Please submit written comments on this proposal, and be there in person if you can! It’s up to all of us to help the regulators reject this project.
From the DEQ’s notice of public hearing:
The Marquette County Road Commission has submitted to the DEQ an application for a series of permits to create Marquette County Road 595, a proposed 21-mile road to connect US-41 with County Road AAA.
The Marquette County Road Commission’s stated purpose is to construct a new primary county road that will improve emergency, commercial, industrial, and recreational access to northwest Marquette County and reduce truck travel through Marquette County’s population centers.
The proposed road project connecting US-41 near Humboldt to County Road AAA near Kennecott’s Eagle Mine requires wetland, inland lake and stream, and floodplain permits. The DEQ has determined the road commission’s application is administratively complete, and the department will host a Feb. 21 public hearing to receive comments on the proposal. The hearing starts at 6 p.m. at the Country Village Banquet and Conference Center, 1011 North Road, in Ishpeming.
A significant goal of DEQ’s review is to solicit comments from the public, Department of Natural Resources and the United States Environmental Protection Agency on the reasonably foreseeable benefits and detriments of the proposed road, as well as feasible and prudent alternatives to achieve
the purpose of the road.
SUGGESTED TALKING POINTS
Project Purpose
The project purpose, as stated, is poorly defined and deceptive. State and federal regulators are under no obligation to accept the applicant’s conclusions regarding project purpose. The stated purpose of CR 595 should focus on the primary function of the road. It does not.
This is a haul road for Kennecott. It is a nearly direct route from Kennecott’s Eagle Mine to their processing facility in Humboldt. Kennecott has invested over $8 million in the project so far, and has offered to pay for construction of the road. There is no previously documented public need for this road, while Kennecott’s mine permit application shows they considered the possibility of a south haul route as far back as 2006.
Existing transportation networks were not given adequate consideration. Upgrades to current roads will improve access to northwest Marquette County and will better serve the public with fewer adverse effects on the environment.
There will still be heavy truck traffic on County Road 550, and consequently, through the City of Marquette. Kennecott employees and contractors will still use the 550 route when they are traveling to and from the east side of the County. And not all loggers will travel west.
The possibility of using a bypass north of the City was not given adequate consideration. In 2006, prior to discussion of Woodland Road/595, Marquette Township’s planning commission began a study of potential future road connections including just such a bypass. It was never pursued.
Wetlands/Environment
Construction of County Road 595 would cause severe and widespread adverse impacts to the environment. The proposed action will result in degradation and destruction of aquatic ecosystems, waters, and associated natural resources. Wetlands mitigation has a high rate of failure.
The activity is not wetland dependent. There are available alternatives that would meet the purpose and need stated in the 595 application. Updating Kennecott’s permitted haul route (Triple A-510-550) and continuing to use other existing roads would result in wetland impacts of only about one acre.
Nearly three-quarters of the original wetland area in our state (estimated at over 11 million acres) has been destroyed. Despite new laws and the efforts of government and private conservation groups, the destruction of wetlands continues. The number of acres of directly impacted wetlands in the 595 application is approximately 1.5 less than for the Woodland Road, which was rejected largely due to unacceptable levels of wetlands impacts.
There are economic benefits to preserving wetlands. Wetlands provide critical habitat for plants and other wildlife, provide erosion control, filter pollutants, recharge aquifers and contribute to recreational opportunities such as hunting and fishing.
Potential impacts to wildlife are unacceptable. Habitat fragmentation, dust, noise, increased secondary road construction, increased hunting and trapping, and disruption of the landscape’s natural processes such as groundwater flow are some of the more serious concerns.
Greenhouse gases emitted during two years of heavy road construction have not been considered. Rehabilitating existing roads would use much less oil and aggregate. Impacts of extraction, processing and delivery of materials should be taken into account as well.
DEQ must not grant a permit if the proposed project or structure will result in significant degradation and destruction of aquatic ecosystems, waters, and associated natural resources. CR 595 would directly affect close to 26 acres of wetlands, involve 22 river and stream crossings, and indirectly affect many acres of land outside of the road’s immediate footprint.
Cumulative Effects
Secondary impacts, such as additional road-building and private development have not been considered. Our local officials and legislators are intent on “lobbying” the EPA to allow the permitting of the road and on “opening up the area” for economic development and mining. Marquette County’s 2010 Zoning Plan says that construction of a north-south access road for Kennecott “will generate requests to rezone areas for year-round development.”
