Bald Mountain Resource Directory Of Past Study & Exploration

Bald Mountain History & Study 1977-1998

This directory , which is still in development, is intended to provide an annotated bibliography with links to all the study of Bald Mountain in Aroostook County Maine since it was first discovered in 1977 by Mainer JS Cummings. It is intended to serve legislators, government and non-government agencies researchers and journalists.  Its organization may change over time but will be grouped alphabetically by topic and within that by date  from earliest to most recent. The documents I have  created from the actual permit history at Bald Mountain are stored in google docs.

Steffen Roberson & Kirsten ( now SRK) has refused permission for this publication and asserted copyright protection but “facts” are not copyrightable nor are “facts” organized  and copied in standard graphs, tables, maps,  or “facts” derived from measurement whether the measurement was by original means or not.  All of the measurements and their presentation here  are “facts” without copyright protection.  Whatever privilege may have been agreed to contractually by the entity commissioning the report and the entity creating it no longer existed when the reports became part of an application for a permit with a public agency.

Lindsay Newland Bowker, CPCU ARM, Environmental Risk Manager
Bowker Associates
Science & Research In The Public Interest
15 Cove Meadow Rd
Stonington, Maine 04681

207 367 5145

ARD Generation Analysis

Steffen Roberston& Kirsten (B.C.) Inc. Report80701/2 “Report on the Acid Generation Characteristics of Mine Wastes For the Proposed Bald Mountain Project” Prepared for Boliden Resources Inc.  August 1990

Here is a graphic depiction of that report applying globally recognized risk criteria to characterize the 29 samples which formed the basis of this SRK 1990 assessment of Bald Mountain

My analysis accompanying distribution of this report to legislators, journalists, environmental advocates and global recognized experts with whom I have been in touch for about 18 months accompanied email transmission.

At the outset of taking over the lease from Chevron, Boliden, who were very experienced in  mining Volcanogenic Massive Sulfide deposits, based on past data and analysis of drill cores had anticipated mining the entire deposit top to bottom as an open pit up to 800’ deep.  They indicated it would take 13 years and employ around 220 people none of whom, they were clear to say, were likely to be the then locally unemployed.  After reviewing this report Boliden scaled back its plan to a much smaller 500’ depth pit with a 30 acre total surface area and commissioned the report  below.

SRK’s own analysis of this data is in the first document of this series of documents on which NRCM based its report on DEP withholding vital information from legislators and from the public.  SRK the world’s top mining consultant then and now, advised Boliden that their plan for a top to bottom , open pit extraction could not avoid off site environmental damages with any known technology.

Steffen Roberston& Kirsten (B.C.) Inc. Report80702/3 “Proposed Bald Mountain Project Report on Mine Rock Acid Generation Potential” Prepared for Boliden Resources Inc.  March 1992

Here is the text of my email transmitting this report to DEP & LUPC key policy staff ( Heather Parent. Mark Stebbins, Samantha Horn Olsen) It provides a good plain english summary of what the report says.

Basic explanation of ARD generation and associated risks

Red Dog Mine Alaska like Bald Mountain is a VMS with no neutralizing potential and will essentially be a perpetual care mine generating acid and toxics into perpetuity.

“The closure plan at Alaska’s Red Dog Mine calls for 7-15 perpetual workers, treating over a billion gallons of water annually using 7,300 tons of shipped-in lime, and producing over 70,000 tons of sludge, at a cost of over $10 million every year, forever” (Pebble & Perpetuity March 2013 op cit above

This document reports the revocation of permits for Red Dog Mine in 2006 for violations of the Clean Water Act
Here is a consolidated report of all ARD generation analysis done at Red Dog since 1996

Interestingly there is a case history on the Red Dog prepared by the Federal EPA. Very telling for Bald Mountain. Failure to require adequate prior ground water study and geochemical analysis lead early on to problems that were never fully mitigated or controlled.

