GIant Cups of Poison: The Politics of Mining & Mining Science For Sale

Dr. Robert Moran, has been out front in calling attention to the existence of a body of “fake science” that is creeping its way into public policy, mostly in the form of mathematical models purporting to predict the behavior of complex natural systems. I like using entire email threads on a topic like this especially when the voice is one of unquestioned authority as Dr. Moran is. This form of presentation preserves the voice, original words and thought of the speaker. Also I think a quote from a conversation doesn’t convey as much as the conversation itself.

Giant Cups Of Poison is the title of Chapter 7 of the Pilkey’s book on this topic “Useless Arithmetic” which Dr. Moran reviewed.

I think this is a very significant public policy issue in metallic mining especially where nearly al state laws and rules are vulnerable to this kind of invasion where science for sale masks the actual risks of an undertaking for which a permit is sought

This chain of correspondence began with Dr. Moran expressing his reservations about a specific mining company y developed mining risk assessment tool.

Email January 10, 2014

Dear Lindsay—I suspect we are “on the same page”, but , I focus  mostly on how water-related predictions have been used to mislead the public. …

Part of the reason I am so outspoken on this issue is that civil society is MUCH more effective when they force companies to make public actual data–not predictions. Generally companies (and governments) would prefer to release models rather than the original data. It is the data (or the lack of) which you can attack most readily.
   cheers—Bob Moran

PS:Below is a 2007 article from The Guardian (of London), which was written by a friend, Robert Goodland, who died unexpectedly a few weeks ago. He started the Environmental Dept. at the World Bank in the 1970s, and was their main in-house environmental adviser for 23 years. This article presents, very simply, his real-world experiences in this arena.

Comment

How to aid destruction

My former employers, the World Bank, are damaging the planet and punishing the poor
  •         Robert Goodland
  • The Guardian,        Monday 22 October 2007

    I worked as environmental adviser for the World Bank Group,  headquartered in Washington, for 23 years. I joined because I believed  the bank wanted to improve the lot of the poor and conserve the  environment. Before going to Washington I did an environmental study for the government of Tucurui, the first big dam in Amazonia. A vast part  of the forest was flooded, so I saw at first hand the huge environmental and social cost of misguided development projects.The bank knew how  impassioned I was but hired me none the less. I thought I would work  with colleagues to prevent blunders in the future. Indeed, we achieved a lot. Perhaps our greatest feat was having the bank adopt a suite of  social and environmental policies to be applied to all projects.The bank also adopted policies for reducing poverty directly, instead of  relying on “trickle-down” economics. In 2000 I was thrilled when James  Wolfensohn, then president of the bank, led it to pursue the UN’s  Millennium Development Goals. Assessing risks and impacts, we failed to  stop the bank funding ExxonMobil’s oil pipeline in Chad and Cameroon,  but managed to prevent it supporting China’s Three Gorges dam.

Progress faltered in the late 90s. Most social and environmental policies were  gutted, and those that remain are no longer being rigorously followed.  During the Wolfowitz presidency, policy work on the two key challenges  of population and climate change was crippled. While governments around  the world are regulating carbon dioxide as a pollutant, the bank is not  yet doing anything like this. The bank has encouraged India to resume  investing in coal and nuclear energy. Social and environmental policies  have been handed over to developing countries to implement – or not, as  the case may be. The bank’s private sector affiliate, the International  Finance Corporation (IFC), is backing oil palm plantations in Indonesia  and cutting protective mangrove forests. Among the worst is financing  for monoculture soya plantations in Amazonia, even though soya is  suicide for Brazil’s rich agricultural lands.

The Bank Group is  stimulating hundreds of millions of dollars’ worth of cattle ranching in Amazonia, an activity I campaigned against strongly. These ranching  investments violate applicable standards for both deforestation and  slavery. Bank Group policies mandate that the companies it finances are  responsible for compliance, yet in this case, the IFC is abetting  Brazil’s biggest beef exporting company’s noncompliance by bringing in  donated funds to pay for some compliance in the future. Since such  efforts historically have had no previous success, the bank’s  independent evaluation group has stated that the IFC’s efforts pose “a  grave risk to the environment and to the bank’s reputation”.

A  quarter of the Amazon forest has already been destroyed, aided and  encouraged by the bank. Amazonia suffered its most devastating drought  yet in 2005. The 2007 drought and fire seasons look like being even more shattering. This loss of forest is intensifying climate change, and  there are reports of impending reductions in rainfall and farm yields in the rest of Brazil. While Brazil is possibly crossing the threshold  into free fall, plans are being drawn for massive dam, cattle ranching  and highway projects.

