Legislature(2021 - 2022)BUTROVICH 205
02/28/2022 03:30 PM Senate RESOURCES
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| Mining Industry Update | |
| Adjourn |
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ALASKA STATE LEGISLATURE
SENATE RESOURCES STANDING COMMITTEE
February 28, 2022
3:34 p.m.
MEMBERS PRESENT
Senator Joshua Revak, Chair
Senator Click Bishop
Senator Gary Stevens
Senator Jesse Kiehl
MEMBERS ABSENT
Senator Peter Micciche, Vice Chair
Senator Natasha von Imhof
Senator Scott Kawasaki
COMMITTEE CALENDAR
Mining Industry Update
- HEARD
PREVIOUS COMMITTEE ACTION
No previous action to record.
WITNESS REGISTER
DEANTHA SKIBINSKI, Executive Director
Alaska Miners Association
Anchorage, Alaska
POSITION STATEMENT: One of three mining industry slideshow
presenters.
KAREN MATTHIAS
Executive Director
Council of Alaska Producers
Anchorage, Alaska
POSITION STATEMENT: One of three mining industry slideshow
presenters.
WAYNE HALL
Manager, Community and Public Relations
Teck Alaska - Red Dog Mine
Juneau, Alaska
POSITION STATEMENT: One of three mining industry slideshow
presenters.
ACTION NARRATIVE
3:34:52 PM
CHAIR JOSHUA REVAK called the Senate Resources Standing
Committee meeting to order at 3:34 p.m. Present at the call to
order were Senators Kiehl, Stevens, Bishop, and Chair Revak.
^Mining Industry Update
MINING INDUSTRY UPDATE
3:35:32 PM
CHAIR REVAK announced a mining industry update presented by the
Alaska Miners Association, the Council of Alaska Producers, and
Teck Red Dog Mine.
[The slideshow presenters introduced themselves and are
identified in the minutes below.]
3:36:49 PM
DEANTHA SKIBINSKI, Executive Director, Alaska Miners
Association, Anchorage, Alaska, one of three presenters began
the mining industry slideshow, stating the association
represents all aspects of the mining industry from large scale
mines and projects, Alaska's coal mine, the individual small
placer operations, sand and gravel, and the vendors and
contractors that do business with the mining industry.
MS. SKIBINSKI began the Mining Industry Update with slide 2:
[Original punctuation provided.]
Overview
• Global Factors: Growing Demand
• US Policy: Increase Domestic Production
• Alaska's Advantage
• Benefits for Alaska and Alaskans
MS. SKIBINSKI said that during this presentation she intends to
discuss the existing and predicted significant increase in
demand for minerals worldwide; the nation's reliance on foreign
sources of minerals and the policies needed to produce more
minerals here at home; and satisfying the mineral needs of the
nation by focusing on Alaska to produce them. Finally, the
presentation will spotlight the benefits of mining for Alaska
and Alaskans.
MS. SKIBINSKI recited a mining adage saying mining underpins
everything that we do, from the airbags in cars, to X-rays in
medical devices, to the fact that a person can walk into this
room and turn on the light. Modern lifestyles would be
impossible without mining. The global dependency on mine
products requires the steady production of minerals worldwide.
3:37:40 PM
MS. SKIBINSKI said that in terms of obtaining and satisfying the
world's need for minerals, this is just the beginning. The
pursuit of renewable technology and energy storage has sent and
will continue to send the demand surging. Subsequently, the
production of these minerals needs to surge as well. The World
Bank, the International Energy Agency, and other entities have
studied the global energy goals and project a massive increase
in mineral needs moving forward. The following slides address
how the growing demand for minerals can be satisfied.
MS. SKIBINSKI advanced to slides 3 and 4:
Global Factors: Growing Demand for Minerals
Mineral Production to Soar as
Demand for Clean Energy Increases
Washington, May 11, 2020 - A new World Bank Group
report finds that the production of minerals, such as
graphite, lithium and cobalt, could increase by nearly
500% by 2050, to meet the growing demand for clean
energy technologies. It estimates that over 3 billion
tons of minerals and metals will be needed to deploy
wind, solar and geothermal power, as well as energy
storage, required for achieving a below 2-degree
Celsius future.
The report "Minerals for Climate Action: The Mineral
Intensity of the Clean Energy Transition" also finds
that even though clean energy technologies will
require more minerals, the carbon footprint of their
production - from extraction to end use - will account
for only 6 percent of the greenhouse gas emissions
generated by fossil fuel technologies. The report
underscores the important role that recycling and
reuse of minerals will play in meeting increasing
mineral demand. It also notes that even if we scale up
recycling rates for minerals like copper and aluminum
by 100%, recycling and reuse would still not be enough
to meet the demand for renewable energy technologies
and energy storage. (The World Bank)
"Over 3 billion tons of minerals and metals will be
needed to deploy wind, solar and geothermal power, as
well as energy storage, required for achieving a below
2?C future."
"Even though clean energy technologies will require
more minerals, the carbon footprint of their
productionfrom extraction to end usewill account for
only 6% of the greenhouse gas emissions generated by
fossil fuel technologies."
...even if we scale up recycling rates for minerals
like copper and aluminum by 100%, recycling and reuse
would still not be enough to meet the demand for
renewable energy technologies and energy storage."
MS. SKIBINSKI began the discussion of how to satisfy the growing
demand for minerals by addressing recycling. As part of a
mineral strategy, the pursuit of mineral recycling must continue
as well as investing in technology to improve its efficacy.
Understand that recycling alone will not be enough to satisfy
the world's mineral needs. She cited a projection from The World
Bank and explained that even if base metal recycling rates like
copper and aluminum doubled, it would still not be enough. The
nation must broaden its approach to satisfy its mineral needs.
3:38:47 PM
MS. SKIBINSKI advanced to slide 5, Where Our Critical Minerals
are Coming From. She asked the committee where they want mining
to occur knowing that mining must increase to meet global needs.
Slide 5 contained headlines which indicate the U.S. is losing
ground to China in the contest for clean energy and dominance in
rare earth production. The world has watched political
instability unfold over the last few days. The United States is
reliant on minerals that are mined in unfriendly countries;
countries with the ability to hold the U.S. economy hostage. The
U.S. is importing 90 percent of its rare earth needs from China.
The majority of the world's cobalt is produced in the Congo with
operations employing young children in poor conditions; it is
better for mining to occur in a country with strong safety and
environmental laws.