See under ARD above the MEND Manual. ARD analysis must be the cornerstone of each phase of a well developed mine. It should inform the plan.

Another major new deposit in this same chain, Artic Mine, is touted as the highest grade of copper ever found and is as yet unstudied. This official Alaska State report looks at the environmnetal risks attending mining sites in the same range .

William K. Price 2009 Manual on ARD prediction for Canada’s MEND Program
The most complete and authoritative guidance on management on identification and management of ARD risks.

Black Hawk Application ( as NNM Resources)

Black Hawk, a company with no mine planning. mine development, mine managing or mine closure experience, acquired the lease from Boliden for $2 million in 1995 and submitted a mining application in 1997 for a very small gossan only (gold & silver) open pit mine.

They submitted the prior work of Boliden and earlier leaseholders and did very little new work .

The Black Hawk  Mining Application itself and the required  Envionmental Impact Report are the second and third documents in this series of documents scanned to PDF by NRCM in support of their 2013 report accusing DEP of intentionally withholding this information from the public and from legislators

Notice of Incomplete Application March 31, 1998

This 20 page main letter to Black Hawk at Denison headquarters in Toronto co signed by mining coordinator Mark Stebbins and LURC permitting official Catherine Varney outlines the principal incomplete elements of the Black Hawk application and the unresolved issues of environmental impact. At p 6 Stebbins highlights the likely permanent impacts of lowered ground water levels that would occur over the three year period of active extraction from the small pit. It also flag silence on the management of arsenic.

We have and will be translating to PDF and posting here:

Additional Geohemical & Lab Work perfomed to further detail the specific area of the planned small pit.

Black Hawks letter of withdrawal of the application
Black Hawks Lease and royalty agreement
Boliden Application

Boliden, a highly respected highly qualified Swedish mining company with experience in mining Volcanogenic Massive sulfides under tight environmental regulations took over from Chevron in 1989.  Boliden was the very first company involved at Bald Mountain who actually had experience in mine assessment, mine planning and mine development. They invested a total of anout $20 million in Bald Mountain under permits to LURC.  Their work never materialized to a full blown mining application.  They sold in 1995 to Black Hawk, another company with no mining experience for $2 million.  Boliden began with an expectation of mining the entire deposit top to bottom as an open pit and anticipated about 130-200 jobs(depending on official source..many different numberss in notes) over 13 years.  On reviewing work commissioned of Steffan, Roberston & Kirsten ( see ARD Analysis above) in 1990  they scaled their plans back to a much smaller mine of about 30 acres in surface area and only about 500 feet deep.  Notes indicate that Chevron, who had absolutely no experience in mining, had anticipated a huge sprawling open pit operation with on site milling. (Chevron’s predecessor, Superior also had a huge sprawling plan)

Bolidens first exchanges with LURC on taking over from Chevron.  Note especially John Cesar’s(President of Maine subsidiary Boliden set up for the Bald Mountain project) Boldiens 1989 letter expressing Bolidens desire that LURC and DEP will write the regulations directed by the legislature in 1985.

This 1991 Correspondence between Boliden and DEP officials is a fascinating early history of Maine’s 1991 regulations.  Most of these exchanges are about Bolidens difficulties complying with the requirements based on very low detection limits adopted in Maine’s 1991 regulations that had no correspondence in commercial laboratory standards.  Further as Boliden points out Maine’s low detection limits not only made it impossible to find a lab but were standards with an error of 100% whereas the standard industry criteria that excellent labs were using had an error rate of only 28%. Boliden surmised that DEP had come up with these standards based on some sort of literature search without verifying whether any labs were actually capable of the measurements at the specified level.

