Tuesday, October 13, 2015

Letter to DNR: Save the Wild U.P. requests moratorium on mineral leasing, public hearing on 320-acre lease request from North American Nickel

This Andersen archaeological site, damaged during recent resource extraction activities, is located within the 320 acres of public land, in section 35, Michigamme Township, where North American Nickel has requested a metallic mineral lease. (Photo courtesy Save the Wild U.P.)
[Editor's Note: Save the Wild U.P. (SWUP) recently sent a letter to the Michigan Dept. of Natural Resources (DNR) with their comments on North American Nickel's request for a metallic mineral lease on 320 acres of public land in Section 35 of Michigamme Township, Marquette County, Michigan. We are publishing part of their letter here at SWUP's request.]

Karen Maidlow, MAIDLOWK@michigan.gov
Property Analyst, Minerals Management
Department of Natural Resources
P.O. Box 30452
Lansing, MI 48909
October 12, 2015

Dear Ms. Maidlow,

On behalf of Save the Wild U.P.’s Board of Directors, Advisory Board members, and SWUP’s supporters, we strongly urge the Department of Natural Resources (DNR) to deny the mineral lease sought by North American Nickel, Inc. for 320 acres of State-owned land on the Yellow Dog Plains (SW1/4; N1/2 SE1/4; W1/2 NW1/4, Section 35, T51N, R29W, Michigamme Township, Marquette County).

We ask the DNR to deny this mineral lease for the following reasons:

Ecological Concerns

Ecologically, this land is part of the Escanaba River State Forest, and supports a jack pine forest habitat, including age/class critical to the endangered Kirtland’s warbler. The DNR lease review acknowledges the possible (?) presence of this species. Does the lease review process involve any on-site review? Kirtland’s warblers have been seen in this area by local birdwatchers. We ask the DNR to conduct a rare species survey on the property before further ecological disruption is sanctioned, in collaboration with local experts and environmental stewards who are deeply familiar with the land. Moreover, we request that the DNR complete a landscape-scale habitat preservation plan for the Yellow Dog Plains, with an eye to Kirtland’s warbler conservation. The current Land Management Plan for the Yellow Dog Plains is out of date, and fails to address any of the industrial threats. The Yellow Dog Plains is seasonally used by migratory songbirds and waterfowl, which are unaddressed in the lease review.

Endangered Kirtland's Warbler. (Photo © and courtesy Joseph Youngman. Reprinted with permission.)

According to the DNR’s Management Plan for the Yellow Dog Plains, this area "provides multiple benefits including forest products, dispersed recreational activities, and provides habitat for a variety of fish and wildlife species" and the DNR's stated management priority in this area "is to continue to provide these multiple benefits..."

Note: Mineral exploration was NOT listed among the DNR’s management priorities for this land.

Archaeological Concerns

The DNR lease review acknowledges the presence of a site of "archaeological significance" on this land. While confirming the nature of this archaeological site (a homestead), it has come to our attention that this significant site has never actually been evaluated. There is a standing ruin on the property, but also a number of related sites on the property that would be difficult for a mineral exploration team to "see" much less avoid disturbing.

Historically, this land is an integral part of our collective culture. As historian Jon Saari has noted, "The Yellow Dog Plains is one of those storied places in our collective
imagination. That place, and the larger community we live in, includes rivers, forests, wildlife, rocks and waterfalls, and quiet backwoods camps."

Archaeologically, the site contains a remnant structure from the Andersen Homestead, directly connected to the land’s first European settlers, the result of the controversial Homestead Act. The Nels Andersen homestead (misspelled Anderson on some maps and sources), was built by early Danish immigrants who settled on the Yellow Dog Plains in 1902. Additionally, the history of the Andersen family and their homestead are interwoven with the history of White Deer Lake, as members of the Andersen family were employed by industrialist Cyrus McCormick -- land now preserved as the McCormick Wilderness Area. Photographs, oral histories and stories related to the Andersen site were recorded by the late historian and storyteller, C. Fred Rydholm, in Superior Heartland: A Backwoods History.

