CEA NOP Comments to Nevada County Planner

By Community Environmental Advocates Foundation

August 17, 2020

The following scoping comments were submitted to the county in response to the Notice of Preparation (NOP) of the Draft Environmental Impact Report.


Matt Kelley, Senior Planner Nevada County

Planning Dept. 950 Maidu Ave

Nevada City, CA 95959-8617


Notice of Preparation Comments for the Idaho-Maryland Mine Project, Scoping

Dear Mr. Kelley,

Please accept these comments on behalf of CEA Foundation regarding the preparation of the Environmental Impact Report for the Idaho-Maryland Mine Permit Application.

Aesthetics An analysis of aesthetics’ impacts must be made. All visual impacts must be evaluated.

The project includes 122,000 sq. ft. of structures plainly visible from East Bennett Rd, Brunswick Rd., and from multiple surrounding rural residential neighborhoods. The proposed ore processing facility is 425 feet by 70 feet, and 65 feet high. Construction of “engineered fill” pads on both sites will create the continuous presence of operations that are synonymous to a gravel quarry, involving continuous haul trucks, graders, and compactors working on an ever increasing build up area of engineered fill.

These operations will continue for about 11 years, and ultimately result in a highly visible fill area covering 44 acres at the Centennial site with heights up to 70 feet, and a similar fill area covering 31 acres on the Brunswick site with heights of up to 90 feet. Following that, approximately 70 years of operations will entail trucking mine waste to Hwy 49 via Brunswick Rd.

The removal of woodlands and open space will starkly degrade the aesthetic nature of the area, impacting its rural residential character and diminishing property values. Increased traffic will affect the quality of life.

Noise and dust and other impacts must be evaluated on their aesthetic impacts. The project is in the City of Grass Valley Sphere of Influence.

2. The aesthetic impact must be evaluated with respect to the Grass Valley Development Code and the General Plan.

Over the last few decades the areas surrounding the Idaho Maryland Mine have become predominantly residential.

3. The EIR must evaluate how the reopening of the mine would change the character and trajectory of development in this section of Nevada County.

Agriculture and Forestry The areas of lower conifer and oak woodlands which will remain outside the direct physical constructs of the project sites will be impacted by light, air pollution, noise, temperature changes, and other impacts.

A Forest Restoration and Management Plan should be required to prevent further degradation of these woodlands and to preserve and enhance the native habitat. Ongoing biological monitoring should be conducted in these areas throughout the life of the project. Air Quality As evidenced at the Empire Mine State Park, mining and milling operations at the mine left behind a mixture of naturally occurring contaminants (arsenic, lead, cadmium, and other metals) and introduced cyanide and mercury (used in the gold extraction process). Operations produced ore rock and generated tailings and waste rock. Contamination produced by these operations was determined to pose a health hazard to people, wildlife, and area waterways.

Arsenic has been classified as a carcinogen and causes other severe health issues, including thickening skin, pain, nausea, paralysis, and blindness. A legacy of gold mining at Empire Mine and elsewhere is the contamination of mine wastes and associated soils, surface waters, and groundwaters with arsenic (As), mercury (Hg), lead (Pb), and other metals.

Disturbance of materials containing mafic and ultramafic rocks is regulated by the California Air Resources Board (CARB) and the Northern Sierra Air Quality Management District (NSAQMD).

The presence of naturally occurring contaminants (arsenic, lead, cadmium, and other metals) which are released into the air and soil when the mine rock is crushed should be independently investigated and included in the EIR and clearly explained for the public to review. Impacts to the public as well as employees of the mine should be included in the discussion. Fugitive dust from surface operations will affect air quality. Dust and air pollutants from all sources must be contained.

3. The EIR should analyze all sources of air pollutants.

4. It should specify how these sources of air pollutants will be contained and controlled. These include but are not limited to dust and emissions from truck transport, chemical emissions, equipment emissions and exhaust, odors, emissions from all mining activities on the surface and within the processing facilities and mine tunnels.

