How To Write DEIR Comments


Authored by CEA Foundation


Now Is the Time: Let the County Know What YOU Think About the Mine and the Draft Environmental Impact Report (DEIR)

DEADLINE: Comment letters are due to Nevada County by April 4, 2022

In May of 2020, the Nevada County Board of Supervisors voted 5-0 to authorize the preparation of a Draft Environmental Impact Report (DEIR) to study the risks associated with re-opening the Idaho Maryland Mine – a project led by Canadian Company, RISE Gold. That July, the County published a Notice of Preparation (NOP) outlining what will be studied in that DEIR and the community provided comments and feedback on what the analysis in the DEIR should include. The DEIR is now and out and it’s time for the public to make comments on what it contains. Our comments are due by April 4th, but you should know that we are working to get an extension.

Make sure your voice is heard. Here’s how: • Identify your own areas of concern (eg; impacts to air, wells, traffic, noise…) • Consider reviewing the Project Summary, Executive Summary and Table of Impacts and Mitigations (hyperlinks provided at the end of this sheet). • Then go to the specific chapter on your impact of concern and read it thoroughly. • Write a comment letter. • Send your letter to the Nevada County Planner, Matt Kelley, no later than April 4th. Why should I send a comment letter to Nevada County about the Mine? This project has many potentially significant environmental impacts that are listed in the DEIR. It’s up to concerned citizens like you to tell the County’s staff and consultants what you are most concerned about. They must respond to each comment letter. What points should I make in my letter? Focus your letter on what concerns you the most. Some people focus on the environmental impacts of the mine on the land, water and wildlife. Others are very concerned about air pollution, traffic impacts and neighborhood safety. Some want to see what impacts there might be to climate change. You want to make your specific requests and questions clear, for example “I’m concerned how this proposal impacts wells in the area. The FEIR needs to analyze all the wells potentially impacted by the project. The impact analysis on wells in the DEIR is ….(choose any of the following language: missing, invalid, inadequate, underestimates impacts, proposes inadequate mitigation measures). Some tips for writing an effective comment letter:

  • If you have special expertise or education on the issue you are discussing, note that. A related job or volunteer experience, special understanding of local conditions, years lived in the area, or if you live close to the mine; all give you special expertise, so note any of these.

  • Focus your requests on what you want analyzed and what environmental impacts you want considered or considered in greater detail. Explain the WHY for each of your conclusions. If you think the impacts proposed will not mitigate impacts explain WHY. If you think the project impacts in your subject area simply cannot be mitigated to an acceptable level, explain WHY.

  • Be specific on impacts and mitigations.

Example of a good comment:The discussion of water quality impacts related to loss of wetland vegetation on DEIR page 5-7 is inadequate because potential loss of cover vegetation due to road widening required near the creek is not discussed. Mitigation should include a 100 foot centerline of creek setback from the road construction zone.” (Notice: Includes citation, very specific impact noted, solution recommended.) Less specific comment not as effective:The DEIR is completely inadequate because it does not adequately discuss impacts to water quality. The project should be decreased in size.” Make sure that your specific requests are clear, concise and singular (bullet points are fine).

  • Including your opinion on the mine, is valid and OK but is not a factor for staff in developing the Final EIR – so make sure that your personal opinions don’t distract from your clear, concise requests to the County.

  • Include your name and contact information in case the County needs to contact you to clarify a point.

  • DEIR comments are divided into various categories. Reviewing these categories may help spark your thinking and may help organize your comments. The comment categories are:

Aesthetics Agriculture and Forestry Air Quality Terrestrial and Aquatic Biological Resources Cultural Resources Tribal Cultural Resources Geology / Soils Greenhouse Gas Emissions Hazards & Hazardous Materials Hydrology / Water Quality Land Use / Planning Mineral Resources Noise Population / Housing Public Services Recreation Transportation and Traffic Utilities and Service Systems Economic Study* Water Supply Analysis**


*An economic study is not required under CEQA, however the County has commissioned a Study.

**A Water Supply Analysis is included in the Appendices of the DEIR

Where do I send my letter?

Send your letter (email or regular mail) to Nevada County by April 4, 2022 at 5pm to:

Mr. Matt Kelley

Senior Planner

Nevada County Planning Department

950 Maidu Avenue, Suite 170

Nevada City, CA 95959-7902 (530) 265-1423

Via email:Idaho.MMEIR@co.nevada.ca.us


Do you have a sample letter I can use as a template?

It’s always best to use your own words. You can start with your personal experience like how long you’ve lived in the area, and briefly share your connection to the project. Most important: Be specific about your key concerns and questions about the project.

Please help us track the impact we are having – send a copy of your letter to: DEIRcomments@cea-nc.org


This information sheet is available online at: https://www.minewatchnc.org/post/how-to-write-deir-comments


Want to learn more about key topics and impacts?

Visit www.MineWatchNC.org


A copy of the DEIR is available at the Nevada County Library and on the County’s project website. Visit Idaho-Maryland Mine Draft EIR | Nevada County, CA (mynevadacounty.com)


Draft EIR in Chapters:

Idaho-Maryland Mine Draft EIR | Nevada County, CA (mynevadacounty.com)


The Executive Summary and Table of Impacts and Mitigation Measures:

2_Executive-Summary (mynevadacounty.com)

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