Andrea Piontek

Metallic Minerals Lease Applications

Keweenaw Land Association (KLA) has applied for multiple mineral leases from the State of Michigan for metallic mineral rights located within Meyer, Spalding and Holmes Townships.  The KLA isn’t a mining company.  In December 2021 KLA’s business was “forest products and land management.”  KLA declared itself to be “focused” on mineral assets as of 2022, this doesn’t make it an exploration company.  KLA is not conducting exploration or mining activities.  A mining company, by definition, operates mines; a mining company conducts exploration, extraction, processing and production of ore.  KLA pursues none of these activities.  KLA’s current goal seems to be the capture of state mineral leases in order to control and re-market the mineral packages to “partners” who might have the capacity to conduct exploration work.  The State of Michigan should lease only to qualified applicants.

The DNR’s process of metallic mineral leases serves only a handful of self-interested corporations seeking to control substantial blocks of public mineral rights.  The rights of the public, and the wellbeing of public trust resources like lakes, wetland and wild rivers, are substantially ignored in this process.

The DNR’s Primary Statutory Obligation: to protect and conserve the NREPA Act of 1994, 324.503 Duties of Department.  First and foremost, “ (1) The department shall protect and conserve the natural resources of this state; provide and develop facilities for outdoor recreation; prevent the destruction of timber and other forest growth by fire or otherwise; promote the reforesting of forestlands belonging to the state; prevent and guard against the pollution of lakes and streams within this state and enforce all laws provided for that purpose with all authority granted by the law;  and encourage the protection and propagation of game and fish.

Sec. 503 mentions authorities for economic decision such as mineral leasing and concessions, but the clear and primary mandate of Sec. 503 is that natural resources are to be protected prior to economic considerations.

There has never been a sulfide mine that has not polluted nearby water resources.  The legacy of sulfide mining is Acid Mine Drainage.  AMD poisons water forever. The Department of Natural Resources’ first duty is to “protect and conserve the natural resources of this state” and this specifically includes the prevention of harm, and a further charge to “prevent and guard against the pollution of lakes and streams.”   The DNR is obligated to deny the applications for Metallic Mineral Leases for reasons listed above.

Please submit a written comment no later than  thirty (30) Days from October 19, 2023 to: DNR, Minerals Management Section, P.O. Box 30452, Lansing, MI 48909-7952 or DNR-LeaseManagement@michigan.gov  subject line should read: Keweenaw Land Association-Menominee-1734; Keweenaw Land Association-Dickinson-1735.

Andrea Piontek,
Wallace

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