Monday, November 26, 2012

Letter: One more for the Road

Another deadline approaches for (Marquette) County Road 595. The EPA expects to announce their final decision by December 1. Our legislators continue to pressure EPA at all levels, but we can’t let them have the last word. It’s time to raise some ire, muster your energy, and comment one more time.

This photo was taken from the old 510 bridge. It shows a plow spraying snow and presumably salt off the new 510 bridge and into the Dead River. The author of this letter says, "The impacts of similar activity at the 22 stream crossings described in the CR 595 permit application would be completely unacceptable." (Photo © and courtesy Catherine Parker)

Letters do not have to be lengthy, but they should be reasonable. Please tell the EPA why they should maintain their objections to the permit application. Here are some key points that you might use and/or expand upon in your letter:

Donation of off-site wetland areas by one of the interested parties does nothing to lessen the damage that would be done to the proposed 595 corridor.
  • Bisecting a relatively undisturbed area with a road this size would have severe impacts on wildlife.
  • Construction of new stream crossings and increased traffic will cause significant harm to aquatic resources.
Wildcat Canyon Falls. This waterfall is part of Wildcat Canyon Creek, which empties into the west end of the Silver Lake Basin. CR 595 would cross the creek and wetlands approximately a mile upstream from the falls. (Photo © and courtesy Catherine Parker)

There is no pressing public need for a new highway in northwest Marquette County.
  • CR 595 would be a dead-end road.
  • Building this road would likely result in more emergency calls, further straining fire department and other emergency services, as well as state police and sheriff’s department resources.
  • Rio Tinto admits that we’ll see less traffic during the operational phase of the mine than we have during construction.
  • There is no significant projected increase in logging activity for this region.
  • So-called beneficiaries, described in the permit application, have found existing roads to be both feasible and prudent for their purposes.
The 595 applicants have so narrowly defined their project purpose as to eliminate all but their preferred alternative. They have done this in an effort to force approval of Rio Tinto’s route.

Michigan DNR and DEQ field staff recommendations, and comments from USFWS (US Fish and Wildlife Service) and USACE (US Army Corps of Engineers), have been disregarded or overruled by the directors of both of these state agencies, presumably under Governor Snyder’s instructions.

Since the primary purpose of CR 595 would be to haul ore from Rio Tinto’s mine on the Yellow Dog Plains to its mill in Humboldt Township, cumulative impacts of all three components must be considered. Rio Tinto is "piecemealing" its project in an attempt to avoid additional environmental review, which is forbidden.
           
Allowing or encouraging a public agency to take over the permitting process for private interests sets a bad precedent. A permit may be denied solely on the basis of deception.

This project would not be a job-creator: Logging activity is not projected to increase significantly; 595 would not increase the amount of mining in the area (according to the permit application); and upgrading existing roads would create more work than new construction.

Rio Tinto has used Woodland Road/CR 595 as a way to divide the community and detract attention from allegations of fraud and inadequacy regarding its mine permits.

The Marquette County Road Commission has been accepting RFQs, or proposals, for both construction of CR 595 and upgrades to Rio Tinto’s currently permitted haul route (Triple A-510-550), demonstrating that using existing roads is both feasible and prudent.

The purpose of Part 303, Wetlands Protection, is "to ensure the preservation and protection of the wildlife habitats known as wetlands." The 595 corridor contains rare wetlands resources that cannot be replaced. They provide critical benefits within the affected watersheds.

Please e-mail your letter as soon as possible, to Susan Hedman, EPA Region 5 Adminstrator: Hedman.Susan@epa.gov and copy to these additional addresses: Hyde.Tinka@epa.gov, Haveman.Melanie@epamail.epa.gov, Elston.Sue@epamail.epa.gov, Swenson.Peter@epamail.epa.gov. *

Thank you, one more time.

Catherine Parker
Marquette, Michigan 

*Note:
Click here for additional talking points.
Click here for  official comments.

Editor's Note: See Keweenaw Now's coverage of the Aug. 28, 2012, EPA Public Hearing on CR 595:
"EPA Hearing on CR 595 permit: Part 1, Questions" and
"EPA Hearing on CR 595: Part 2: Comments"

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