Additional notes including handwritten LURC staff notes at the initial meeting between Boliden & LURC. See especially the handwritten notes of the working group meeting June 28, 1990. The name of the author/note taker isn’t given but is presumably an LURC staff person. Two important and note worthy descriptions. First it describes the rather huge sprawling operation Superior had planned ( Superior preceded Chevron and was an investor JS Cummings brought in). Ths is also the only source I’ve seen that describes any details of what Boliden initially had in mind on taking over from Chevron ( Superior’s successor). On site milling was anticipated with transportation of milled ore by train on the Bangor & Aroostook to a port for shipment to a refinery/smelter. In these notes 150 is the number noted as total employment for this initial mining plan by Boliden.

The initial Boliden letter referenced above is in this group ( John Ceasar advising they have acquired the lease from Chevron and expressing their expectation that DEP/LURC will issue the rules required by legislation)

All of these records were provided to me ( Lindsay Newland Bowker, Bowker Associates) by LURC in response to a records request. They were provided in pdf form and appear here as grouped by LURC for transmission. ( it was agreed the records would be transmitted in groups by year). The request was for all permit records on LURC/DEP’s relationship with Boliden.

Cummings, JS Letters to Legislators John Martin, Troy Jackson, Jeff McCabe

Mr. Cummings communicated with both John Martin and Troy Jackson at the time John Martin brought his proposal to “streamline” Maines Mining Laws to our Joint Standing Committee on Environmental and Natural Resources

Letter to John Martin ( )
Letter to Troy Jackson (

While there is a certain amount of woundedness apparent in these communications that he was not consulted or included, he is also very clearly trying to make sure that legislator understand the challenges of the mountain itself, in particular the high levels of arsenic and the huge ratio of overburden to ore ( waste to productive rock ).

This year Mr. Cummings wrote to Jeff McCabe, as sponsor of a bill that would have amended the mining statute.

One of Maine’s largest and most influential environmnetal lobbyists and at least one reporter had a copy of the letter to McCabe and its attachments but chose not to release it and not to follow up on the accuracy of the reported high levels of arsenic at Bald Mountain. Mr. McCabe did not release or follow up on it.

It was read to me over the phone by one of the several who had possession of it and I did follow up with Mr. McCabe and all members of the Joint Committee who already had all of the letters.

Not one member acknowledged or replied.


JS Cummings Geochemical detection of volcanogenic massive sulphides in humid- temperate terrain : (using surficial methods) self published Bangor 1988

J.S. Cummings account of the unusual methods he used to identify almost all of the known sulfide deposits in Maine are set forth in his book. He has no copues himself and did not retain nay other significant documentation on his many important Maine discoveries. Three copies he donated still exist in libraries in Maine.

One of these is a circulating copy and you can arrange to have it available at one of many local libraries throughout Maine.

Cummings, JS The Lost Promise of Golconda Metals in The Maine Earth Re-Books 2012 ch 5 Deceit At The Highest Level 1989-1995

Flambeau Comparison

The Flambeau mine in Wisconsin is often touted as an exmaple of a successful open pit reclaimed VMS mine.

Flambeau is very small mine only 200 feet deep with a tiny surface area and with available limestone and other neutralizing potential of high quality within the deposit itself..  Bald Mountai is 800 feet deep with a significantly larger surface area. Additionally Flambeau had a much lower over all acid generation profile than Bald Mountain  All processing was off site.  Raw ore was shipped out for milling and refining.

The following document is an inquiry to Dr.David Chambers about his study of Flambeau and contains a link to it as well as a link to Kennecotts description of their mine plan.


Slack, John F., Flohr Marta J.K.  USGS & Scully, Michael V. Hypogene Mineralogy and Paragenesis Of the Bald Mountain Massive Sulfide Deposit  Open File Report 97-46  December 1997 ( Deposit geology)


Ground & Surface Water Quality

Fontaine, Richard A.  Hydrologic And Meteorlogic Data Bald Mountain Area Aroostook County Maine June 1979- June 1984  U.S. Geological Survey  Open-File Report 85-174 Augusta Maine 1989 ( a Joint Study of USGS and Maine DEP in anticipation of an open pit mine at Bald Mountain) Seal

Dr. Robert Seal.Pre Mining Analysis of Bald Mountain ( 1997)showing elevanted arsenic and lowered ph 12km down gradient of the deposit.

