To: Heidi Grether, Director
Michigan Department of Environmental Quality
P.O. Box 30473, Lansing, MI 48909-7973
Rick Snyder, Governor of the State of Michigan
P.O. Box 30013
Lansing, MI 48909
From: Michigan Citizens for Water Conservation
RE: Objection of DEQ Potash Mining Permit in Osceola County with Rationale
It has come to our attention that the DEQ may be considering permitting of a solution potash mining operation in Osceola County. Michigan Citizens of Water Conservation requests a public hearing on the three injection wells required to bury the contaminated mining solution. We are given to understand there might not be a requirement for a public announcement and/or public hearings on the permits for the solution mines themselves, however the injection wells required for the mining operation are not subject to the same secrecy provisions as the mines and we formally ask for a public announcement and public hearings on the proposed injection wells.
MCWC objects to the permitting of the potash mine as proposed for the following reasons.
1) Michigan Potash, LLC designated specific wells that they are using to prove the safety of the containment strata. These wells were drilled about 35 years ago and are no closer than a mile from the proposed mining operation. Since these original wells were drilled, there was a 4.3 earthquake approximately 100 miles due south of the proposed mines. With the potential of changes from an earthquake, there exists significant doubt the containment strata is intact and mining can safely occur. Moreover, older wells, oil flowlines, and natural gas laterals pose both environmental hazards at or near the surface, and having penetrated the target depth and confining strata for mineral solution mining. Certain wells in completion before 1973 DO NOT have the safety of intermediate casing. Such has history of pushing annulus pressures for blowouts to atmosphere. This needs significant case study.
2) The proposed water withdrawal of 1,200 gallons per minute (GPM) during the digging of eight wells, and then an operational withdrawal of 800 to 900 GPM will not be sustainable and will likely create significant water table reductions in the immediate area. The Michigan Water Withdrawal Assessment Tool needs to be applied to the proposed water requirements of the mine prior to permitting.
3) It is the responsibility of the DEQ to permit only those operations that do the least environmental damage. The location of the proposed mining operation would be located in an area surrounded by wetlands, and thus do a great environmental damage. Four delicate wetlands need not be destroyed, when the company seeking the permits has mining leases involving thousands of acres in both Osceola and Mecosta Counties. There are dozens of locations in the leased areas by Michigan Potash Company LLC that offer the potential to do far less environmental damage in the development and operation of these mines. The DEQ has a responsibility to ask the company to seek a less potentially harmful location.
4) It is deeply troubling that the company seeking these permits is a limited liability company. Michigan Potash Company LLC is not a Michigan company, but operates out of a suite in downtown Denver that appears to be inside of another Colorado LLC. It appears to be purposefully unclear as to the actual ownership of this operation and clearly it is a legal situation that demands a large performance bond as a requirement for permitting. It poses a legitimate responsibility concern as well as a liability “dodge” for a shadowy investment. The proposed mining location is sufficiently environmentally important and delicate that a performance bond of $100 million dollars would not be too much. Also, Magna Corporation, as a vendor for well plugging, cannot be considered the final bonding party for this part of the surety performance. Who are the actual owners of these permits and should they be granted?
MCWC believes that permitting the proposed mine, without resolution of these issues, would be irresponsible and too dangerous for the environment and the people living in the area surrounding the “proposed’ Potash Mine.
We would respectfully request an explanation from you concerning this permit.
Michigan Citizens for Water Conservation
Board of Directors