“… a tendency to describe the kind of things that could be done rather than a commitment to do specific things.”

This file is a 2012 review of the Flotation Tailings Basin Management Plan by outside consultants (DS = Don Sutton, Spectrum Engineering, CO = Cecilio Olivier, EOR). Note that 5 years ago, DNR consultants were raising red flags about the way plans like this one were not requiring PolyMet to do anything and making it clear that they need to be changed if they would be used as part of a permit. Five years later, the DNR issued a draft permit to mine that continues to commit this error – incorporating plans that are permissive and descriptive, rather than prescribing requirements.

 

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