Wind, dry conditions, and other circumstances may require cessation of mining operations and surface activities.

5. The EIR must identify and set criteria for managing these conditions.

6. Air quality impacts from all aspects of construction and operations and from the production and transport of materials and equipment produced off site must be evaluated.

7. Air quality impacts from the processing of ore and mining by-products offsite must be evaluated.

8. Emissions due to the other supplemental activities including but not limited to relocation of non- residents for employment, transportation, traffic impacts, construction and operation of utilities and utility services must be evaluated.

9. The effect on air quality of extended activities such as reclamation activities and water treatment operations, must be assessed for their entire lifespan, beyond 80 years.

10. Rise Gold must show how the cumulative effect of small drips and spills during transfer and fueling activities will be prevented from entering into the environment (as happens at gas stations), and contaminating Wolf Creek.

11. All of the above mentioned conditions should be assessed in terms of the range of predicted changes in weather patterns due to global warming.

Biological Resources The project has potentially significant impacts on biological resources. The majority of the 175 acres being utilized will be disrupted due to construction, grading, engineered fill, and other actions, followed by prolonged ongoing operations, eliminating forested habitat and impacting riparian zones. Noise, air pollution, temperature changes, traffic, light spillage and other impacts will affect wildlife far beyond the project boundaries.

Short term and long term impacts on biological resourced must be assessed. Baselines of flora and fauna on both sites and in surrounding areas must be established. In particular, biological impacts in the riparian zone of South Fork Wolf Creek downstream must be established due to significant changes in flow, seasonality impacts, temperature, pH, dissolved solids, and other water quality criteria relevant to aquatic life. For example, what will be the effect of removing 18 acres of forest habitat? What effect will the constant noise, traffic, nighttime lighting, and depositing of engineered fill have on the wildlife that inhabit the area around the mine site? Will there be an increase in animal-vehicle accidents? What effect will the mine have on seeps and natural springs used as a water source. Will wildlife be forced into neighboring residential areas, creating hazards?

4. Wetlands on both sites must be delineated and project impacts on wildlife assessed.

5. Perennial and seasonal seeps, springs, and creeks must be delineated and project impacts on wildlife assessed.

6. The spring fed pond designated as “clay-lined pond” on the Brunswick site and the marsh and meadow lands below that pond must be evaluated for impacts to the aquatic and avian species.

The South Fork Wolf Creek is a perennial stream that originates on the East side of Brunswick Rd. It is incorrectly classified in the current project descriptions.

7. The riparian habitat along this stream in the reach to the West of Brunswick Rd before it flows into a grated culvert on the Brunswick site must be evaluated.

8. The culverted portion of the stream should be daylighted across the project and afforded 100’ setback protections.9. The EIR also must include reviews and approvals from CA Dept of Fish and Wildlife, US Fish and Wildlife Service, the Regional Water Quality Control Board, California State Parks (Regarding impacts to Empire Mine State Park Restoration Areas downstream on South Fork Wolf Creek ), and other oversight agencies.

Tribal Cultural Resources The mine project sites are both located in areas that were probably inhabited by native Nisenan people prior to the arrival of miners and settlers. Despite the fact that the sites are extremely impacted by mining and other activities, it is highly likely that there are undisturbed soils that have remained in place under the overburden of tailings, waste rock, pavement, and fill. These may contain tribal cultural resources from generations of occupancy.

An archeological analysis of the area must be conducted in order to determine the degree to which this is a cultural heritage site of the Nisenan people. Careful monitoring of construction and mining related activities must be conducted, especially when excavating native soils. Geology Soils and Mineral Resources The project includes dumping of waste rock and tailings into two major, engineered fill pads. Landfills settle as buried materials realign, decompose, and are transported by surface and subsurface flows. Cover integrity is compromised by vegetation, burrowing animals, and depressions that allow surface pooling, etc.