3:39:29 PM
MS. SKIBINSKI advanced to slide 6, stating this quote from U.S.
Senator Lisa Murkowski summed up America's predicament best:
Mined in America: US Policy Needed
"America's reliance on foreign countries for the
production and recycling of our critical minerals is a
vulnerability to our national security, a disadvantage
to our economy, and a hindrance to our global
competitiveness. Unfortunately, the current Federal
permitting and review process is painfully
inefficient."
- Senator Lisa Murkowski
MS. SKIBINSKI said that the permitting system must change to
turnaround the nation's vulnerable position. America's laws are
among the strongest and most stringent in the world. However,
the federal government's implementation of these laws has
resulted in a negative impact on investment with no added
benefit to the environment or safety. She enjoyed making these
same points in the previous three administrations, possibly
longer, about the fundamental policies that are needed to grow
mining in the U.S. To varying degrees these are the building
blocks of what it takes to get more mining investments in our
country. It is unfortunate that the nation has taken major steps
backwards in these fundamentals in the last year. While the
current federal administration touts a desire to achieve its
climate goals, acknowledges more mining has to take place, and
purports more mining needs to happen domestically, it has not
acted accordingly.
MS. SKIBINSKI reviewed the following bullet points, stating that
to produce more minerals here at home the mining industry needs:
• Access to lands
MS. SKIBINSKI discussed the nations need to have access to
mineral deposits; this is particularly true in Alaska where
known mineral potential is mostly in remote locations. The
patchwork of land ownership in Alaska means exploring
mineral deposits on federal lands will be more challenging.
Working on state or private land still requires access
across federal lands in most cases. Instead of multiple use
management and access to deposits, the Biden administration
has instigated significant changes with land management.
One example of this is the recent reimposition of the
roadless rule in the Tongass National Forest. Previously,
the roadless rule had an exemption which facilitated
mineral development, hydropower projects, and other
economic development in the Tongass National Forest. This
exemption is no longer in place.
• NEPA process scope and timelines
MS. SKIBINSKI said the industry was affected by the
cancellation of improvements made under the National
Environmental Policy Act (NEPA), the nation's permitting
process created alongside the nation's environmental laws.
The NEPA process has swelled to result in documents where
thousands of pages have limitless topic areas, and it can
take years to pull one of these documents together. It has
become difficult for agencies and project proponents to
manage and even more difficult for the public to engage in
and track. Recent attempts to make the process more
thorough and efficiently managed, have been rolled back.
Previous collaborations between agencies has suffered as a
result.
• Collaboration amongst agencies
• Decrease risk of litigation
3:42:07 PM
MS. SKIBINSKI said that regulatory changes that swing on a
pendulum can result in regulation processes that lack
clarity, and in turn, can open projects and permit
decisions up to the risk of litigation. It is fair to
assume that all types of resource development in the U.S.
will encounter litigation at some point, but the cost of
litigation and delays is especially detrimental to Alaska
in terms of attracting investment.
• Public comment improves project; increases support
MS. SKIBINSKI said the mining industry believes that
engaging with the public early and often has a two-fold
benefit:
1) Working with local, public stakeholders improves the
proposal, and
2) It demonstrates that the industry is working with local
communities and helps to gain support for the proposals.
• Spotlight on Ambler Road decision
MS. SKIBINSKI recapped a White House announcement which
introduced the next steps to a mineral strategy, titled
"Securing a Made in America Supply Chain for Critical
Minerals." She asked the committee to consider how mining
in America could be improved based on the following events.
A White House announcement emphasized the importance of
critical minerals, yet the actual details instruct the
Department of the Interior to evaluate the need to reform
mining laws with an insinuation that domestic mining is not
done responsibly. That same day, the Department of the
Interior announced that it had asked the federal court to
vacate the permit that was obtained for Ambler Road and to
reopen the environmental analysis alleging there were
deficiencies in the process. This was a process that
spanned three federal administrations and it had dozens of
public meetings throughout Alaska, particularly along the
road corridor, with multiple opportunities for public
comment in a transparent process.
MS. SKIBINSKI admitted that she talked at length on slide
6, but it paints a picture of the magnitude of industry
challenges with the federal administration. She thanked the
chair and the committee for their efforts to defend Alaska
against federal difficulties.
3:44:17 PM
KAREN MATTHIAS, Executive Director, Council of Alaska Producers,
Anchorage, Alaska, one of three presenters continued the mining
industry slideshow, stating the Council of Alaska Producers is
the trade association for five large metal mines and several
advanced development projects in Alaska. The soaring demand for
minerals was just covered. Increasing production is good for the
nation's economy, and security. The state must ensure Alaska
gets its fair share of investments, not only to be part of the
national solution but to grow Alaska's economy.
MS. MATTHIAS highlighted Alaska's advantages listed on slide 7:
Alaska's Advantage
• Mineral potential
• Strict environmental regulations
• Excellent track record
MS. MATTHIAS advanced to slide 8, stating that the Fraser
Institute annual global survey of mining companies consistently
ranks Alaska in the top five jurisdictions for its pure mineral
potential. The map on slide 8 shows that Alaska is so abundantly
rich in minerals, that it was hard to fit all mineral data on
just one map to illustrate the enormous mineral potential in
Alaska. The map depicts the minerals Alaska is currently
producing. Six stars mark large mines. Diamonds indicate 44
statewide projects, ranging from early-stage exploration to
advanced development. Circles on the map indicate prospects, all
the sites known to have mineral potential. The map emphasizes
the contrast between the sizeable number of projects and
prospects compared to the small number of mines. This is due to
the challenges of developing a mine in Alaska. Remote locations,
lack of infrastructure, and high cost of energy add to the cost
of developing mines in the state. Labor shortages and supply
chain delays are also development hindrances, which are
currently being experienced by all industries across the board.
Lastly, unpredictable political interference with federal
permitting sends a negative message to investors and companies.
3:46:33 PM
MS. MATTHIAS advanced to slide 9, Mining Development Takes Time,
stating that it is a long process to bring a mine into
production even in the best of circumstances. The graphic on
slide 9 shows a mine timeline, depicting the stages of
development, from its infancy to operational maturity. In a
perfect world, the feasibility and permitting stages would take
ten years, but recently these stages have taken longer. As
global demand for minerals increases, commodity prices are
expected to stay robust, and projects are progressing. The state
is on the cusp of realizing Alaska's potential. The state's
large mines have been in production for many years, and are
still going strong. They are exploring and permitting expansion
to continue operating in years ahead.
