Public Comments of Andi Rich, supporter of the Coalition to Save the Menominee River
DEQ Public Meeting in Stephenson, MI – January 9, 2019

Why are we being required to review amendments of such a large project with changes so extensive that they can only be described as a full rewrite?

It is not reasonable to expect the public to filter the already-complex documentation initially submitted, in addition to the exorbitant amount of changes, and I would like to make the common sense request that as this project no longer resembles the initially approved permitted project, that Aquila should be allowed to walk away from the initial permit; but, in order to obtain a valid permit for this entirely new project, they should re-submit their request as a new permit application. This is the only way to allow an organized, fair, and thorough review, unobscured by the tremendous new amount of documents to review.

Citing the 2012 Earthworks report: 100% of the fourteen mines studied experienced pipeline spills or other accidental releases, 92% had water collection and treatment systems that failed to control contaminated mine seepage, tailing spills occurred at nine of the operations, and a partial failure of the tailings impoundment occurred at four out of fourteen mines (over 25%). Total costs for just seven of these 16 large failures was $3.8 billion, at an average cost of $543 million per failure.

With an average $543 million price tag for errors, the EXPECTATION BY AQUILA that the DEQ review what basically amounts to a completely new permit request (but harder to follow), with innumerable chain reactions from each change, IS UNREALISTIC, since the likelihood of our community members and even trained professionals, such as yourselves, to complete this exorbitant task with any type of accuracy is not only unlikely, it is also unrealistic.

When small, fairly common errors that occurred in 100% of the sulfide mines reviewed by Earthworks come with an average price tag of millions of dollars, I submit that our community deserves a permit application that is far more comprehensive than this jumbled mess of changes. Our safety depends on it.