The impacts of these must be evaluated. Monitoring of the integrity of the landfill cover must be established. Funding for routine maintenance must be explained. Approval for the landfill at the Centennial M-1 site requires that Nevada County allow entitlements for development in a Seismic Hazard Zone, and along an Earthquake Fault line. In addition, construction in areas with slopes that exceed 30%, and are comprised of highly erodible soils, is in planning.

4. A full analysis of how the landfill will be designed to prevent seismically induced slope failure must be made.

The applicant has asked for waivers on multiple entitlements.

5. The EIR must respond to each of these waivers and explain on what grounds these waivers will be granted.

6. The EIR must contain options other than these waivers. For example, a reduced slope, or a reduced size of the mine waste piles must be considered. Elimination of onsite dumping must also be considered.

Energy What happens when there is a power outage?

All aspects of operations during a power outage and a power restart must be assessed in terms of emergency power capacity, safety, emergency services, impact on the environment and other impacts. An assessment of these energy impact conditions should be done for short term and long term scenarios. An analysis of how the proposed energy use of the mine impacts the Nevada County Energy Action Plan. The EIR must assess the availability of gas and electric utilities and other utility providers, and their capacity to serve the project. Greenhouse Gas Emissions (GHG)

Due to global warming and the 80 year scope of the proposed project, the full range of predicted changes in weather patterns and precipitation must be considered in estimating the surface water runoff and storm water management systems, as well as water usage and shortages, fire risks, temperature impacts on water resources and habitat, and all other impacts from climate change.

The following analyses must be included in the EIR with respect to GHG impacts:

Air quality and GHG emissions from transportation of materials and equipment. Embedded energy costs, costs due to the production of materials and equipment. All project related activities of employees, non-resident and resident. Emissions due to the relocation of non-residents into the area to fill jobs Impacts from traffic due to mining operations. Activities following closure (beyond 80 years) should be assessed, including but not limited to:

6. Emissions from continuing operation of water treatment facilities following mine closure

7. Maintenance and testing of stockpiled materials, monitoring wells, reclamation, etc.

All initial and ongoing supplemental activities should be assessed in terms of energy costs and GHG emissions such as:

8. The provision of new water lines, additional energy costs of water transport, road improvements off site.

9. Emissions from reclamation

10. Emissions of GHG gases other than CO2

11. Cumulative impacts must be considered in all GHG sources.

12. California targets for GHG emissions reductions for 2030 and 2050 must be addressed with viable solutions for meeting reductions

13. Project alternatives in scale, scope, and configuration must be considered as options for addressing GHG emissions over the course of the project lifespan.

Hazards and Hazardous Materials The EIR must fully evaluate the potential impacts of accidental release or harm from transport, storage, and utilization of explosives and other hazardous materials. Provisions for general employee health and safety must be considered in all work environments. In particular, risk to health, safety, and lifespan due to mining hazards must be assessed, including the effects of long term exposures, chemicals, fugitive dust, exhaust and other health risks. Wildfire impacts must be assessed. The EIR must evaluate the wildfire risks of facilities and materials, such as fuel storage tanks and chemicals, and how they will be kept from contributing to the existing fire danger at this location. Wildfire evacuation issues must be addressed, as well as emergency response. Safety issues with haul trucks and other mine related traffic must be assessed. Earthquake hazards must be analyzed. Potential hazards from subsidence or collapse of mining tunnels over the 2585 acres of mineral rights must be addressed. Hydrology and Water Quality The Geotechnical Report prepared by NV5, submitted by the applicant states that: Index testing of the near-surface soils were performed as part of our soil evaluation in an effort to evaluate corrosion potential. The measured minimum resistivity values indicate that the on-site soil conditions exhibit a “moderate“ risk for corrosion of ferrous metals in contact with the soil or rock. The presence of high acidity, pH of 5.5 or less, in the soil samples is considered corrosive to concrete. Soil with a pH of 5.5 or less can react with the lime in concrete to form soluble reaction products that can easily leach out of the concrete. The result is a more porous, weaker concrete.

