Open letter to Osisko, an investor in the Back Forty mining project
March 17, 2018
Wisconsin Resources Protection Council
Box 263
Tomahawk, WI 54487
Mr. Sean Roosen, CEO and Chair of Board
Osisko Gold Royalties Ltd.
1100 Avenue des Canadiens-de-Montreal
Suite 300
Montreal, Quebec H3B 2S2
Canada
Dear Mr. Roosen:
We are once again writing in regard to Osisko’s 15% ownership of Aquila Resources’ Back Forty metallic sulfide deposit in Michigan’s Upper Peninsula. You have undoubtedly seen Aquila’s March 9 permitting update announcing that the U.S. Environmental Protection Agency has provided comments to the Michigan Department of Environmental Quality (MDEQ) regarding the company’s wetlands permit.
Not surprisingly, Aquila’s press release failed to mention the specific concerns of the EPA, along with the U.S. Army Corps of Engineers and the U.S. Fish and Wildlife Service pursuant to Section 404(G) of the CleanWater Act CWA). These concerns include “deficiencies in the impacts analysis, the significance of aquatic resource impacts, alternatives analysis, and the demonstration of adequate compensation for wetland and stream impacts. Therefore, this project does not comply with the CWA Section 404 (b)(1) Guidelines, and EPA objects to the issuance of a permit for this project as proposed” (EPA letter from Christopher Korleski, Director, Water Division March 8, 2018).
Aquila’s press release tries to minimize EPA’s concerns by stating that these issues “are readily addressable.” However, the list of concerns includes some fundamental deficiencies such as a failure to provide a complete description of the project, including a final site plan identifying the final location of key project features, including storm water and waste management features…Nor are all impacts of the project identified in the application, including impacts caused by any planned underground mining, a power plant, and mining water management systems. Without this information, the reviewing agencies cannot adequately assess the extent of the proposed mine’s impact on aquatic resources as required by the CWA.”
If these issues were “readily addressable” why has Aquila failed to provide this information to MDEQ, as requested in letters of January 19, 2018 and March 2, 2018?
The EPA letter, with 7 pages of single-spaced comments, along with MDEQ’s January 19 letter with 9 pages of single-spaced comments, suggests fundamental problems with the mine plan and the economic feasibility of the project.
We are enclosing a copy of the full-page ad that appeared in this week’s Menominee County Journal inviting the public to read EPA and MDEQ comments on the Back Forty project and come to their own conclusion about whether they believe that these issues are readily addressable or whether this is an ill-conceived project that is neither safe nor protective of the environment.
We urge that you take these concerns seriously and consider whether continued financial support of this project will benefit your investors.
Sincerely,
Al Gedicks, Wisconsin Resources Protection Council
Ron Henriksen, Front 40 Environmental Fight, Stephenson, MI
Guy Reiter, Menikanehkem (Community Rebuilders), Keshena, WI,
Kathleen Heidemann, Mining Action Group of the Upper Peninsula Environmental Coalition, Houghto, MI
Dale and Lea Jane Burie, Coalition to SAVE the Menominee River Inc., Marinette, WI
Seth Hoffmeister, Wisconsin League of Conservation Voters, Green Bay, WI
Dick Dragiewicz, Northern Ilinois Fly Tyers, Grayslake, IL
