A Clinical Reassessment of Bald Mountain, Aroostook County Maine
February 28th, 2014
LD 1772 A Resolution to Reject Maine’s Draft Mining Rules
Dear Co-Chairs Boyle and Welsh & Members of the Joint Standing Committee On Environment & Natural Resources:
I attach a major policy work by the eminent geophysicist Dr. David Chambers which was commissioned specifically to inform and guide the development of Maine mining policy We hope it will take you in the direction of a “best knowledge” based framework for responsible mining. Bowker Associates has commissioned, funded, managed and directed this work .
My cover transmittal explains what we were trying to convey in this work and why we went about it in this way fading the realities of Bald Mountain into the background as just an anonymous “mountain X” with a set of attributes indicating severity and source of environmental risk. We bring to the foreground the elements of this risk itself through two independent systems of risk assessment each of which is an authoritative expression of best knowledge (MEND/GARD GUIDE), best science and best available technology.
Each system produces an overall risk score intended to establish when a given mine is “No Go”, that is, is fatally flawed .
Yes, we did find that from a point of view of modern best knowledge and modern best available technology nothing has changed since 1990. Best policy would definitely not lead to issuance of a permit for any open pit extraction of the Bald Mountain sulfide itself and it is highly questionable whether even a small open pit focused only on the gossan above the deposit itself is environmentally viable today any more that it was in 1997 when Black Hawk withdrew its application
This isn’t news.
I have been reporting this to all since June when I acquired and compiled all the most relevant data on Bald Mountain between its discovery in the late 70’s and 1997 when Black Hawk walked away.
We didn’t select and engage Dr. Chambers to just “grade my homework”
It was obvious to Dr. Chambers, who has more in depth experience at more northern cold wet climate volcanogenic massive sulfides than anyone else I’ve found, that there was no new proven technology that changed the advice SRK gave and Boliden took in 1990 ( before the 1991 mining rules were written)
I testified to that in my Oct 17th written comments to BEP.
What we really wanted to show is WHY it is the case;,to make it obvious what elements of law and regulation need to be in place to identify such risks and evaluate them in a reliable decision framework where environmental risk and effective technology for controlling risk is the basis of granting or refusing a permit.
This work has never been about revelations on “the truth” at Bald Mountain. It has never been a political work or intended to be used to support heated rhetoric, deeply held ideologies and preconceived positions. It has always been about trying to offer you the best possible guidance on what modern mining statutes and regulations have to look like to identify and avoid public risks of immeasurable and non recoverable loss.
We ask you to consider and use it in the spirit we offer it to understand how far off course the rules before you are. Please work through the the two independent risk screening tools we applied to Bald Mountain. Look at each criteria, look at its weight for severity of risk then see if you find anything in the rule before you that will bring the right information together to identify and evaluate the risk of catastrophic environmental loss.
We also ask you to then forget the rule before you , to forget that this environmental risk assessment is about “Bald Mountain” and all the controversy it conjures. Consider it as “Mountain X “, a place you know nothing about . Work through the two screens and at the end ask yourself honestly would you issue a permit for “Mountain X’?.
I thank Dr. Chambers for allowing me to transmit this in a state we both consider not quite finished. It’s more a close to final working draft but it is serviceable for the purpose here and we hope you find it a constructive and informative guide to the task before you now.
With Appreciation & Gratitude For Your Willingness to Serve Us In This Challenging Deliberation
Lindsay Newland Bowker, CPCU, ARM Environmental Risk Manager
Science & Research In The Public Interest
15 Cove Meadow Rd.
Stonington, Maine 04681 Transmittal Letter:https://drive.google.com/file/d/0Bw0jCpuVRzgERDRHamMwampkdVE/edit?usp=sharing Dr. Chamber’s Case Study On Bald Mountain: https://drive.google.com/file/d/0Bw0jCpuVRzgEZ3lPYmFibzB2RDFoWm1ZSmNGekpoc0FtQ0w4/edit?usp=sharing ADDITIONAL BACKGROUND & RESOURCES This paper on risk that can be inferred from geology is particularly helpful in understanding the preliminary assessment portion of the Rio Tinto Risk Assessment protocol.https://drive.google.com/file/d/0Bw0jCpuVRzgEZEllbklZNjg0dlE/edit?usp=sharing YT John Kwong ” ARD Assessment in Exploration” Mend Report 1.31.2 This paper by Dr. A.Mac G. Roberson & Shannon Shaw Explains how a mine plan is driven by the feasibility of closure http://www.infomine.com/library/publications/docs/e-book%2002%20mine%20closure.pdf. Dr. Robertson applied this process to the work he and Linda Broughton did for Boliden in 1990 and 1992 at Bald Mountain. Their professional analysis using this approach is borne out by both the Rio Tinto risk assessment ratings ( driven by issues with successful/viable closure) and the Chambers Go No Go technical criteria. ( where the No Go scores were related to feasibility for a viable closure plan). Dr. Robertson has not commented yet on our completed work but responding to my description of what Dr. Chambers & I had found, he said he was delighted to see that confirmation of this early work at Bald Mountain. The long debate over the Pebble Mine, which would be one of the largest copper mines in the world if allowed to be developed faces EPA challenge over potential irreparable risk to Bristol Bay Salmon http://america.aljazeera.com/articles/2014/2/28/epa-deals-blow-toalaskacopperminepotentialboonforslamon.html This illustrates the point of the work Bowker Associates has been doing through Dr. Chambers to define where the line is between private privilege and the public interest. A partner had previously withdrawn over the salmon impacts issue.