Ground & Surface Water Quality Monitoring


1990 Correspondence with Boliden Who Took Over from Chevron and took over the permit and sampling stations



Table of Contents Black Hawk Mine Application as NNM Resources 1997  ( link to be added available in pdf)

Maine Agency Comments on Black Hawk application 1998 (link to be added available in pdf


All photos posted here are in the public domain and may be used without permission. The coutesy of photo credits as indicated would be appreciated and, via comments email, a link to any use.

Jonathan Carter 2013

Jonathan Carter 2013

claytonlakeusgsstudy Bald Mountain( to be added)

Jonathan Carter 2013

Jonathan Carter 2013

Valuing A Copper Deposit

VMS deposits like Bald Montain are not as competitive as the easier to mine porphyry mines of the southwest and Latin America.  Porphyry deposits account for 60% of copper production globally.  And are generally amenable to open pit mining, ie the ore body  has a high enough grade (.6 is average today) and is close enough to the surface to make extraction profitable.

In comparison to Poryphry deposts, VMS deposits in general are smaller and deeper but have polymetallic charceristics ( metals like gold and silver) that  can offset the high costs of deep excavation overburden.

In comparison to porphyry deposits VMS deposist are more likely to be acid generating  and pose more complex environmental problems with toxic metal leaching.  Bald Mountain, even among VMS deposits is a challenge for its anomalously high levels of arsenic , its high acid generation profile and the absence of any neutralizing material within or near the deposit. ( see above Boliden Application and the SRK reports developed on the geochemical profile of Bald Mountain)

Volcanogenic Massive Sulfides

2013 winnipeg address on why VMS deposits are not being developed

VMS deposit have accounted for about 27% of  Canadas copper production historically.  There are 350 known VMS deposits in Canada and 800 worldwide