All soils issues must be investigated as part of the EIR and clearly explained to the public. California Health and Safety Code Division 20, Section 6.5 defines disposal as:

The abandonment of any waste which may be emitted into the air or discharged into or on any land or waters including groundwaters, or may otherwise enter into the environment creates a disposal site at the mining site. Using sand generated from blasting to refill the tunnels left from previous mining may contaminate groundwater and should be investigated and included in the EIR. Waste rock and tailings that are deposited below the surface in any form (e.g. cemented slurry, crushed rock, etc.) must be investigated and included in the EIR. Underground refilling of past mining tunnels should include continuous quality assurance inspections during placement of backfill, testing of mineral composition to verify conformance with pH ranges deemed acceptable.

The flooded Idaho-Maryland Mine must be dewatered and then a maintenance level of water discharge must be maintained. The initial dewatering will require discharge of 2500 acre-feet of mine water. After about 6 months of operation, the discharge rate will drop to about 1.9 cfs. continuing throughout the lifespan of the 80 year project and beyond that indefinitely. All of this water must be treated to remove contaminants.

The project proposes a treatment facility and a holding pond.

2. The measures that Rise Gold is taking to ensure that the treatment facility will remain fully functional in various probable failure scenarios must be stated.

3. There must be sufficient built-in safeguards and redundancy to protect the environment in the event of failures to the treatment system which must be fully explained

There have been prolonged power outages due to PGE Red alerts, etc. We have had power outages that last over a week in this area.

4. There must be sufficient redundant back-up generation in place to ensure that the water treatment remains fully operational, and these must be completely documented in the EIR

5. An explanation of how the precipitants in the holding pond are being managed must be provided

6. What happens to the outflow and water purification during the times when the pond is being cleaned must be explained.

7. Explaining whether or not there will be a bypass pond available during times when the main pond is not operational due to cleaning, etc, must be noted

8. What will happen to the residue from the pond must be noted

9. What is the estimated frequency for pond cleaning must be noted

10. Full life cycle management of the treatment operation with appropriate safeguards must be evaluated in the EIR

11. The EIR must address the need for the treatment facility to operate in perpetuity

12. Will there be a perpetual fund and management system set up for maintaining water quality from the water treatment facility indefinitely? This must be well defined.

Extreme weather changes and capacity must be addressed.

13. A detailed explanation of the plans to respond to extreme weather events such that the pond and water treatment facility will remain fully operational must be note

14. As the mine develops, the rate of discharge may drastically change. How will this be accommodated?

Filtration media upkeep must be addressed

15. What will be done with the backwash fluids from regeneration of the filtration media? This must be explained

16. What are the service life projections for the media? This must be explained.

Iron fouling was the reason for elimination of ion exchange as a treatment option. Fouling as a result of iron and manganese oxidation can be an issue with filter media as well17

17. How operations progress should plugging of media by oxidized Fe and Mn occur must be explained

18. The contingency plan for if and when the plugging occurs must be documented

The proposed Idaho-Maryland Mine has significant potential impact on private and public wells. Even with assumptions, predictions and models, it is not possible to know how the geological system will respond to dewatering and from ground water consumption. The EIR must address the potential impacts and concerns.

The means of providing the following aspects of well monitoring must be thoroughly documented in the EIR

19. Provide well monitoring to private wells, within and beyond the boundaries of the mine’s mineral rights area

20. Monitoring data must be collected that is current, to establish reliable current baseline conditions, prior to the start of initial dewatering. The well monitoring data from the 2007 Todd report is 13 years old, prior to the drought

21. Monitoring data must include water quality in the data collection, to establish a quality baseline prior to dewatering

22. The monitoring program must begin well in advance of initial dewatering, to establish a reliable baseline

23. There must be an analysis for past drought and possible future drought scenarios and their effect on groundwater and wells for the life of the project, including post-project reclamation and maintenance

24. There must be an analysis on impacts to wells when the applicant expands and opens up new areas of exploration/mining within its mineral rights boundary

Well Mitigations

25. What are the mitigation measures for impacted wells outside the assumed area of impact? These must be included in the EIR.

