A Voice Crying in the Wilderness, for the Wilderness

(A Response the PolyMet Draft Environmental Impact Statement)

The proposed PolyMet Mine at the edge of the Boundary Waters is an obvious example of politically expedient, short sighted public policy initiatives that have a nasty habit of gaining traction and becoming impossible to stop. The process through which this idea is being implemented is an ideal representation of internal parasitism—the corruption of the political process by narrow economic interests. Mancur Olson called these distributional associations—highly organized, well financed, and relatively small associations that are able to drive public policy toward their own economic interest against the public interest. (Mancur Olson, The Rise and Decline of Nations, Yale University, 1982) PolyMet and its lobbying arm, Mining Minnesota, have successfully co-opted the local politicians in Northeastern Minnesota with their mantra of “jobs, jobs, jobs” to bring this destructive project to fruition. The jobs mantra is often used to justify special interest rent seeking at the state and local level. At the federal level national defense is an additional excuse for special interest corruption. This all purpose justifier ignores the fact that some jobs have adverse social impacts that outweigh any supposed benefits. A prime example is the creation and marketing of tobacco products. This creates jobs and provides wealth to the corporations in the tobacco business, and tax revenues to government. But the product has no other purpose than to cause addiction, illness, and death, which, unfortunately, creates other jobs in the health care and funeral industries, all of which increase that sacrosanct indicator of economic growth--GDP. It has now become evident that some high paying, “good jobs” in the finance industry have decimated the economy that they are supposed to promote. The fact that the jobs associated with this project will defoliate, consume, and pollute a priceless resource that would generate far more lasting value if left alone puts it in the same category.

The environmental arguments against this project are so overwhelming that its rejection ought to be a no brainer. Since these arguments have been presented elsewhere (e.g. http://nmw.org/issues/sulfide%20index%20page.htm, http://minnesota.publicradio.org/display/web/2010/01/12/loch/, and http://www.preciouswaters.org/# ), I will not bother to repeat them here. Rather I shall focus on some issues that may have received less attention. This whole problem began with the ill-advised leasing of state lands in Minnesota for mining exploration. This raises the question about the property rights attached to these lands. Supposedly these lands are held in the interest of all the citizens of Minnesota, and their acquisition and maintenance are supported by the tax payments of those citizens. The state justifies mineral exploration on the grounds that it will create jobs and drive economic growth. (It ought to be obvious that unlimited economic growth, by treating the earth as both a source and a sink, will consume and pollute the biosphere to our own detriment. The fact that this is not obvious is too complex to address here.) This promise of economic activity captures the interest of the “local leaders” in the communities near the areas where minerals are found. But living in the local area does not confer a property right to the resources in the area that are on public lands. Leasing these lands, however, initiates a pseudo-legitimate transfer of property. (Legality is not the issue here. Unfortunately much corruption is legal which has resulted in a general complacency regarding it.) The end result is that the some local residents behave as if they have a special use right to the property to the detriment of the more diffuse interests of the rest of the citizens of the state. When all the negative externalities are added in, the issue of property rights becomes far more complex. What about the pollution of the Boundary Waters, a resource that belongs to all citizens of the United States, and is used by national and international visitors? What about the pollution of adjacent private lands? What about pollution of waterways that may affect Canada and air pollution that has worldwide effects? The fact that the approval of this proposal will inevitably lead to the approval of several more such “projects” magnifies the complexity and cumulative impact of these issues. This cumulative impact only received passing mention in the DEIS.

In addition to negative externalities, there are transcendental values that are ignored by the economic calculations. These include natural beauty, the experience of being in the relatively unspoiled natural world, outdoor recreation, and the satisfaction of knowing that our natural heritage is preserved even though we may never visit it. Evidence is now beginning to accumulate that modern man is starting to suffer from a nature deficit disorder. The fact that we are becoming so divorced from the natural world may have deleterious consequences for human evolution. The wanton destruction of our natural areas will only hasten the development of this condition. Since transcendental values are not amenable to valuation by the price mechanism, they are not adequately accounted for in the economic calculations used to justify this ill-advised project. In addition, the failure to account for these values violates inter-generational equity since we will be leaving a despoiled environment to our descendents.

The alleged benefits upon which this project is justified are local, short term and short sighted. The non-local benefits will accrue to an alien corporation. It has been argued that this project should go forward because we need to import most of these minerals from countries that do not share our environmental standards*, and that the shipping of the imported minerals will leave an extremely heavy carbon footprint. However, this argument implies that these mining projects are a substitute for mining projects elsewhere. They are not substitutes, but additions thereto. Since the minerals from this project will be sold on the world market, they are more likely to end up in China which will only add additional shipping and an increased carbon footprint. Once the resource is depleted; a massive pile of waste will remain. History is very clear when it comes to clean-up after projects like this are completed—it does not get done. The corporate organization of the mining industry is designed to avoid these costs. PolyMet is a subsidiary of a parent organization conveniently located in Canada. Once the resource is exhausted, the subsidiary will declare bankruptcy after transferring its assets to its parent, leaving the citizens of Minnesota with a permanent toxic mess. In addition, unfortunately, those who are responsible for this irresponsible decision will not be in place to be held accountable once the environmental consequences become evident.

The draft environmental impact statement for this project is a massive document that cannot be adequately reviewed in the time period allocated for public comment. Since this project impacts the Superior National Forest, Lake Superior, an international body of water, and the atmosphere which is obviously international, public notice for review and comment should have at least been distributed nationally. The document is based on many assumptions, which it admits, are uncertain. Many of these are based on the experience of iron mining which is wholly illegitimate. The type of mining proposed here, because of its highly acidic production process and the low grade quality of the ore, will produce toxic runoff that will continuously seep into the watershed. A fancy statistical technique—uncertainty analysis—was employed to get around these uncertain assumptions. But how free is this method of bias since it was based on “data, professional judgment, and literature values that were approved by the resource agencies” that have the mission of permitting this project? The wetland mitigation proposals make absolutely no sense. The wetlands impacted are in a sensitive watershed that depends on them to store, release, and filter water into the watershed. Creating wetlands in a different watershed may meet legal requirements, but will not undo the damage to the impacted watershed. Perhaps the saddest part of the DEIS is its coversheet. Three of its pictures depict the area that this massive blueprint for a toxic waste dump seeks to bequeath to posterity as a monument of our ignorance. The pursuit of this project based on such uncertain and erroneous assumptions is nothing but an act of technological hubris which conflates commercial feasibility with environmental stewardship. The only responsible and reasonable alternative is the no action alternative. Unlike other ill-advised policy initiatives, this one cannot be corrected by future action. Once the damage is done, it is permanent and irreversible. It is sad that the citizens of Minnesota did not have the wisdom and foresight to enact an Environmental Protection Amendment to the state constitution that could have prevented folly such as this. But, a political culture that is accelerating into degeneration cannot be expected to produce wisdom and foresight.

* Governor Pawlenty, in his 2010 State of the State speech, ordered the executive agencies to speed up the permitting process, and then at the end of the speech, had the audacity to extol the natural beauty of Minnesota.