Robert Zoellick, the new president of the  bank and IFC, has not yet changed course for the better. On the  contrary, at last weekend’s annual meetings of the world’s finance  ministers, he urged the private sector arm of the Bank – IFC – to lead  in setting priorities for the Bank Group. Ahead of the meetings, he  pushed through an initiative to have net income from IFC transferred to  fund the majority of Bank operations for the poorest tier of developing  countries, meaning private interest in those operations will now  supplant public interest.

Zoellick’s focus is on globalisation,  helping multinationals extract oil, gas and other resources from  developing countries. This hugely helps industrial nations, but does  nothing for the world’s poorest, who should be the paramount focus of  the bank. Fostering climate change through deforestation, cattle  ranching and fossil fuels are all anti-poor priorities that the Bank  must halt.

In recent years, many stakeholders have expressed doubt that it is possible for the World Bank and IFC to serve public interest as they should. I believe they can, but only if the world’s governments  – the shareholders of the World Bank – demand accountability,  transparency and consensual development. Citizens of every country  should demand that their governments take responsibility for the Bank to end its procrastination on climate change, before it is too late. rbtgoodland@aol.com

Robert E Moran, PhD Michael-Moran Assoc. LLC Golden, Colorado  USA +1 303.526.1405 remwater@gmail.com
Lindsay Newland Bowker <lindsaynewlandbowker@gmail.com>
Jan 10 (2 days ago)

Dr. Moran,
Thanks you so much for this paper.  I hope it has been published and is in general circulation.

https://drive.google.com/file/d/0Bw0jCpuVRzgEZVFfYzNHVnlzUTkwNzhubzRGUWJqY2x3Um9B/edit?usp=sharing

I have seen and have been advocating from many of the principle works you cite (in particular Lapakko’s & Price’s emphasis on long term testing to assess ARD), the importance of complete independence & integrity of all science used to make public decisions on mining, the caliber of expertise employed, and the principle of responding to uncertainty with an abundance of caution (with the most conservative assumptions).  These have all been the main parts of my “sell” here in Maine but here, “no sale” due to what I call the “bananaism of Maine”.
Your paper is a very powerful summing up of all these critical core issues of science integrity & reliability on which public decisions on mining are based.  Presenting this summation in application to a real world situation of government review and approval of a particular mine gives it added thrust that brings the message home with your characteristic clarity.  I too feel an urgency about this message and my testimony and statements also reflect that in the increasing use  of bold letters, red letters, italic letters and words and observations not customarily associated with writing on science.
Part II of what we are trying to do in  our GO/NO GO project with Dr. Chambers is aimed exactly at this cluster of critical issues in the science of authorizing mine activity.  We actually did have some excellent early work by Mac Robertson and others going back to after the deposit was first discovered that tells exactly the story you are telling about this mine in Guatemala. Fortunately that long term testing well past the customary 20 weeks was done.( I think I may have sent you some of that and my analysis of it).  Bald Mountain has no neutralization potential , sulphur over 20% throughout the deposit itself and its footwall  and  all of the NP:AP ratios in the sulfide itself are below 1. It has extremely high levels of arsenic.  The public data record was not complete ( some $30 million was spent over 20 years) but the quality  and relevance of what we do have will enable us ( Like your paper here on Guatemala) to bring these central issues to light before Maine’s mining law and policy is cast in stone.
 Your paper will help us enormously and by bcc of this letter I am sharing it with Maine’s most important environmental advocates and our key legislators and agency policy makers.
Best to you & In gratitude
Lindsay
On Thu, Jan 9, 2014 at 6:25 PM, Robert Moran <remwater@gmail.com> wrote:

Dear Lindsay—Thanks for the kind words. I do not recall if I previously sent you a copy of the attached report. I send it because I encourage you to review the details of the sulfide-oxidation tests (LONG-TERM) conducted by Kim Lapakko (see refs.), which show how foolish most short-term test results are. It is such short-term results that are usually incorporated into most geochemical predictions of ARD generation.
In addition, you probably know that the Zortman-Landusky Mines in Montana, with which Dave Chambers has been involved, developed severe ARD problems despite having an average / median waste rock sulfide concentration of less than 0.2 % total sulfur—in contrast to all the consultant’s predictions. I managed the water quality and geochemical portions of the Zortman-Landusky EIS field activities and report writing (for the U.S.BLM), and was the center of most of the criticism when we (Woodward-Clyde) refused to pretend to use geochemical models to make quantitative predictions of future constituent concentrations. Nevertheless, the company and BLM ultimately accepted the wording of our document (I don’t recall if it was officially a Draft EIS), and you might find the original wording quite useful. Not long after we released this document the company declared bankruptcy, leaving the State of Montana with the long-term treatment and remediation costs. Dave probably has access to the original document. I also have one–somewhere in my files, but I don’t have an electronic copy.
   cheers—Bob Moran
Robert E Moran, PhD Michael-Moran Assoc. LLC Golden, Colorado  USA +1 303.526.1405 remwater@gmail.com
Seal, Robert
Jan 10 (2 days ago)

