</guid>
		<description>Dean, 
As soon as we get the go-ahead from MIWater Committee, it will be made very public as to where you can sign a petition.
Thanks for asking!. 
SWUP staff</description>
		<content:encoded><![CDATA[<p>Dean,<br />
As soon as we get the go-ahead from MIWater Committee, it will be made very public as to where you can sign a petition.<br />
Thanks for asking!.<br />
SWUP staff</p>
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		<title>Comment on Ballot Initiative Moves Forward by Dean Johnson</title>
		<link>http://www.savethewildup.org/blog/ballot-initiative-moves-forward/comment-page-1/#comment-9055</link>
		<dc:creator>Dean Johnson</dc:creator>
		<pubDate>Mon, 04 Jan 2010 01:24:58 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1212#comment-9055</guid>
		<description>Where and when can I sign the petition?</description>
		<content:encoded><![CDATA[<p>Where and when can I sign the petition?</p>
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		<title>Comment on South Road – Projected Pollution Corridor by Beer Man</title>
		<link>http://www.savethewildup.org/blog/south-road-%e2%80%93-projected-pollution-corridor/comment-page-1/#comment-9048</link>
		<dc:creator>Beer Man</dc:creator>
		<pubDate>Mon, 28 Dec 2009 15:19:17 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1232#comment-9048</guid>
		<description>This is a very inaccurate article, why not compare apples to oranges. The are many factors that don't match between the two cases, ex: climate, technology (fully contained trailers), mining procedures, ect.</description>
		<content:encoded><![CDATA[<p>This is a very inaccurate article, why not compare apples to oranges. The are many factors that don&#8217;t match between the two cases, ex: climate, technology (fully contained trailers), mining procedures, ect.</p>
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		<title>Comment on Western Shoshone Prevail at Ninth Circuit Court on Mining Sacred Land by TWilliams</title>
		<link>http://www.savethewildup.org/blog/western-shoshone-prevail-at-ninth-circuit-court-on-mining-sacred-land/comment-page-1/#comment-9033</link>
		<dc:creator>TWilliams</dc:creator>
		<pubDate>Thu, 17 Dec 2009 17:08:54 +0000</pubDate>
		<guid isPermaLink="false">http://www.savethewildup.org/blog/?p=1301#comment-9033</guid>
		<description>What is interesting is if you google this issue and read the newspaper articles you'll find that there is very divergent opinion about this decision within the bands considered the Western Shoshone.  Any chance of getting the opinions of the bands in support of the mine posted?</description>
		<content:encoded><![CDATA[<p>What is interesting is if you google this issue and read the newspaper articles you&#8217;ll find that there is very divergent opinion about this decision within the bands considered the Western Shoshone.  Any chance of getting the opinions of the bands in support of the mine posted?</p>
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