3:47:16 PM
MS. MATTHIAS explained that the map on slide 10 takes a closer
look at mines in the state. While the industry is proud of its
contribution to state revenue, it could increase the
contribution by bringing more mines into operation. The map
illustrates the regional impact of mining. The red stars show
large producing mines, which operate 24/7 throughout the year.
Large mines employed 3,000 miners and onsite contractors in
2020. Moving from north to south, the large mines are:
- Red Dog, the world's largest zinc concentrate producer. It is
an open pit mine on Northwest Alaska Native Association (NANA)
land.
- Fort Knox, the largest producing gold mine in Alaska. It is
located outside Fairbanks. The employees are able to live in the
Fairbanks North Star Borough and commute to work.
- Pogo is an underground gold mine near Delta Junction. Pogo
built and maintains a 50-mile road to access the mine from the
road system.
- Usibelli Coal Mine is immediately adjacent to Denali National
Park. It has been in operation since 1943 and has been family
owned the entire time. A report has been distributed to the
committee that provides more detail about Usibelli.
- Greens Creek and Kensington are both underground mines in
Southeast Alaska and their workers commute to work by boat.
Greens Creek is the top silver producer in the United States,
producing 30 percent of the nation's domestic supply of silver.
The industry has two projects in permitting: Donlin Gold in
Western Alaska and Pebble in Southwest Alaska.
This map also highlights the industry's current advanced
exploration projects with green circles. Moving from north to
south these projects are:
- Upper Kobuk in the Ambler Mining District, Northwest Alaska.
- Graphite Creek near Nome
- Livengood near Fairbanks
- Manh Choh in Tetlin
- Palmer near Haines
- Niblack on Prince of Wales Island
MS. MATTHIAS said there are dozens more projects and deposits:
- Dawson which is a small underground gold mine
- Bokan Mountain which is a rare earth project
Both of these projects are on Prince of Wales Island. The wide
distribution of yellow circles on the map represents one of the
over 90 communities in Alaska where a mining industry employee
lives.
3:49:58 PM
MS. SKIBINSKI advanced to slide 11, stating placer mines are
commonly referred to as the state's seventh large mine. There
are approximately 170 active placer mining operations across
Alaska. The slide depicts a variety of different placer mining
methods. Placer mining is generally small-scale. Gold is
recovered from dirt using water and gravity. These mines
resemble a neighborhood construction project that has a small
footprint and an average of four employees. Many of these
operations are family owned and operate seasonally when the
ground is not frozen.
3:50:45 PM
SENATOR BISHOP directed attention to the bullet point about
rigorous permitting on slide 12 and posited that more should be
done to highlight that Alaska does it right. He shared a story
about giving two regulators from the Army Corps of Engineers a
tour of a site that was placer mined 15 years ago. They
commented on the pristine wilderness and were surprised to see
the regrowth and habitat that had flourished since the mine shut
down. He also pointed to a representative sitting in the back of
the room who was doing reclamation before it was a federal law.
He apologized for the interruption.
MS. SKIBINSKI commented that Senator Bishop is right. The
presenters have photos of interior projects, dozens of placer
mines, and a coal mine, illustrating Senator Bishop's point, not
to mention regulators who have voiced similar praise. The mining
industry has received many national awards for its reclamation
work from the Bureau of Land Management (BLM) and the Department
of the Interior. The industry is proud of the work miners do.
3:52:50 PM
MS. SKIBINSKI advanced to slide 12, Doing it Right:
Environmental Safeguards. She said that Alaska miners have to
work within an environmental regime. The industry maintains that
the state's mining operations and the agencies that regulate
them account for what is a world class regulatory system. Mine
permits protect all aspects of the environment, including air,
land, water, fish and wildlife, and public health. The industry
strives to reduce emissions, energy, and water consumption by
continually seeking efficiencies and improvements. Throughout
its lifespan a mine has strict regulatory oversight, including
reclamation and restoration of the site after closure. The mine
must have tailored financial assurance prior to operation, so
that the public does not bear the burden if the cost of
reclamation falls to the state.
• Rigorous permitting regulations
• Strict operational oversight
• Reducing emissions and increasing efficiency
• Closure/Reclamation
• Financial Assurance prior to operating
3:53:51 PM
MS. SKIBINSKI advanced to slide 13 which shows the scope of
mining permits. This list was supplied by the Department of
Natural Resources (DNR).
No Single Permit to Mine: there are
many permits & authorizations
Mine permitting is a mixture of State, Federal
and local permitting requirements. Each project
is unique.
STATE
? Plan of Operations (DNR)
? Reclamation and Bonding (DNR)
? Waste Management Permits and Bonding (ADEC)
? CWA Section 402 APDES Water Discharge Permit
? Certification of ACOE Permits (ADEC)
? Sewage Treatment System Approval (ADEC)
? Air Quality Permits (ADEC)
? Fish Habitat and Fishway Permits (ADF&G)
? Water Rights (DNR)
? Right of Way/Access (DNR/DOT)
? Tidelands Leases (DNR)
? Dam Safety Certification (DNR)
? Cultural Resource Protection (DNR)
? Monitoring Plan
(Surface/Groundwater/Wildlife)
(DNR/DEC/DFG)
FEDERAL
US EPA Air Quality Permit review
US EPA Safe Drinking Water Act (UIC Permit)
US ACOE S. 404 Dredge and Fill Permit
US ACOE S. 10 Rivers and Harbors Act
US ACOE S. 106 Historical & Cultural Resources
Protection
NMFS Threatened & Endangered Species Act
Consultation
NMFS Marine Mammal Protection Act
NMFS Essential Fish Habitat
NMFS Fish and Wildlife Coordination Act
USFWS Threatened & Endangered Species Act
Consultation
USFWS Bald Eagle Protection Act Clearance
USFWS Migratory Bird Protection
USFWS Fish & Wildlife Coordination Act
These are only some of the permits required!
Permitting a mine in Alaska takes many years from start to
finish. The process includes planning, an environmental study,
review, testing, and approval. Dozens of local, state, and
federal government agencies are involved in the process. The
permits listed above are typical for a large mine on state- or
privately-owned land and would still require a significant
amount of federal authorization. By comparison, a mine permitted
on federally owned land requires many additional permits like
those under the Bureau of Land Management and-or U.S. Forest
Service regulations. These permits contain multiple stipulations
that agencies can and do prescribe. The stipulations are either
outside of or in addition to governing laws and mines must
perform on them.
