★ Ralph Silberstein: DEIR and Rise Gold's Well Fantasies
CEA Foundation President, Ralph Silberstein weighs in on the DEIR, saying the issue is far from settled. "Looking into our crystal ball, we see a recirculation of the 'Speculative' Draft in the future in order to create a 'Realistic' Draft, consuming another year’s worth of delays."
Read the full opinion piece below, or read it in The Union.
The Idaho-Maryland Mine “Speculative” Draft EIR that has been released for public comment is a massive document based upon, well...clairvoyance? One might think so because the baseline, or “current conditions” of the Centennial site - described in the Draft Environmental Impact Report (Draft EIR) - is some future condition of the site after a required toxic mine waste cleanup project has been completed. However, no actual document describing the cleanup was included in the Draft. It turns out that the needed document, the “Remedial Action Plan” from the Department of Toxic Substances Control (DTSC), is not yet even finalized.
Meanwhile, well owners get a nice little letter from Rise Gold that repeatedly states things like “The County has determined that no domestic water wells will be drained by mine dewatering.” Of course, this also must be based upon a crystal ball session because a Final EIR has to be approved before any County determination can be made.
But after all of that, Rise still could not accurately claim that the County has determined anything about the mine project. This is because the County is not clairvoyant either and so can’t possibly know whether a well will or will not see a drop in water levels, not to mention the fact that the current Draft EIR recognizes that wells could be drained.
Regardless, the real issue is: can anyone can ever predict with any certainty what the impacts on wells will be? The short answer: No.
Even among experts, there are different predictions, and all of them are couched in disclaimers, assumptions, and phrases of uncertainty. And the unfortunate situation is that the only way to find out how much damage the dewatering of the mine would cause to wells and groundwater is to dewater the mine and wait for a few years. By then, the damage would be done.
For that reason alone the mine should not be approved. And if for some reason it is approved, there need to be protections for well owners. CEA Foundation estimates that more than 300 well owners should be protected. Rise’s own studies list 242 wells that will likely have some groundwater level decrease.
And back in 1996, when the Board of Supervisors granted a 5 year permit to just dewater the mine for exploration, all of the wells within a designated “Study Area” were to be provided with emergency water hookups within 24 hours. That was backed up with water service connections that were pre-designed, pre-permitted, NID approved, and financially assured. This involved over 100 wells. None of that is included in the Rise Gold project Draft EIR, a slap in the face of well owners.
This issue is far from settled, and the documents that supposedly make the case that the impacts to wells are known are surprisingly inadequate.
What is fascinating is that in spite of the thousands of pages and over a year of delays, Rise Gold didn’t even bother to gather critical data needed to strengthen its arguments about groundwater predictability, such as logging the amount of water flowing out of the mine or conducting well monitoring.
Instead they have relied upon sparse previous data from the Emgold Mining reports and word of mouth. Other omissions and errors point to a inadequate ground water assessment. Even the historical data examining mine water levels and seasonal variations were misinterpreted in the Draft EIR reports.
Looking into our crystal ball, we see a recirculation of the “Speculative” Draft in the future in order to create a “Realistic” Draft, consuming another year’s worth of delays.
Ralph Silberstein is a Grass Valley resident and President of the Community Environmental Advocates Foundation.