26. How will the applicant guarantee a permanent potable water supply to any well that is impacted by the project, in areas where no NID service is available? This guarantee must be thoroughly documented in the EIR.

Well Impact Determinations, Definitions & Timelines 27. A criteria must be established before the project begins, as to what defines and determines an “impacted well”. This must be included in the EIR.

28. There needs to be a well mitigation action plan spelled out, in the event of any well being impacted, including a timeline. This must be included in the EIR.

The applicant shall not have to bear the burden of proof to show the cause of negative impacts on an impacted well. Depletion of ground water and/or pollution of ground water as a result of the mining operations can take place at any time during the 80 years of operation and, due to the nature of ground water movement and recharge, may not be evidenced for many years beyond the end of mining operations.

29. How will well owners and future well owners be identified and compensated for losses due to impacts from the mine over this time period? The EIR must include an adequate independent assurance mechanism to identify impacted well owners.

Wells, Community Relations

30. A community relations program must be established that provides a direct line of communication between Rise, Nevada County, NID, Grass Valley and the well owners, with specific contacts. This is a complex project and all parties need to have access to information and be able to report. The EIR must include such a program.

Wells, Financial Considerations

31. The EIR must assure that the full costs to each homeowner of all expenses related to the damage to or loss of well quality or capacity shall be borne by the project. This would include but is not limited to restoring homeowners property which may be damaged, the installation and monthly fees of any water service provider, costs due to loss of value of property.

Net Impact on Ground Water and Stream Flows 32. The EIR must analyze the net impacts on ground water, ground water recharge, stream flows and surface flows due to ground water consumption (123,000 gal/day est), initial dewatering and de-watered maintainance flows, evaporation, impervious surfaces, and other potential impacts to the water resources at both sites.

Land Use, Planning, Population, and Housing Some of the area on the Brunswick site in the proposed zoning change is not in the mining resource zone. the EIR must explain how this is being addressed? The Centennial property is in the near term annexation horizon, and the Brunswick property is in the long term annexation horizon, for the City of Grass Valley

2. The City’s plans and goals must be considered in the EIR. Some of these which must be addressed are: The re-alignment of Centennial Drive and Spring Hill Drive into a single intersection

The Wolf Creek trail along Wolf Creek at the Centennial site The City goal of residential infill

Pre-zoning at Brunswick site and proximity to residential Pre-zoning at Centennial

The project documents list the 56 acre Centennial site as “Industrial” based on the Nevada County zoning classification. The City of Grass Valley has the parcels pre-zoned as Business Park (BP) and Urban Medium Density (UMD), and these parcels are in the City’s Near Term Annexation Horizon. LAFCo lists the properties as BP and UMD also. ( LAFCo document https://www.mynevadacounty.com/DocumentCenter/View/14241/Grass-Valley-Sphere-Plan-Update- April-2011-PDF , Grass Valley General Plan map, page 55)

3. The EIR must take the City of GV designation into consideration in reviewing the zoning for the project, and explain the mine’s impact on the designation Note that Nevada County General Plan, Land Use Chapter, Section 1.8 recognizes the City’s planning designations, and that standards used to govern the clean-up activities on that site must comply with the City’s zoning

4. The EIR must provide justification for the proposed zoning change to M1 rather than M2 for an industrial mining operation.

Nevada County is suffering from a housing shortage. However, the costs of construction have continued to increase, suppressing the construction of new housing due to limited profitability. Realtors in the area of the project have indicated that the market value of housing is being reduced due to the prospect of the Idaho-Maryland Mine re-opening. This will further exacerbate the housing shortage