Slide 13 points out that there is no one decision to approve one
single permit for a mine in Alaska. None of the steps within a
mine permitting process guarantee approval. There is no
automatic yes, no rubber stamp. Every mine is different, and
each requires a tailor-made environmental mitigation plan
discussed and altered at length by both the agency and the
project proponent before advancing a stage forward.
3:55:25 PM
MS. SKIBINSKI advanced to slide 14, Permitting Flow Chart. DNR
supplied this chart dissecting Alaska's specific environmental
management. It provides an overview of how many agencies and
departments are involved in evaluating mining proposals and
their monitoring goals through all the mine stages. It is
important to understand that multiple opportunities for public
participation continuously occur throughout the permitting
process. The importance of public participation is on par with
"no automatic approvals" in the permitting process. The chart
shows that a large mine permit requires thirteen public notices,
and the state sponsors an additional four as a courtesy. The
process is transparent and designed to ensure the public has a
voice in state mining activity.
3:56:12 PM
MS. MATTHIAS advanced to slide 15, stating that the strict
oversight in permitting also continues through the operational
life of the mine:
Strict Operational Oversight
Alaska: the best mine monitoring
system in the world
• Water quality monitoring
• Bottom-to-top comprehensive biomonitoring
• Third-party of both the mine and the regulatory
agencies
Alaska has one of the best water quality monitoring systems in
the world with respect to mines. It has two distinct parts:
First, water quality monitoring. This is fairly standard
globally, but Alaska's system is more comprehensive than many.
Second, Alaska goes further and does biomonitoring, which is
less common in other jurisdictions. The Alaska Department of
Fish and Game (ADF&G) oversees the monitoring of algae, the
benthic zone, and fish, including metals uptake, habitat, and
population. Alaska does more and better monitoring than most of
the world, and it is a system of which to be proud.
MS. MATTHIAS advanced to slide 16, Reclamation and Closure,
which clarifies misunderstood reclamation laws with these key
points:
• Alaska law (AS 27.19) requires that a mine site must
be returned to a stable condition compatible with
the post-mining land use
• Plan must be approved by DNR Commissioner before
operations begin
• Financial assurance applies to all companies
A mining company must provide financial assurance at the outset
and may not use the funds for reclamation work. Financial
assurance funds are guaranteed to the state so that if the
company cannot perform the reclamation, the state can step in
without tapping its treasury. It does not matter where a company
is headquartered or who owns the land; financial assurance
applies to all companies mining in Alaska.
• Reviewed every 5 years or earlier if necessary
Finally, the financial assurance amount is not set then
forgotten. The guarantees are reviewed every five years or
whenever a significant change requires review.
3:58:17 PM
MS. MATTHIAS advanced to slide 17, Poker Flats - Usibelli Coal
Mine, stating a couple of good reclamation examples follow:
DNR Commissioner Corri Feige: "In successfully
achieving Phase III bond release, Usibelli has
demonstrated the fundamental strength of our state's
mineral development system. We can develop our land to
produce resources to meet the state's energy and
economic needs, then restore the land to provide
healthy habitat for people and wildlife."
September 2021
Alaska's coal mines require a three-phase bonding process. Phase
I includes backhoeing and regrading to restore or approximate
the original contour; this may occur within the first year of
mining. Phase II requires planting native vegetation and
establishing drainages; this can take several years. Phase III
requires successful completion of the first two stages plus:
-a minimum of ten years after the completion of Phase II, plus
-two years of vegetation studies to validate sufficient
vegetative cover and diversity.
Phase III is a fairly involved, multi-step process. When
Usibelli Coal Mine began its operation in the Poker Flats area
near Denali National Park almost forty years ago, it committed
to restoring the land and posted a bond backing that promise. As
Senator Bishop mentioned earlier, this was before reclamation
was required. The company did it because it was the right thing
to do. DNR declared that Usibelli had achieved top tier, Phase
III status last September. Alaska can and does develop land to
produce resources to meet the state's energy and economic needs,
then restores the land to provide healthy land for people and
wildlife. Usibelli is right to be proud of its achievement.
3:59:56 PM
CHAIR REVAK agreed, saying that sometimes the worst is heard
about the interface of mining and the environment, but it is
important to note, again and again, that Usibelli was restoring
the site before it was the law because it was the right thing to
do. There are many miners and organizations that go to great
lengths to be good stewards. Television ads show an opposing
message from time to time, but in many cases, the land is left
better than it was found.
4:00:40 PM
MS. MATTHIAS stated that Alaska does not have a lot of
reclamation examples because most of the mines that started in
the modern mining era are still operating. Alaska's oldest mines
are Red Dog and Greens Creek, both mines began operating in
1989, and both are still in operation. While reclamation is
ongoing during operations, a full closure simply has not
happened at most mines in the state. One exception is True North
Mine.
MS. MATTHIAS advanced to slide 18, quoting Commissioner Feige's
acclaim for the full reclamation of True North Mine:
True North - Kinross Alaska
DNR Commissioner Corri Feige: "The developers leased
state land, produced a valuable commodity to serve
global markets, employed Alaskans, and paid state
taxes and royalties. When they were done, they
remediated the effects of their work and returned the
land to the state for its next use. The system works."
October 27, 2020
4:01:51 PM
MS. MATTHIAS advanced to slide 19, Benefits for Alaska and
Alaskans which pictures the roots, trunk and leaves of a tree
planted in soil. The soil represents state land, federal land,
and Alaska Native corporation land; the roots represent science-
based policy and regulations; the trunk represents mining
companies and landowners; and the leaves represent how all parts
benefit each other when properly nurtured. These benefits are
not limited to job opportunities and contributions to state and
local tax. Other benefits include vocational training and
scholarships, supporting local goods and service industries,
supporting Alaska nonprofits, and promoting a safety culture
learned on-the-job and passed on at home and to the community.
The following mine example delves deep to illustrate how mines
and projects collaborate with different communities and what
that partnership looks like at the Red Dog Mine.
4:02:39 PM
WAYNE HALL, Manager, Community and Public Relations, Teck
Alaska-Red Dog Mine, Juneau, Alaska, a mining industry slideshow
presenter added the following personal touch to show how the
mining industry benefits people. He moved to Juneau in 1971.
