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Comment Collection - DEIR - CEA Foundation - March 2022

Read comments prepared by experts, volunteers, and legal minds from CEA Foundation and its MineWatch coalition members about the Draft Environmental Impact Report (DEIR) for the proposed reopening of the Idaho-Maryland Mine.

“This DEIR is riddled with errors, omissions, and legal flaws”, said Ralph Silberstein, President of CEA Foundation. “We’ll see many more impacts listed as significant and unavoidable before this is done." Read the press release.


CEA FOUNDATION & MIneWatch Coalition

MineWatch Coalition - Summary Letter 18 page subset of the CEA Foundation comment letter, signed by coalition members.

Download PDF • 4.43MB

CEA Foundation - Full Comments

Download PDF • 257KB


Center for Science in Public Participation (CSP) - by Dave Chambers

CSP2 Comments on Idaho-Maryland Draft EIR - 16Mar22
Download PDF • 479KB

Legal Comments from Shute, Mihaly & Weinberger

Download PDF • 54.59MB

Baseline Environmental Consulting Report Covers hazards, hydrology, air quality, and greenhouse gas emissions

Baseline Consulting Report
Download PDF • 3.29MB

Salter Report Noise

Salter Report Acoustical Review
Download PDF • 643KB

LOCAL Agency Comments

Read local agency comments, (City of Grass Valley, Nevada Irrigation District, Northern Sierra Air Quality Management District, Central Valley Regional Water Quality Control Board)

Files referenced with CEA FOUNDATION comments

Review of the Idaho-Maryland Mine DEIR Groundwater Model Examines the data and analysis used to create the model

Review of the Idaho-Maryland Mine DEIR Groundwater Model
Download PDF • 194KB

Review of the ITASCA Groundwater Model Identifies multiple assumptions that understate the extent of groundwater drop

Comments on Itasca GW Modeling Oberdorfer
Download PDF • 426KB

Mine Exhaust Moisture Provides facts about saturated air coming out of the mine and the potential cloud plume

Download PDF • 49KB

Faulting Hazards Identifies potential seismic hazards from mining activities adjacent to and through fault lines

Download PDF • 1.25MB

Health Risk Assessment Critique

Health Risk Assesment Critique
Download PDF • 120KB

Sampling Procedures Critique Identifies the very few samples used to characterize mine waste, etc.

Sampling Procedures
Download PDF • 80KB

Sample Quality Control Review Details the failure to process specific tests correctly, making much of the data unreliable

Sample QC Review
Download PDF • 153KB

ASUR Plan Analysis Examines the issues with the asbestos mitigations and the air quality hazard

ASUR Plan Analysis
Download PDF • 371KB


Wells Coalition

Download PDF • 181KB


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