5. An economic study must be conducted to determine the impact on housing.

Noise Noise and vibrations from equipment used in transport, dumping, grading, compacting, mixing, and otherwise processing, handling and managing the processing of ore and the disposal of mine products such as waste rock and tailings as engineered fill must be fully assessed in the EIR for noise impacts. Traffic noise must be evaluated in the EIR Given issues to date, continuous long term noise will have significant impact, and mine design should meet standards as per Nevada County General Plan Noise Element, Policy 9.1.2. E. 1. a., b., and c. The EIR must clearly state such compliance with the standards. The health effects of long term lower level noise shall be fully addressed in the EIR Operational hours, changes in operations, and other mitigations should be considered as options for reducing noise impacts. The EIR must clearly provide for these mitigations. The Brunswick Site and the Centennial Site are currently zoned Light Industrial M1-SP. The Brunswick Site is surrounded on all sides by rural residential property. Rise Gold is asking for a zoning change to permit mining operations on the Brunswick site. However when two different zonings abut, the maximum allowable sound level is the lower of the two zonings plus 5 dB. Therefore, while changing the zoning of the parcel may allow mining activities to proceed, it will not allow an increase in the noise levels permitted.

Rise Gold mining Operations involve underground blasting, moving 1000 tons of ore daily to the storage silo on the surface, transporting that ore from the silo to the crusher, separating mineralized ore from tailings, trucking concentrated mineralized ore to an outside processing facility, trucking tailings to a disposal site and grading and compacting those tailings to create a building pad for future industrial use. These operations are among the noisiest industrial operations that exist.

The EIR should address the following

6. Rise gold’s claims that blasting will be unnoticeable on the surface due to the depth of these activities, is based on calculations of a blast at 500 feet of depth. Rise Gold must address the possibility that further exploration will reveal mineralization at shallower depths or in different acoustic environments and explain how it will mitigate noise and vibration during the entire 80 years of the project

7. 1000 tons a day of ore will be raised to the surface and stored in the concrete silo on the Brunswick site. This ore will be dumped from the headframe lift onto a steel ramp in the silo 24 hours a day, 365 days a year. Rise Gold must address how it will mitigate all related noise from these operations, particularly during the night hours when permitted noise levels are limited to 50 dBA with 65 dBA peaks

8. Rise Gold proposes to contain the transport of ore from the silo to the crusher, the crushing operation, the separating and concentrating operations and the truck loading operations in a massive, sound attenuating building. Detailed architectural and engineering plans, including the machinery to be in place and the means of monitoring compliance with established limits must be provided. Rise Gold’s report must consider different possible scenarios, such as one where, in spite of time and money spent on best efforts, Rise Gold is unable to mitigate noise to the required levels, or one where, a change of equipment in the structure produces an increased outside sound level

9. Rise Gold proposes to conduct mine wasted disposal operations at both the Centennial site and the Brunswick site, where it will dump, grade and compact 1000 tons a day of waste rock and tailings into building pads for future industrial use. Rise Gold must detail how it plans to mitigate the noise of these operations from impacting business and residential properties at both disposal site

10. Transporting 1000 tons of tailings daily by heavy truck on city streets will increase traffic noise levels through residential neighborhoods as well as traffic noise and volume throughout the Brunswick Road neighborhood for the next 80 years, as the haul route for tailings will be down Brunswick to HWY 49 after the Centennial project and Brunswick disposal site are completed. Details of the impact of both sound and traffic volume on the greater Brunswick neighborhood, including the Brunswick/HWY 49 intersection must be studied

11. Complete analysis of baseline ambient noise at all potentially impacted adjoining properties shall be conducted prior to the start of activities

12. The study must include how, and with what frequency, compliance with established sound and vibration levels will be monitored

13. The study must include the procedure for reporting non-compliance with established sound and vibration level

14. The study must include how compliance with established sound and vibration levels will be enforced

15. Although acoustic containment of sounds generated by the transport and milling operations may be successfully accomplished, low frequency ground vibrations and rumblings transmitted through the ground from those operations will impact the adjoining residential properties 24 hours a day, seven days a week. Analysis of the ambient levels and future levels of this vibration must be made. The study must include how future compliance with applicable standards will be established.