Juneau is a town built on mining. It is a town that still
utilizes infrastructure from those mining days, like a
hydroelectric facility. He left Juneau to obtain a degree in
environmental science, returned to work at the Greens Creek
Mine, and now works at the Red Dog Mine. Working in the mining
industry benefitted himself, his family, a lot of friends in
Juneau and in Northwest Alaska.
MR. HALL advanced to slide 20, NANA, Red Dog Mine, Teck, stating
this is an opportunity to brag on the mining industry. It shows
some of the different compartmental areas of how mines produce
benefits. In the case of the Red Dog Mine, NANA Regional
Corporation owns the land and the resource. Red Dog is fortunate
to have a great partnership with NANA.
MR. HALL pointed out a couple of areas of focus that people do
not think about often. One is local control. When the Red Dog
Mine development was proposed, the Northwest Arctic Borough
(NAB) was formed. The borough created an opportunity:
- for the region to make decisions for themselves,
- to decide how to generate revenue from the mine, and
- for local control of schools and the school district. In a
related sense, mining helped expand educational opportunities
with the magnet school, GeoForce, scholarships and internships,
and participation in the Alaska Native Science and Engineering
Program (ANSEP). Mining also generated opportunities in the
trades and post-secondary education.
4:05:27 PM
MR. Hall stated that many people do not realize that monies from
the resource mined at Red Dog are reaching every corner of the
state. He reviewed slide 21, a bar graph with stacks of dollar
bills representing the mine dollars that are circulating in the
Alaska economy:
Broad Benefits of Development
~75 percent U.S. zinc
production & largest zinc
mine in the world (2019)
Red Dog Mine
$2.65 BILLION proceeds paid to NANA since mining began
(thru FY 2021)
MR. Hall stated that NANA shared 70 percent of its proceeds
through the 7(i) and 7(j) sections of the Alaska Native Claims
Settlement Act (ANCSA).
$1.6 BILLION in total 7(i) payments (thru FY 2021)
MR. Hall stated that $1.6 billion has been paid out to all the
other Alaska Native Corporations and most of the Alaska Village
Corporations as well.
$1.4 BILLION Payments to State of Alaska, AIDEA
(thru 2021)
MR. Hall stated that the State of Alaska has received $1.4
billion over the years thru corporate taxes, Alaska mining
license taxing, and shipping containers through the state-owned
Alaska Industrial Development and Export Authority (AIDEA)
facility. Red Dog ships its concentrates out through the AIDEA
facility;
$318 MILLION to NAB since mining began (thru 2021)
$270 MILLION Spent on goods in Alaska in 2021
~$80 MILLION Annual wages (2021)
4:06:44 PM
SENATOR BISHOP pointed out that $318 million was contributed to
the borough thru 2021, $270 million was spent on goods in Alaska
in 2021, and $80 million was paid-out in annual wages in 2021.
These numbers show the economic impact Red Dog has on the state.
Alaska needs more mining to drive the state's gross domestic
product and bend the economic curve upwards, which is not the
trajectory the state is on now.
4:07:33 PM
MR. HALL advanced to slide 22:
Broad Benefits of Development
Organization Project Amount
City of Kivalina Evacuation Road $1,000,000
City of Kivalina Electrical Intertie $3,500,000
City of Selawik Water & Sewer $1,000,000
Native Village Wellness Program $378,872
of Selawik
Ipnatchiaq New Generator $147,750
Electric Co
Native Village On-demand $166,049
of Deering Water Heaters
Native Village Water & Sewer $579,331
of Buckland
MR. HALL stated that Red Dog has two primary mechanisms for
providing funding specific to some of the NAB projects:
1. Payment in lieu of taxes, which generates 90 percent of the
borough's revenue.
2. The Village Improvement Fund. The balance is between $4 and
$8 million, having a floor of $4 million and a ceiling of $8
million. It is based on mine profits, so even in bad times the
fund balance will be no less than $4 million. Since the
beginning, the fund has made significant payouts.
MR. HALL pointed out that a 7-mile evacuation road was built on
a spit from Kivalina inland. The road had erosion problems, so
$1 million in NAB project funds helped with repairs to the road.
Additionally, NAB used $3.5 million in project funds for the
electrical intertie at the end of the new road, which is the
location for the new Kivalina school and proposed townsite. The
amount of money is significant. These funds can be leveraged for
grants, other opportunities, and other funding because seed
money is available.
MR. HALL expressed industry pride in this program. The people
from these communities decide how to use the infrastructure
funds. A commission meets to make decisions on applications
received from all the communities. So, all eleven communities
decide how to use the funding. It is quite a unique model.
4:09:34 PM
MR. HALL advanced to slide 23, Jobs and Livelihoods:
Teck Alaska Persons on Roster as of September 2021
? Regular 527
(56.4% NANA Shareholder)
? Seasonal & Temp - 92
(96.7% NANA Shareholder)
73% of employees live in Alaska
MR. HALL explained the difference between a job and a
livelihood. Red Dog Mine has jobs, but it also offers
livelihoods. Many employees enjoy working four months out of the
year during the shipping season, spending the balance of the
year enjoying a subsistence lifestyle. Red Dog sees itself as a
steppingstone. Between 1300 and 1500 NANA shareholders have
worked at the mine and progressed into other areas throughout
the state. Red Dog is part of the path, offering on-the-job
training, which employees carry to the next opportunity. Red Dog
tries to improve NANA shareholder numbers and is proud that 73
percent of its workforce lives in Alaska.
4:10:48 PM
MR. HALL advanced to slide 24, Jobs and Livelihood, In-House
Apprenticeship Program:
Training
8,500 hrs avg/yr
Trades Apprentices
• Powerhouse, Electrical, Millwright
Heavy Equipment & Light Vehicle
Mechanic
• Apprentices are 25 percent of the total trades
Mill Operator Apprentice Program
• Commenced in 2016
• First Mine in North America
Red Dog Mine has a trades and apprenticeship program, and the
programs are listed on the slide above. Red Dog is the first
mine in North America to work with the U.S. Department of Labor
to develop a federally recognized apprenticeship program, the
Mill Operator Apprenticeship Program. Highly trained individuals
are coming out of these programs. These achievements are
significant.