North American Nickel, Inc, is seeking a new mineral lease for 320 acres of Public Land (area in brown) on the Yellow Dog Plains. Grassroots environmental group Save the Wild U.P. is urging the Michigan DNR to reject the mineral lease application, stating that it threatens to undermine critical habitat for the Kirtland’s Warbler, and a site of historical significance. Click here for a larger version of the map. (Map courtesy Save the Wild U.P.)

Prior to the 1900’s, the plains were frequented via a trail between L’Anse and Big Bay, used for hunting and berry-picking, with a strong pre-European Indigenous presence. Much evidence of this ancient trail was obliterated in 2014, when the historic sand road was replaced with a highway (pavement ends at the gates of Eagle Mine, approximately 3 miles SE of this historic site).

Recently, the physical integrity of the Andersen historical site was severely damaged during the DNR’s logging of the public forest. The damage has not been remedied, and may have been undocumented. This fragile archaeological site will only be further compromised by new mineral exploration, and increased traffic on the 2-track roads that pass the ruins. This lease request (North American Nickel, Inc.) follows a mineral lease granted to Prime Meridian; it is clear that the Andersen archaeological site was damaged and the environment degraded during the tenure of that mineral lease -- without DNR intervention.

Save the Wild U.P. respectfully requests that a moratorium on mineral leasing be instituted until the integrity of all Andersen historical sites, and their archaeological significance, can be fully evaluated.

Indigenous Natural Resources

Contemporary tribal uses of this land include the gathering of traditional foods and medicines, in accordance with protected treaty rights. Given the long history of pre-European Indigenous presence, the Yellow Dog Plains have a cultural value -- beyond their ecological value, watershed, mineral or timber value -- deeper than the value of any individual archaeological site. This land should be seen as an integral part of the human culture and natural history of Marquette County, the Keweenaw Bay Indian Community, "the wild U.P." and the State of Michigan as a whole.

Hydrological Concerns

In their Management Plan for the Yellow Dog Plains unit, the DNR states that "almost all state lands are leased and extensive exploration has been conducted" yet notes "there is insufficient data to determine the glacial drift thickness" on the Yellow Dog Plains.

Clearly, the State of Michigan is allowing a live experiment -- industrialization of a remote and previously unpolluted environment -- to play out in real time, with insufficient monitoring and a pattern of "insufficient data."

If the DNR does not possess sufficient data about the thickness of glacial sand deposits in this area, they must also lack sufficient understanding of the complex hydrogeology of the Yellow Dog Plains, especially the groundwater aquifer contained in these glacial sands, an aquifer which is currently pristine and without industrial contamination.

Groundwater from the NW Yellow Dog Plains aquifer feeds the headwaters of several rivers and coldwater trout streams, such as Cedar Creek, Salmon Trout River, Yellow Dog River -- and unique spring-fed ponds, including nearby Andersen Lake, which provide key habitat for mammals (especially predators crossing the Yellow Dog Plains), migratory birds, reptiles, amphibians, insects and native plants, including threatened species.

No watershed information is included in this mineral lease application, but we assume that surface water (precipitation) on this parcel drains into headwaters of Cedar Creek, flowing into Mountain Lake en route to Lake Superior. Mountain Lake is a pristine wilderness lake of critical scientific research value, located entirely within the Huron Mountain Club. Groundwater in this parcel, by contrast, feeds the Salmon Trout River. Mineral exploration poses serious and apparently unconsidered risks to groundwater. We ask that the DNR explain how mineral exploration is regulated with regards to drilling in this unconfined sand aquifer, given the "insufficient data" about the land’s hydrogeology, and lack of oversight in the field.

Note: if the DNR is truly interested in hearing the public comments about mineral leasing of State lands on the Yellow Dog Plains and elsewhere, we believe the ideal venue for this exchange of information would be a Public Hearing -- something which Save the Wild U.P. has repeatedly requested....Click here to read the rest of this letter.

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