16. Ground vibration transmitted to adjacent residential properties from truckload dumping, grading and compacting has not been addressed. The study must include how future compliance with applicable standards will be established

17. Underground activities such as drilling, blasting equipment operations, conveying of materials, and back-filling can take place in any location within the mineral rights of the project applicant. These may be directly under residences and businesses and closer to the surface than suggested, taking place up to the legal distance below grade. Potential noise and vibration impacts from these activities must be fully analyzed in the EIR. Variations in rock strata and other variations such as mine adits producing transmission pathways must be considered

18. Rise Gold must provide a study of the cumulative impacts.

Public Services Utilities and Service Systems Law enforcement and public services impacts must be considered.

Fire equipment and personnel, and additional training must be assessed. Addition impacts on regulatory oversight such as inspections and issue responses must be assessed. Mine rescue teams and training will be needed. The EIR must explain in detail whether or not independent inspectors routinely review the mining operations to insure conformance with all requirements and mandated practices, e.g. OSHA and mining related regulators Levels of water usage and the ability of NID to provide water services to the mine and mining operations should be assessed. Levels of water usage and the ability of NID to provide water services to property owners who may be requiring service due to loss of use of private wells must be determined and documented. Transportation & Traffic Independently verified traffic analysis must be provided in the EIR, and should include trucking of all waste rock off site when the onsite engineered fill is halted. The following analyses must be recorded in the EIR: Truck traffic on Brunswick road etc. Unsafe intersections

Air pollution

Need to include traffic from employees and from cement trucks, etc. Centennial Drive construction

Wear and tear on roads and associated maintenance and repair costs

Rise Gold projects that up to 1000 tons a day of crushed rock will be loaded into large haul trucks at the Brunswick site and transported to the Centennial site, to elsewhere on the Brunswick site, and later, to unknown destinations. This will be between an average of 50 to 100 truckloads a day, 7 days a week, from 6:00 AM to 10:00 PM for 80 years. There will be one heavy truck leaving every 10 to 12 minutes, all day, every day, and one empty truck returning every 10 to 12 minutes, all day, every day. For 80 years.

This will put considerable impact on the road surfaces along the haul routes, and will require a large increase in road maintenance along those routes

2. Rise Gold must show in the EIR who will pay for the increased workload on maintenance crews

3. Rise Gold must show in the EIR how it will ensure that such maintenance will be done in a timely manner, such that the quality of the neighborhoods through which the routes pass is not degraded

4. Rise Gold must prepare a study of the impact on traffic of the disruptions caused by this necessary maintenance

5. Rise Gold must prepare a study of the increased danger of these heavily loaded trucks traveling on steep hill slopes in winter weather conditions

6. In addition to the haul truck traffic, Rise Gold will employ more than 300 personnel in two shifts daily on the Brunswick site. Half that number will be arriving and the other half leaving at 7:00 AM and 7:00 PM. The EIR must show how this this commute surge will impact the local community who also commute from their residences to work and back

7. Rise Gold projects an unknown number of truck trips to the Brunswick site to transport fuel oil, diesel fuel, explosives, concrete and other supplies. Rise Gold must prepare a study of what this volume of additional traffic, over and above the haul trucks and the employee commute generates

8. Residents living along Greenhorn have only one way in and out. Rise Gold must prepare a study showing how the increased traffic from this project at the Brunswick and Greenhorn intersection will affect the ability of Greenhorn residents to travel freely to and from their homes?

Rise Gold Mine Project EIR and DTSC Centennial Cleanup The EIR must evaluate current conditions on the 56 acre “Centennial” site with respect to all impacts from the legacy tailings arising from the former Idaho-Maryland Mine operations and other prior activities. It is not sufficient to state that another agency will perform this task. As reported in a June 12, 2020 Preliminary Endangerment Assessment accepted by the DTSC, approximately 270,000 cubic yards of legacy tailings and mining residue are on the surface of this site with various levels of contamination. Current impacts to groundwater, surface water, seasonal runoff, air quality, surface contamination, and potential impacts from the legacy activities must be evaluated in the EIR, and a plan of action for remediating these must be provided. It is stated in the Project Description, pg 16, that some of the imported tailings and waste rock will be mixed with the legacy mine waste to achieve the physical characteristics suitable for engineered fill