MR. HALL advanced to slide 25, Alaska Built and Alaska
Infrastructure. The slide shows two building modules. One photo
shows a heavy piece of equipment transporting a mammoth-sized,
prefabricated powerhouse module; it was built in the Port of
Anchorage. The other photos are of the expanded personnel
accommodations complex. All of the accommodation modules were
built in a facility located in Big Lake, then transported to and
assembled at the mine site. He reiterated that the modules were
built in Alaska and employed Alaskans.
4:12:16 PM
MR. HALL advanced to slide 26, Alaska Built and Alaska
Infrastructure. Pictured in the slide are the DeLong Mountain
Regional Transportation Port Facility and associated road. The
facility is a state asset and a great example of the financing
work done by AIDEA. He expressed his belief that two of Alaska's
largest buildings, by square footage, are located in this
complex. Red Dog stores its concentrates all winter long here
while waiting for the Chukchi Sea's spring thaw. Also pictured
on slide 26 is the Kiana Junior High School. Eleven communities
qualified themselves to tap into the bond market when they
formed a borough. All but one of the eleven communities have
used the bond market to build a new school; the eleventh is yet
to be built.
4:13:31 PM
SENATOR BISHOP commented on slide 24, Jobs and Livelihoods, In-
House Apprenticeship Program. He noted that apprentices are
employed in 25 percent of the total trade positions in the mine.
The mine does not have to look as hard to find its workforce
when this model is embraced. When recruitment starts from day 1,
employees are indoctrinated into the model. It makes recruiting
easier for the Human Resources Office and it is the right thing
to do.
MR. HALL commented that having a ready work horse that wants to
embrace a lot those trades has been a successful model.
4:14:31 PM
CHAIR REVAK asked whether Red Dog Mine produces 75 percent of
the nation's zinc consumption.
MR. HALL answered not consumption. Out of all the zinc producers
in the United States, Red Dog Mine produces 75 percent of the
nation's output.
CHAIR REVAK asked whether any of that zinc is used for dietary
supplement.
MR. HALL answered yes. The United Nations Children's Fund
(UNICEF) has a program that combines salts with zinc, the Zinc
Association is involved with this program. In developing
nations, a lot of youth and babies die from dehydration due to
diarrhea. The hydration salts have been incredibly successful in
reducing child mortality due to dehydration. A very small
portion of production is used in rehydration tablets; but yes,
zinc is used as a dietary supplement.
CHAIR REVAK said that is fantastic. He has become more familiar
with zinc's immune system benefits over the last couple of
years. To think that a mine in the NAB could be benefiting, even
saving lives by improving the immune system is interesting.
4:16:02 PM
SENATOR STEVENS asked for more information about the state
reclamation fund; where the money comes from; where it is right
now; and can Alaskans be assured that sufficient funds have been
set aside.
MS. MATTHIAS answered that a company must set up financial
reassurance before completing much work and start-up. Some
financial instruments are available, like bonding, and she
expressed surprise that the law still allows a company to put up
gold. Financial reassurance is like an insurance policy.
MS. MATTHIAS said that the longer a mine is in operation, the
greater the reclamation effort required. The opposite is also
true. A shorter-lived mine requires less habitat restoration
effort. It is more economical and in its interest for a mine to
complete the work while staff and equipment are still on-site
before the mine ceases operations. If the mine fails to do the
reclamation work, the state will assess the reclamation cost
based on using third-party contractors, and third-party audits
will oversee the work. A company that uses its own on-site staff
and equipment is a more cost-effective reclamation strategy than
walking away, letting the state take hold of the financial
instrument, and hiring third-party contractors to do the job.
Each mine has its own individual financial assurance; money is
not pooled. Small mine reclamation works differently, but a
specific amount is set aside for large mines. The amount is
periodically updated so that the state can step in at any stage
of operation and take care of reclamation using third-party
contractors.
4:18:21 PM
CHAIR REVAK drew attention to the map with many projects and
prospects and the disproportionate number of mines, commenting
that it would seem the number of mines should be more
significant. He questioned the ratio of projects and prospects
to the number of large mines. He asked whether permitting
complicates the process of developing a mine and what the
legislature could do to help the process.
MS. SKIBINSKI replied that the ratio of mines is
disproportionately low to the number of projects and prospects.
She pointed out that the geographic distribution of deposits,
stating they are far from infrastructure, roads, ports, and
energy sources. If some of these deposits were in Nevada, on a
road system, they would already be developed. Available
infrastructure makes development tremendously cheaper. However,
a lack of infrastructure does prevent development, and the state
has good examples of companies that successfully developed mines
in challenging areas. Mr. Hall could give statistics on AIDEA
funding which helped make the DeLong Mountain transportation
system a reality. Using AIDEA to invest in the development of
infrastructure is a good step towards getting a mine online. The
legislature could help by finding ways to incentivize
infrastructure, large company investment in Alaska, and
encourage companies that want to invest significant capital for
a mine. Slide 9 shows the timeline for the development of a mine
but does not show the 100s of millions if not billions of
dollars spent on exploring, permitting, and ultimately
constructing a project.
MS. SKIBINSKI said the legislature could send the message that
Alaska is a secure place to spend your big dollars, and as long
as the regulatory tests of our nation's permitting system are
met, your mine will be permitted and constructed. Regulatory
certainty, the cost of infrastructure, and building in Alaska
are the biggest factors investors consider.
MS. MATTHIAS drew attention to the diamonds on the map of mines,
projects, and prospects. The diamonds are projects somewhere in
between early exploration and advanced development. These
projects have invested a significant amount of money to
determine:
- if what they think is there is in enough quantity, and
- if the grade is high enough
to be economically feasible to build a mine.
MS. MATTHIAS said the circles are prospects. Circles indicate
geologists have a good indication of potential, but the
significant drilling required to determine what is actually
there has not been completed. Do not assume the circles could be
a mine tomorrow; they are at the very beginning of a long
process. Circles must explore, drill, and assess results before
looking at a preliminary economic assessment to determine mine
feasibility. Then, they drill some more, explore some more, and
work some more while simultaneously launching environmental
studies, all in an effort to get closer to making a decision on
whether or not to build. A lot of holes are drilled that do not
immediately result in a mine.
4:23:16 PM
CHAIR REVAK expressed uncertainty whether the Ambler Mining
District is a diamond or a circle but expects a lot of money was
spent to get where they are in the process. The discussion today
mentioned permitting, but access is also another challenge for
mines. It is upsetting to see that the carpet was pulled-out
from under the Ambler project, and he asked what kind of message
this sends to the industry. He inquired about the status of
moving forward to deliver needed minerals to the world.
