JUN   3 3 198b






   neon C. La FoSlleft
   Atorney Geral

     Gead S. Wilcox
DeputyAffrny General



June 26, 1986



Mr. Howard S. Druckenmiller
Director, Bureau of Environmental
   Analysis and Review
Department of Natural Resources
Post Office Box 7921
Madison, Wisconsin 53707

      Re: Draft Environmental Impact Statement Comment/Crandon
           Project

Dear Mr. Druckenmiller:

     Enclosed is a copy of a review of some of the socio-
economic impact analysis done by the Department on the
Crandon project. The review was done by Professor Alenen
at the University of Wisconsin. Professor Alenen's remarks
have great pertinence to the Draft Environmental Impact
Statement, especially since the statement does not analyze
mine shutdowns and their effect on communities. I am
submitting Dr. Alenen's comments as supplemental DEIS
comments on behalf of the Public Intervenor's office.

                             Sincerely,

                             X    WSl1z i  i,
                             Waltraud A. Arts
                             Public Intervenor

WAA:pl

cc: William Tans



                                                                        
    JUN 3   1986


               DEPARTMENT OF LANDSCAPE ARCHITECTURE * SCHOOL OF NATURAL RESOURCES
    *         /COLLEGE OF AGRICULTURAL AND LIFE SCIENCES 0 UNIVERSITY OF
WISCONSIN-MADISON
               25 AGRICULTURAL HALL  0  MADISON, WISCONSIN 53706  0 TELEPHONE
608-263-7300


    June 13, 1986


    MEMO TO: Waltraud A. Arts, Assistant Attorney General

    FROM:    Arnold R. Alanen, Professor and Chairman

    SUBJECT: Comments on Denver Research Institute, "Preliminary
              Socioeconomic Impact Analysis of Exxon's Proposed Crandon
              Project"


        This review, by necessity, is brief, and is directed almost entirely
    to certain socioeconomic and cultural considerations that have proved
to
    be important throughout the entire Lake Superior region, both in previous
    years and at present. The comments are an outgrowth of the author's
    long-term interest in the historical development of this region.

        Mining activities have occurred in the Lake Superior region since
the
    mid-1840s when copper deposits in northern Michigan began to be
    exploited. Copper mining was followed by the initiation of iron ore
    extraction on the Marquette Range (Michigan) in 1846, Menominee Range
    (Michigan) in 1877, Gogebic Range (Michigan and Wisconsin) in 1884,
    Vermilion Range (Minnesota) in 1884, Mesabi Range (Minnesota) in 1892,
    and Cuyuna Range (Minnesota) in 1911. Today, only one copper mining
    operation--at White Pine, Michigan--is active. Likewise, virtually all
    of the high grade iron ore mines have closed, although the processing
of
    low content taconite ores has allowed mining activities to continue in
    areas of Michigan and especially Minnesota. Consideration of specific
    phenomena within the region can at least provide additional questions
(if
    not the answers) that were not addressed completely in the PSIA for
    Crandon.

        I. Though the PSIA mentions the need to identify the implications
of
    a premature closure or suspension of the project during its construction
    and/or operational phases, the impacts are perhaps understated (p. 153).
iDsruptions to personal and business income and to public finance are
\J  mentioned, as are the resulting commercial failures, layoffs, and
    out-migration of individuals that will occur. These are very likely and
    real possibilities, but little mention is given to the actual social
    costs that will result from such occurrences.

        The history of the Lake Superior mining region is replete with



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