3. Integration of these legacy tailings with the new imported mine waste and tailings must be evaluated in the EIR in terms of the chemical composition and contamination levels of both sources as well as their suitability in engineered fill

4. Phasing of the project must ensure that the complete remediation of the legacy tailings is completed and the Centennial site undergoes reclamation before the mining operations can begin. Documentation to this effect must be provided in the EIR. Otherwise, there is a high level of interdependence between the proposed mine operations and the Centennial site contamination cleanup project being managed by the DTSC. Any proposed phasing of operations would depend upon fulfilling multiple project conditions which are not predictable

5. The EIR must safeguard the environment by addressing all foreseeable scenarios to assess impacts from the mine project, their impact on the cleanup project, and the reclamation activities that will take place in each scenario. A few examples of these many scenarios which must be addressed include delays in the cleanup project, failure of the mine project to produce adequate materials, early closure of the mine, contamination levels in the mine waste that are unacceptable, financial insolvency before the cleanup is complete, and so forth.

Reclamation The Department of Conservation review and comment letter, dated August 11, 2020, for the Notice of Preparation of this project indicates that the Reclamation Plan is incomplete: “Division staff will provide comments on the Reclamation Plan for this proposed mining activity once the Division receives the complete Reclamation Plan and any supporting documents along with the statement from the County that certifies the submission as complete and in accordance with PRC Section 2772.1(a)(3)(A-C).”

A Reclamation Plan is a “project” under CEQA and must be included and reviewed in the EIR, and must include the “phased reclamation” of the proposed slopes of the mine waste. Because of the inter dependencies, reclamation plans must be developed for each scenario regarding the state of the DTSC Centennial cleanup project and the state of the Idaho-Maryland Mine project, and must be included in the EIR Economic Impacts The economic impacts of the project are significant and must be analyzed. The Centennial site lies within the near term annexation horizon area of Grass Valley and is surrounded by local businesses. The southern portion abuts areas designated as Medium Density Housing. The Brunswick site is surrounded by quiet rural residential neighborhoods and is in the long term annexation horizon for Grass Valley. Both sites are effectively “in Grass Valley”. Given the significant impact that one would expect from a project of this magnitude, there has been a wave of concern about the economic and aesthetic impacts that will result from this mine opening.

The region is faced with the prospect of the serene rural residential area around the Brunswick site having a large ore processing facility and extensive gravel operations plopped down in its center. Already there are reports of residential real estate values dropping just on the potential that this project might be approved. Several residents in the area have already indicated they will sell their homes and move out.

Some of the many economic impacts of concern that should be considered:

The negative impacts on the Real Estate Industry must be determined and recorded in the EIR the impacts to adjacent businesses and possible closures of high tech companies must be determined and recorded in the EIR. The negative impacts on local businesses’ ability to attract and recruit new employees, especially in the high tech industries that predominate the area, must be determined and recorded in the EIR The heavy truck traffic and mine employee traffic along Brunswick Rd and into the Glenbrook Basin and the financial burden to the City of Grass Valley’s and Nevada County’s infrastructure must be determined and recorded in the EIR. Local air pollution will be exacerbated by the mine, impacting the health of residents. The potential health costs of this increased air pollution must be determined and recorded in the EIR. There are an estimated 300 wells that are in the mineral resource property of the mine. There exits a potential loss of well function due to impacts on ground water from mine operation. The cost of compensation for the potential loss of wells must be determined and recorded in the EIR. Tax revenue changes due to property value decrease and loss of business must be determined and recorded in the EIR. Due to the high risk of mining operations, the impacts of lower than estimated mine production level and/or early mine closure must be assessed, and its financial impact on the City of Grass Valley and Nevada County must be determined and recorded in the EIR. The financial strength of reclamation bonds and reclamation activities must be evaluated and recorded in the EIR. //end//

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