★ Rise Gold Investors Beware: Idaho-Maryland Mine Unlikely Before 2034
Investors often think gold is a safer choice, but even if the stars align, it's unlikely Rise Gold could process their first ounce before 2034. Retired Capital Planner, Paul Schwartz walks us through the timeline and corresponding risks in detail.
This piece is also published in The Union.
Former U.S. Bankruptcy judge Randall J. Newsome believes it is unlikely the company will be able to follow through with reopening the mine.
Rise Gold CEO Ben Mossman's prior company polluted tribal waters, went bankrupt, and left Canadians with a bill to pay. Mossman is still facing criminal charges.
Community and Local Agencies find massive flaws in Draft Environmental Impact Report
Fourteen months ago, Nevada County Planning Department published the notice of preparation (July 17, 2020) that presented Rise Gold’s proposal to reopen the Idaho-Maryland Mine, including 100-plus technical reports prepared under the direction of Rise Gold. The project scope of work and technical reports were made available for review and comments from federal and state agencies, nonprofits, and the public.
Nevada County selected Raney Planning and Management to use the technical reports, the Rise Gold project description, and comments as a basis to complete the environmental impact report.
This year, Raney Planning and Management submitted a draft administrative environmental impact report for review by Nevada County Planning. Nevada County Planning and Raney Management and Planning directed Rise Gold and their cadre of consultants to update, complete additional data collection, and develop further analysis in many of the technical reports. We are still in the administrative draft phase.
If the county accepted the administrative report as complete, it would be retitled the draft environmental impact report and made available to federal and state agencies, Grass Valley and Nevada City, nonprofits, and the public for a 45-day review. Since the proposal is complex, it is likely the review period would be extended to 60 days.
This process could easily extend into 2022. The process will include public hearings before the Nevada County Planning Commission and the Board of Supervisors. Many agencies will make specific requests that will influence conditions of approval.
The Centennial cleanup proposal, also a Rise Gold project, is in the review and determinations phase at the Department of Toxic Substance Control and may influence the mine’s draft environmental impact report. If the department determined that the mine proposal and the Centennial cleanup proposal should have one environmental impact report that covers both projects, we would expect process delays.
There is the possibility the notice of preparation and environmental impact report process would need to start over with a new unified scope of work and set of technical reports. Raney Management and Planning would likely redefine their scope of work and enter new agreements with Nevada County. If this were to come to pass, project consideration by the Nevada County Planning Commission and the Board of Supervisors could slip into 2023 or even 2024.
The county supervisors circulated a request for proposal on Sept. 2 to complete an economic impact study of the proposed mining operations. The tentative deadline for submitting a proposal is Oct. 8. The draft economic study submittal date in the request for proposals is February 2022. I expect this is a loose date and may change.
The County's Economic Impact Report was released in November 2022.
The selected consultant would submit a draft report for the supervisors to review and comment. Likely, an additional 60-90 days would be needed to complete a final report.
The supervisors could wait for the economic impact study to act on the draft environmental impact report or not. Approval of the draft environmental report is not a project approval.
I would not expect the Board of Supervisors to begin the project-approval process before benefiting from a completed economic impact study and vetting the conclusions. The supervisors can approve the draft environmental report and reject the project.
At some point the Nevada County Planning Commission and Board of Supervisors will hold hearings to finalize the draft environmental report, and consultants will draft a final environmental impact report.
Public hearings will occur with Planning Commission and the Board of Supervisors to consider all public and agency comments received during the application process and finalize a decision on the environmental report.
If the supervisors approved the environmental impact report, the project would proceed to the entitlements phase and project approval. This phase would require Rise Gold to complete schematic level engineering and architectural designs at a sufficient level for county analysis.
Rise Gold would need to acquire the financial resources to fund technical and physical development of the project. Typically, the cost of design, engineering, capital planning and cost modeling is around 10% of the projected budget. If the estimated project cost is $100 million-$200 million, Rise Gold would need to raise $10 million to $20 million to keep the project rolling.
There is a long list of state and federal agencies that require their approvals to advance the project. The entitlements phase could easily become a lengthy process. The Loma Rica Ranch Housing Development Plan was originally approved in the 1980s and only this year has it begun grading the project. We could see the entitlements phase extend the approval process into 2025-26.
There are likely legal challenges and appeals that will follow any level of approval from the Board of Supervisors. If the Rise Gold proposal to reopen the Idaho-Maryland Mine survived legal challenges and the appeals, there would likely be new requirements, redesigns, new bench-marking, new standards for energy efficiency and carbon footprint reduction, and increased bonding requirements. These might require Rise Gold to increase their capital profile to restart the project. After 18 to 24 months in the courtroom, I expect most of 2028-29 would be needed to restart the project.
If Rise Gold were to navigate their way through the environmental review, Board of Supervisors approval, legal challenges and raise enough funding, the two projects would begin rough grading, construct the water treatment pond and the detention pond, construct the underground infrastructure required to support the industrial complex including conduits and pipe for electrical, potable water, waste, fire protection water, data, natural gas or propane, and storm water.
Residential properties relying on well water would need replacement water lines run, including a new water main on East Bennett Road. In addition, the new shaft would need to be constructed. While these improvements were underway, evaluation of the existing underground mine shafts and tunnels would need to occur.
There is the possibility that de-watering couldn’t be undertaken or completed until many improvements were made to prevent shaft collapse or sink holes throughout the system. There is also the possibility that Idaho-Maryland Mine tunnels connect with Empire Mine tunnels and de-watering would require those connections be shut off. This process would likely extend into 2030-31.
Final grading would happen to set the pads for new construction. Infrastructure and utilities would be raised to finished grade and extended where needed. Construction of new buildings would begin. Plans for improvements to the underground mine tunnels based on investigation would continue to advance.
A full water treatment facility would have to be constructed, and the treatment buildings, utilities, equipment, treatment pond, pumps and pipelines would need to be completed before de-watering could begin.
If all the permits were granted and all the prep work completed, de-watering could start as early as 2031-32. Then construction of a new access shaft would be completed and restoration of existing mine works could begin.
When the mine closed for 17 months during World War II, 80% of the Idaho-Maryland shafts were caved in, as reported in Jack Harvey’s history “Gold in Quartz.”
One can only imagine the scope of work needed for reopening after 65 years. All of the facilities and infrastructure for underground crushing, processing, transport and dumping would need to be in built and operational before removing any waste rock. Commissioning of all the systems above and below ground would be completed. The Centennial cleanup project would need to be completed before any waste rock could be relocated there.
Even if all the stars aligned, processing the first ounce of gold would probably not happen before 2034.
Paul S. Schwartz lives in Grass Valley.
Postscript: Paul shares this one additional thought. "Since we don't actually know the lag time between pulling the the first tons of crushed product (2034), shipping to a processing destination, separating gold from the crushed bulk, taking it to market, and then finally putting money in the bank, there is even more delay that could be added here. We don't know exactly what that is, but we bet it is slow."