to me
Lindsay,

Thanks for keeping me bcc’ed on these discussion threads. They are very interesting and highlight the challenges of gaining comfort with the fate of a proposed mine site. As a risk assessor , I am sure that you are more familiar than most with the uncertainty in all risk assessment.
In Kirk Nordstrom’s defense, when he gives presentations on “models”, one of his first slides is a quote that says “All models are wrong, but some are useful” (from George Box, a statistician). The idea is that all “models” are simplifications of nature and merely represent working hypotheses destined to be tested and further refined. If you meet anyone who believes otherwise, you should run the other way. I am sure that Kirk would agree.
Bob
Bibliography

Moran, Robert E., 2000, Is This Number To Your Liking? Water Quality Predictions in Mining Impact Studies, p. 185-198, in Prediction: Science, Decision Making and the Future of Nature. D. Sarewitz, R. Pielke, Jr., and R. Byerly, Jr., eds., Island Press, Washington, D.C., 405 pg.

http://www.unc.edu/~mwdoyle/riverretreat2009/Moran_2000.pdf

Moran, Robert E., 2005 (February), New Country, Same Story: Review of the Glamis Gold Marlin Project EIA, Guatemala [Nuevo País, la Misma Historia:

Revisión del EIA del Proyecto Glamis Gold Marlin,Guatemala] : Prepared for Colectivo Madre Selva, Guatemala City, Guatemala. Available at:

http://www.madreselva.com.gt/documento_de_robert_moran.pdf

http://www.miningwatch.ca/index.php?/Glamis_Gold/Moran_Glamis_en

http://www.miningwatch.ca/index.php?/Glamis_Gold/Moran_Glamis_sp

http://www.theminingnews.org/pubs/Moran_Marlin_rpt_Feb_2005Eng.pdf

http://www.guatemalanetz.ch/dokumente/minen/2004-02-moran_marlin_rpt_sp.pdf

http://www.saviaguate.org/documentos.html

Moran, Robert E., 2005, CAO Marlin Mine Assessment: Technical Responses. Available at: http://www.miningwatch.ca/sites/www.miningwatch.ca/files/Marlin_CAO_Respuesta.pdf

http://www.miningwatch.ca/updir/Marlin_CAO_Response.pdf

http://www.madreselva.com.gt/Guat%20Marlin%20CAO%20Response.pdf and http://www.madreselva.com.gt/Guat%20Marlin%20CAO%20Respuesta%20Rept.%209-28-05%20FINALTradMFCcorJC.pdf

http://www.bicusa.org/bicusa/issues/Guat%20Marlin%20CAO%20Response%20Rept.%209-28-05%20FINAL.pdf

http://www.cao-ombudsman.org/html-english/documents/MadreSelvaResponseCAOAssessmentReportEnglishwithtechnicalReviewAnnexEnglish_000.pdf

http://www.saviaguate.org/documentos.html

Continuing this round table, Houston Kempton forwarded the attached exacellent example of this fake scienece at work in the presentation of the North Met in Minnesota.

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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 2015 Bowker Associates collaborated with globally respected 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 gloal mining economics 1910-2010 ( Risk, Economics and Public Liability of TSF Failures, Bowker/Chambers July 2015) 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://lindsaynewlandbowker.wordpress.com/2014/01/05/a-new-statutory-regulatory-framework-for-responble-sulfide-mining-should-this-mine-be-built/ 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 https://lindsaynewlandbowker.wordpress.com/2014/02/28/mountain-x-would-you-issue-a-permit-to-this-mine/ 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 Bowker Associates Science & Research In The Public Interest, Center For Science in Citizen Participation, David Chambers, Environmental Risk Management, Houston Kempton, John Seal USGS, Lindsay Newland Bowker, massive sulfide risk management, Perpetual Treatment Policy, politics of mining, Robert Moran, Robert Seal, Robert Seal USGS, Science for Sale, Uncategorized, volcanogenic massive sulfide and tagged , , , , , , , , . Bookmark the permalink.

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