We think that's a terrible idea. Here's why:
1. These wetlands are important!
Natural wetlands are essential to the quality of our groundwater, our ability to store carbon, habitat for wildlife, and more. Through the Tilden and Empire mines, Cleveland Cliffs has destroyed almost 1,000 acres of wetlands and lakes and over 100,000 linear feet of streams in the Escanaba River watershed, starving the watershed and severely fragmenting wildlife habitat.
2. Tilden has better options.
Tilden claims the 32.5 acres is the smallest amount of wetland impacts they can feasibly accomplish. However, they've identified stockpile options that would allow them to reach their storage goals while slashing the wetland impacts even further.
The (complicated, sorry) map above shows the "options" for waste rock stockpiles that Tilden identified in this application. The legend shows that Tilden wants to use the whole of a few of these stockpiles, which would create significant wetland impacts (EGLE believes they'd have to look back to the last 5 years to see the last time they permitted impacts this large). However, by using a part of their proposed alternative, in the hot pink, red, and aqua/light green options, as well as part of either the mint green or neon green areas, they can avoid most of their proposed wetland impacts and ALL of their stream impacts.
3. What's up with that mitigation plan?
Tilden proposes to mitigate its impacts to wetlands through use of two sites: Republic Wetland Preserve (RWP) and Green Creek wetlands. One of these sites, the RWP, is outside of the Escanaba River watershed entirely, and is almost 17 miles from the proposed impacts. The other site, at Green Creek, is at least in the watershed. However, it is still over 8 miles downstream of the proposed impacts. We reject the notion that this mitigation plan adequately replaces the functions of the wetlands to be lost, nor does it preserve wetlands that are shown to be threatened like those targeted in the permit application.
We propose on-site wetland restoration and protection.
These are wetlands that were previously threatened by Tilden's last permit application, and which have continuously demonstrated resilience in their ability to function as wetlands despite decades of degradation from the development of roads, railroad grades, utility corridors, logging, and 175 years of iron mining under Cleveland-Cliffs ownership.
These wetlands deserve to be permanently protected. This plan would allow Cliffs to make a strong statement of their commitment to long-term watershed protection to restore and preserve these wetlands.
(Link goes to a Google Drive folder containing relevant permit application documents)
Thank you to everyone who submitted a public comment raising concerns about the permit application! As of June 20, 2024, Cliffs has withdrawn its permit application to fill 77.9 acres of wetlands and 4,661 linear feet of streams with mine waste. EGLE recommended the withdrawal due to issues with tribal concerns and coordination, cumulative impacts in the watershed, and public comments. See news coverage of this announcement here!
The Tilden Mine is an open-pit iron ore mine located 5 miles south of Ishpeming in Marquette County. Owned and operated by Cleveland-Cliffs (“Cliffs”), the Tilden and Empire mines sit directly adjacent in the Escanaba River watershed. According to recent calculations, Tilden employs close to 1,000 people, making it a significant economic driver in Marquette County.
With an average ore grade of only 30%, the mine produces a significant amount of waste, which is stored both in piles which have filled entire lakes and streams in the watershed, as well as created bright orange tailings ponds so large they’re visible from space.
The Tilden is reaching the end of its mine life, and in order to continue mining, they desire additional space to store more waste rock generated by their mining operations. In 2022, Cliffs submitted a wetland permit application to Michigan’s Department of Environment, Great Lakes, and Energy (EGLE) to fill 97.7 acres of wetlands and 6,749 linear feet of streams in the watershed with mine waste. They withdrew that application in 2023 due to the federal listing of the Northern Long-Eared Bat (NLEB) as an endangered species, and subsequently contracted out a survey of the proposed site to determine the presence of the NLEB.
Cliffs submitted a second application on December 20, 2023 to fill 77.9 acres of wetlands and 4,661 linear feet of streams with mining waste. [to see 2023 application, click here and download PN PLANS GO from 12/20/2023]
Citizens for a Safe & Clean Lake Superior has serious concerns about this expansion and banded together with UPEC-Mining Action Group to conduct outreach and encourage the public to submit comments in opposition to the 2023 permit application. Click to see CSCLS's and UPEC-MAG's comments. Our outreach was successful in garnering over 500 public comments in opposition to the application using a form-based template comment for user convenience, citing the following reasoning:
The U.S. Environmental Protection Agency submitted a letter to EGLE objecting to the expansion project on April 1, 2024, which included another letter from the U.S. Fisheries and Wildlife Service citing additional concerns. EGLE met with Cliffs representatives multiple times following the end of the public comment period, and eventually recommended Cliffs withdraw the application due to approaching administrative deadlines and unresolved key issues. Major concerns shared by EGLE and EPA include tribal coordination and concerns, and issues raised in public comment, especially cumulative impacts within the watershed.
If you’re interested in reading the hundreds of public comments, correspondence between EGLE and the Mining Company, or other documents relevant to the application and issue, they are available below as PDFs or directly from MI Enviro Portal.
Joint Permit Application (too large to upload -- in this link, it is called PN PLANS GO. In September 2024, it's on page 9)
Republic Wetland Preserve Supporting Information
EGLE Correspondence Recommending Withdrawal
EGLE Clarification Mitigation Watershed Boundaries