MR. HALL answered a message of frustration. He addressed a
previously asked question about opportunities. One opportunity
is to consider areas where Alaska can do the permitting in-house
rather than through the federal government. When the state went
through the process of obtaining primacy under the Clean Water
Act for the APS program, the Red Dog Mine operations were
greatly impacted. The permits are still rigorous and have to
meet all the Clean Water Act requirements, but Alaskans
understand the context, land, and water bodies, making the
process smoother. The primary hurdle for mines is wetland
permitting. He expressed his belief that wetland permitting is a
key opportunity and encouraged the legislature to consider
taking primacy over the wetlands program. Also, fund agencies
well enough; the industry needs good people to get permits.
MS. SKIBINSKI added to Mr. Hall's comment regarding the
frustrating Ambler Road decision. With the exception of ANCSA,
the Alaska National Interest Lands Conservation Act (ANILCA)
governs all state land ownership. ANILCA specifically granted
Ambler access, through the area, to get to a known mineralized
region. This fact adds insult to injury in the case of the
Ambler project and the Alaska Miners Association was dismayed by
the decision.
4:26:32 PM
CHAIR REVAK agreed with Ms. Skibinski's statement, especially
given the Russian hostilities in Ukraine and the focus on
critical and strategic minerals. The federal government is also
pushing green and renewable energy infrastructure, which is
great, but the conversation with Alaska's regulatory partners
has been frustrating. The fact is that every ounce of green
energy infrastructure is mined from the ground. He asked whether
Alaska's regulatory partners understand the connection between
green energy infrastructure and mining.
MS. SKIBINSKI answered that on the federal level, officials
indicate they understand the need for a huge increase in mineral
production to meet the nation's alternative energy and
technology goals. Unfortunately, their actions do not match
their words.
CHAIR REVAK stated that Alaska has about every strategic mineral
the nation might need. He asked how much progress has been made
towards the production of strategic minerals in the state.
MS. SKIBINSKI defined the difference between critical minerals
and strategic minerals. Critical means that you need it, and
strategic means that you do not have it. A strategic mineral is
available in the ground, but the country is not producing it and
does not have access to it. She emphasized a mine can extract a
strategic mineral from the ground and put it in production.
Alaska has strategic rare earth minerals that are not produced
domestically, for example, cobalt. The industry would like to
pursue the production of domestic mineral deposits in Alaska.
CHAIR REVAK asked what the challenges for mining rare earth
minerals are; the status of cobalt mining in Alaska; and the
hurdles to strategic mineral production.
MS. SKIBINSKI answered that one of the most promising cobalt
deposits was in the Ambler Mining District.
CHAIR REVAK commented that the nation has begged for rare earth
mineral production to reduce reliance on aggressive foreign
countries. He stressed the importance of talking about the lack
of domestic production, especially as the war continues in
Eastern Europe. The federal decision to roll-back on Ambler was
a blow. He asked whether there is hope for the production of
strategic minerals.
MS. SKIBINSKI answered yes. The Department of the Interior (DOI)
asked the court to vacate the lawsuit brought by environmental
nongovernmental organizations (ENGOs). DOI announced its plan
for more consultations with the region and reexamination of the
environmental analysis. DOI did not veto nor use other
mechanisms to take it off the table. She reiterated that the
process was transparent and thorough and went through three
different administrations. Unfortunately, the delay is costly.
DOI plans to re-engage in the process, optimistically speaking,
the reexamination might lead to an approval.
4:31:44 PM
MS. MATTHIAS cautioned members not to limit the focus to the
list of critical and strategic minerals. The problem with making
lists is that it leads to questioning why an item got left off
or put on. DOI put zinc on the 2022 Final List of Critical
Minerals this year, which is great because zinc is important.
However, copper did not make the list because there is a
sufficient supply domestically. Herein lies the problem.
International organizations, like the International Energy
Agency and the World Bank, have emphasized a huge increase in
copper will be needed for renewable technologies and electrical
transmission. This was discussed early in the presentation.
America needs to produce more copper, and its development should
not be ignored just because it is not on the list. Ambler and
Pebble are among multiple sites in Alaska that have copper
deposits. The state should look at all minerals that are
currently produced, their use and need domestically and
globally, and look at minerals that could be produced whether
the minerals are on a list or not.
4:33:10 PM
SENATOR STEVENS asked the presenters to reflect on foreign
ownership of mining in Alaska. He expressed concern about
foreign ownership in the fishing industry, and assumed foreign
ownership is also a concern in mining. He asked whether any
mines are Chinese-owned and why so few American companies are
involved in mining.
MS. MATTHIAS answered Alaska has six large mines. Three are U.S.
owned companies, two are Canadian owned, and one is Australian
owned. She argued that every industry in this state has
benefitted from foreign investments, including fishing, tourism,
mining, oil, and others. Mining requires huge sums of money for
exploration let alone bringing a mine into development. Access
to a large amount of capital is imperative as well as access to
expertise. It makes sense to reach out to an investment partner
rather than putting all an organization's resources into one
venture, consider NANA in this scenario. In the mining industry,
it is standard to reach out to companies who have resources and
expertise, choosing selectively to find the right fit.
Attracting investors is not a bad thing for Alaska. In fact,
most countries and jurisdictions compete to attract foreign
investment. She summated that yes, mines in Alaska have foreign
owners. They brought investment capital making it possible for
the mine to produce. Mining stimulates the economy, increases
the gross state product, and helps Alaskans buy items that are
not produced here, whether it is cars, food or other items which
come in on ships, barges, and planes.
4:35:34 PM
SENATOR STEVENS acknowledged the point then expressed concern
about entangling alliances. He explained that it would not be in
the best interest of Alaska to have large countries, like Russia
and China, involved in the state's mining industry. He
illustrated the concern by directing attention to the current
affairs unfolding in Europe, Germany's reliance on Russian
energy, and Germany's reluctance to take a hard stance. He
expressed hope that the mining industry here is never entangled
politically.
MS. MATTHIAS replied that she is not aware of Russian or Chinese
investments at-scale in Alaska, and certainly not in the Council
of Alaska Producers (CAP) membership.
MS. SKIBINSKI added that she is not aware of Russian or Chinese
investments at any scale but will research it and get back to
the committee.
4:36:45 PM
CHAIR REVAK agreed with Senator Stevens. Alaska relies on oil
from Russian neighbors for mining hydrocarbons; Alaska spent $20
billion last year. He expressed interest in what percentage of
the Russian GPD $20 billion totaled.