About lindsaynewlandbowker

Bowker Associates, Science & Research In The Public Interest, is an independent non profit providing self initiated pro bono analysis on key issues with a potential for massive adverse environmental impact . Bowker Associates has been an internationally recognized and cited voice in analysis of the Samarco failure, its consequence, and the possibilties for recovery. In 2017 we partnered with Daveid M. Chambers, a world leader in responsible mining, in our third joint work on the economics of tailings failures. Bowker, L.N.; Chambers, D.M. In the Dark Shadow of the Supercycle Tailings Failure Risk & Public Liability Reach All Time Highs. Environments 2017, 4, 75. A peer reviewed journal published investigation of the cowboy economics of the supercycle and the resulting escalation on the number and magnitude of catastrophic failures. In 2016 we parnered with Dave Chambers in our 2nd joint work together looking at root causes of failures at a conference . Bowker, L.N.; Chambers, D.M. Root Causes of Tailings Management Failures: The Severity of Consequence of Failures Attributed to Overtopping 1915–2015. In Proceedings of the Protections 2016, Fort Collins, CO, USA, 14 June 2016. [Google Scholar] In 2015 Bowker Associates collaborated with geophysicist David M. Chambers to recompile global authoritative accounts of significant TSF failures in recorded history and to analyze these data in the context of global mining economics 1910-2010 ( Risk, Economics and Public Liability of TSF Failures, Bowker/Chambers July 2015) The third annual update of this globally referenced and used compilation was just released at Researchgate. ( In 2014 Bowker Associates commissioned globally respected geophysicist and hydrogeologist Dr. David Chambers to undertake two technical works: (1) development of technical go no go criteria for vetting mine applications tp:// and (2) a case study of Maine's Bald Mountain, an un mined low grade high risk VMS deposit demonstrating the efficacy and accuracy of two risk assessment tools in vetting mine proposals In Maine, Bowker Associates has deeply engaged and been a public voice in the Searsport DCP LPG Tank, The Cianbro proposal for a Private East West Toll Road, JD Irvings rolling pipeline of Bakken crude to its plant in St. John and review of Phase II plans at The Callahan Superfund site in Brooksville, Maine, and Maine's revisitation of mining in statute and regulation... Our only “client”: is always “the pubic interest”. Our model is to focus on only one or two issues at a time so that we have a substantive command of the relevant field as our foundation for ongoing engagement. Our core work is in envirommental risk management, science and technology as well as bringing any available “best practices” models to the fore. The legal and regulatory history/best models are also a major thrust of our work in building and evaluating public policy. Director/Principal Lindsay Newland Bowker, CPCU, ARM is a recognized expert in Environmental Risk Management., Heavy Construction Risk Management and Marine and Transit Risks and has more than 3 decades of engagement in buiding public policy. Appointed by Governor Mario Cuomo to New York State Banking Board (served 1986-1996); President New York Chapter Chartered Property and Casualty Insurers; Environmental Committee, Risk and Insurance Management Society; Director, Convenor/Co-Chair Bermuda Market Briefing "From Captive to Cats" Hamilton Bermuda. Published Articles of Significance The Risk Economics and Public Liability of Tailings Facility Failures, co-authored with David M. Chambers, July 2015 Beyond. Polarization: Superfund Reform in Perspective, Risk & Insurance Managing Risk For Loss Prevention & Cost Control (Jan. 24, 1997). Lead Hazards and Abatement Technologies in Construction: A Risk Management Approach CPCU Journal 1997 Employee Leasing: Liability in Limbo Risk Management June 1 1997 Environmental Audit Privilege and the Public interest Risk & Insurance Managing Risk For Loss Prevention & Cost Control, April 1997 Asbestos:Holes In Abatement Policies Need To Be Plugged, Lloyd’s Environmental Risk International, May 1993 Editor Published Letters Evironmental Risk Management Beware of Facile Policies Like Fetal Protection Business Insurance 1995(?) High Court Review May Increase Sale of Bank Annuities Business Insurances August 8, 1995 Professional Profiles Protecting the Big Apple’s Core Managing Risk For Loss Prevention & Control December 1996 Major Career Highlights First rigorous analysis showing Relationship Between declining ore grades and TSF Failures of increasing consequence ( July 2015) FIrst Documentation that Gentrification Has Same Impacts as Unassisted Displacement from Urban Renewal Sites Direted Court Ordered EIS of FHA Mortgage Scandal Created Nation's First Homeownership Program for Low Income People (SHIP) Created Earliest Geographic Information Systems Using Defense Technology Developed By IBM Designed and Conducted Parallel Census Count to Show Systematic undercount in minority neighborhoods Documented Bias in ISO Territory Rating Plans for Private Passenger Auto Insurance Using ISO's own Rating Techniques Demonstrated Inherent Bias in Mortgage Policies of Banks With Inner City Branches Demonstrated that NY Telephones Plan for Area Code Split To accommodate anticipated cell phone demand was not efficient and would exhaust in 5 years ( which it did) Undertook First Systematic Evaluation of Child Protective Services Caseload Using Multi Variate Analyic Techniques Developed Child Protective Caseload Management and Tracking System (CANTS) and directed implementation in 4 client states including Illinois, Florida and New York Created and Ran Office of Risk Management for NYC DEP the Nations largest Water & Sewer Authority . Designed, Created and Administered Nation's First Owner Controlled Insurance Program (OCIP)for High Risk Tunneling Education Masters NYU Graduate School of Public Administration BSC New School For Social Research Maine Public Schools Deering High School
This entry was posted in Bald Mountain Aroostook Maine, Black Hawk Mining Co., Boliden, Heather Parent, JD Irving, JS Cummings, Maine Mining Regulations, Maine Mining Statute, massive sulfide risk management, USGS, volcanogenic massive sulfide and tagged , , , , , , , , , . Bookmark the permalink.

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