The area proposed for new road development has the lowest road density in the region. Destruction of a previously intact roadless area primarily to benefit a mining company is a terrible idea, especially when there are existing roads available that would meet their purpose.
There has been no cumulative impacts study involving mine, haul route and mill. As the Army Corps stated in their analysis of the Woodland Road application, “If the road is required to connect the proposed nickel mine at Eagle Rock with the milling operation and tailings disposal facility at Humboldt, these actions should be evaluated under one project.”
Kennecott should be held to their original permitted transportation plan. They have already drastically altered the character of the Yellow Dog Plains with road grading and widening and the accompanying removal of canopy. Why destroy yet another corridor? They should not be able to have it both ways, and they will, if this project moves forward. According to their timetable, 595 would not be ready for another two years after ore hauling has commenced.
Recreation
The public does not want their recreational lands to be altered or encroached upon. Comments during hearings on both the Woodland Road and CR 595 have made this clear. They do not want a highway through their wilderness, their place of refuge. Let’s confine the truck traffic to existing roads, not spread it out so there are no quiet places left.
The road will have a negative effect on tourism. To many, this road signals permanent destruction of the very recreational opportunities road proponents claim they want to enhance. Tourists aren’t going to drive up here from the population centers of lower Michigan, Illinois and Wisconsin to look at the same things they’ve left behind, namely “development.”
Safety
Traffic and trucks can travel on existing roads safely. There are routes available that can be improved to address safety concerns and that would not destroy the last of our roadless areas.
Construction of a new highway in northwest Marquette County may increase the incidence of fires and other situations requiring emergency services, putting a strain on already stretched resources. This is stated in the 595 application.
Wildlife-vehicle accidents will likely be higher with a new road through a remote area than they would be on existing roads. Deer-vehicle accidents already account for the vast majority of crashes in Marquette County. This area has some of the highest moose densities in the Upper Peninsula.
It is illogical to argue that the 2003 dam failure justifies the building of CR 595. A repeat occurrence is extremely unlikely.
Economics
We will be paying to maintain this road—it will be an added economic burden. The Marquette County Road Commission has fewer and fewer funds to pay for road repairs, plowing and other maintenance. Why add another road to the system, and why pay to maintain a road that would primarily be used by one company?
Our roads and bridges are in desperate need of repair. Marquette County needs at least $160 million for repairs on existing roads and an additional $40 million for bridges. Let’s get to work fixing those, instead of constructing a new road we can’t afford to maintain.
Public Support/Opposition
There is no widespread support from the public, for this road. The public was not asked to vote on this issue. In fact, there has been ongoing concern about the impacts a new, major road would have on the health and the character of our larger community. Public hearings were conducted, but the voices of the opposition were given little weight.
Our communities are being asked to choose between two undesirable options. Either we get a haul route through our cities, or we get a destructive road through the wilderness. Kennecott is not giving us any other choice.
Opposition does not come solely from mine opponents. The majority of comments are concerned with improper procedure, a lack of transparency, and impacts to the forests, streams, and wildlife of the corridor this road would bisect.
Conclusions:
The public does not need this road. It would cause unacceptable degradation and destruction. Alternative routes do exist. And if it weren’t for the mine, there would be no road!
The entire application can be viewed online at http://www.michigan.gov/deq/0,4561,7-135-3307_29692_24403-269958–,00.html, or click here to download the pdf: aapa_revised_final_1_9_12
Written public comments, accepted through March 2, should be sent to DEQ, 420 5th Street, Gwinn, MI 49841.
To submit comments electronically, please use this link: http://www.deq.state.mi.us/lwmpn/commentsform.asp?aid=11520075&at=ph
Please submit comments to the EPA and Army Corps as well:
US EPA, Region 5 Watersheds and Wetlands Branch 77 West Jackson Boulevard Chicago, IL 60604
Army Corps of Engineers at: US Army Corps 477 Michigan Ave. Detroit, MI 48226
For additional information, visit: http://lakesuperiorminingnews.net/2012/02/16/talking-points-for-public-hearing-on-kennecotts-mine-haul-road/ and http://keweenawnow.blogspot.com/2012/02/deq-to-hold-public-hearing-on-cr-595.html