4:37:12 PM
SENATOR KIEHL redirected the discussion from international to
inter-state. He repeated Mr. Hall's statistic that 73 percent of
Teck-Alaska's employees live in-state, and the number of Alaskan
employees varies among large mines. Certainly, the high
apprentice utilization is a great step. He asked what additional
steps were taken to increase the number of Alaskans working in
the Alaska mining industry.
MR. HALL answered that he cannot speak to other mines, but Teck-
Alaska targets development opportunities, like the apprentice
program. A program that has not been discussed is the
Accelerated Development Program for Leadership which selects
candidates according to their potential to become leaders and
providing tools to help them. For instance, the program would
target someone exhibiting good leadership skills over someone
exhibiting good welding skills. The program focuses on
leadership development and advancing the candidate to
supervisory opportunities. Teck-Alaska targets where it puts
money associated with bursary scholarships. The purpose is to
recruit youth from the region to enter mining careers and direct
them to postsecondary education degrees. It can be challenging
and not everyone is cutout for a rotational job at Teck-Alaska.
The idea is to support a young person through school, but that
person may end up being very marketable in another place. For
example, one young, great NANA shareholder with an environmental
degree did a job for a year. It was not a good fit for him,
which is fine, because the job is supposed to be a
steppingstone. Now he works for Arctic Slope Regional
Corporation (ASRC). Teck-Alaska tries to think of new ways to
generate local jobs and develop people, focusing on education,
youth, developing the people that you have, and being deliberate
and purposeful.
MS. MATTHIAS added that each mine is different. Mines want to
hire Alaskans, support vocational training, scholarships, and
programs that prepare workers for the mining industry. The
following programs demonstrate the industry's desire to reach
out and provide opportunities for those with college degrees and
high school diplomas alike:
- Delta Junction has an underground mine training center. Two
Juneau mines use the Delta Mine Training Center to train new
hires. Pogo is an underground mine in the Interior that also
uses the training center.
- Both Juneau's mines collaborated with University of Alaska-
Southeast (UAS) to offer the Pathway to Mining Careers program.
- The University of Alaska-Fairbanks has the mining engineering
and geology programs.
A project is at an advantage when it can plan years ahead for
its workforce needs. Donlin Mine reached out to middle school
students years before start-up. The mine provided middle school
students with information about job availability, emphasizing
the mine's need for accountants, food service staff, human
resources staff, logisticians, and miners. Mines located in
remote sites are micro-communities. If you can think of a job,
you can probably do it at a remote location.
4:42:38 PM
SENATOR BISHOP revisited the issue of permitting.
4:42:45 PM
SENATOR KIEHL asked about extending the life of a mine,
significant expansions, and the permitting process involved.
MR. HALL replied that extending mine life falls into two main
areas:
First, continued exploration of the mine. He gave the example of
a potential opportunity under consideration about ten miles
north of the Red Dog Mine, underground and on state land. Red
Dog hopes to obtain the ore from that location and process it
through its facility. Red Dog is currently in the middle of
permitting a road, obtaining an air permit, and underground
drilling, which is needed to get the data necessary to make a
determination on project viability. Right now, it is only
possible to drill in the summertime. By going underground, it is
possible to drill year-round which will speed up the process of
collecting data. A host of permits are required for housing,
potable water, wetland permits, etcetera; permitting requires a
significant amount of time and engagement. This is true for an
advanced exploration project too. Once the exploration project
is permitted and the company makes the decision to move forward,
the mine has to go through another permitting process to extract
the ore source. Extending mine life requires taking a long
approach and questioning whether the mine can prove up and get
permitted before running out of its present source of ore.
Second, mines find ways to make unprofitable ore, known as waste
rock, profitable by using innovations and technology to improve
mining processes. Here are some examples:
- Xray Fluorescence (XRF) technology mounted on the bucket of a
loader can indicate whether the load is ore or waste rock.
- machines with optics examine pieces of crushed ore, separating
the ore from the waste rock. The process results in the delivery
of a richer ore to the milling facility.
- a host of other technology and innovation that allows a
company to re-mine a previously mined area.
4:46:21 PM
SENATOR BISHOP reviewed the timeframes on the Mining Development
Takes Time chart. He expressed his belief that it took about ten
years from inception to initial drilling to constructing the
Pogo Mine road. Pogo Mine was a relatively fast process compared
to Kensington Mine, which took about 20 years. He referenced
Senator Stevens' previous ownership question, stating Kensington
needed a sizeable deposit and deep pockets to obtain the cash
flow to stay in the game for 20 years. An independent operator
probably would not have the resources to time value the money on
the return for a project like Kensington.
SENATOR BISHOP directed the conversation to permitting, stating
the legislature leaned into staffing to some degree last year
and boosted DNR's permit personnel. There are a lot of fine
required permits, but mining progress stalls without sufficient
staff to execute them at DNR, ADF&G, and the Department of
Environmental Conservation (DEC).
SENATOR BISHOP brought up the Section 404 wetlands program. As
long as he has been at the Senate Finance Committee table, DNR
has received budget allocations towards state wetlands primacy.
Hopefully state wetlands primacy will happen someday. This
jurisdictional argument goes back to ANILCA. Alaska cannot do
anything about it, but Congress could hold the Army Corps of
Engineers' feet to the fire on the 1987 definition of wetlands
as well as its new 1994 interpretation. On the subject of
permitting impediments, supporters of renewable energy are
experiencing similar delays in permitting. The complaint is how
hard it is to execute projects due to an arduous permitting
system. Maybe the processing duration would speed up if the
country joined forces to re-examine its permitting process.
4:50:10 PM
CHAIR REVAK stated that today's presentation and discussion were
important. He expressed his belief that some of the hurdles and
hindrances have less to do with environmentalism and more to do
with stopping production. He hears and sees that the industry
goal is good stewardship of the environment. The question is
whether the goal is responsible development or halting
production. He warned that halting production is a dangerous
position to take with all that is going on in the world.
4:51:29 PM
There being no further business to come before the committee,
Chair Revak adjourned the Senate Resources Standing Committee
meeting at 4:51 p.m.
| Document Name | Date/Time | Subjects |
|---|---|---|
| Mining Industry Update to Senate Resources 2.28.2022.pdf |
SRES 2/28/2022 3:30:00 PM |