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Did you know that large noisy gravel hauling trucks will run an average of 100 trips (one way) per day, and up to 200 trips? Running 16 hours per day, 7 days per week, that means a truck will pass by every 9.6 minutes, and as often as every 4.8 minutes. Added to that would be numerous other daily cement and materials trucks.

Dear MineWatchers, MineWatch held a virtual community film-screening about the re-opening of the Idaho Maryland Mine and a panel discussion on Thursday, February 25th at 6:00 pm. See the recording here. Rise Beyond Gold tells the story about a proposal to re-open the Idaho Maryland Mine in Nevada County, CA. The community faces a junior mining company with questionable experience that wants to take the gold from under their property and leave a toxic legacy behind. Rise Beyond Gold also raises more critical questions for the world at large. Why do we desire gold, and ultimately, is it worth it? The movie, created by Catalyst Communications, premiered at the flagship Wild & Scenic Film Festival in January of 2021. Join MineWatchers for a special Zoom screening of Rise Beyond Gold (13-minutes) followed by a panel discussion afterward. The Panel: -Greg Thrush, Sierra Fund will moderate the panel discussion -Jennifer Ekstrom, Filmmaker, and Principal Storyteller, Catalyst Communications -Menkin Nelson, Film Producer -Ralph Silberstein, Community Environmental Advocates Foundation -Carrie Monahan, Sierra Fund -Christy Hubbard, Impacted Homeowner QUICK FACTS: Did you know that large noisy gravel hauling trucks will run an average of 100 trips (one way) per day, and up to 200 trips? Running 16 hours per day, 7 days per week, that means a truck will pass by every 9.6 minutes, and as often as every 4.8 minutes. Added to that would be numerous other daily cement and materials trucks.

Beating the Pebble Mine in Alaska is no small feat. It’s been going on for more than 10 years now. Big money and big politics are involved. But recent setbacks make the prospects of opening the mine very dim. And it’s a great lesson in strategies for beating Rise Gold and the proposed Idaho-Maryland Mine in Grass Valley. 1) Force them to prove they will do no harm. If they can’t, you win. Knowing the law matters. “The Army Corps of Engineers on Wednesday denied a permit under the Federal Clean Water Act for the proposed Pebble Mine in Alaska, likely dealing a death blow to a long-disputed project that aimed to extract one of the world’s largest deposits of copper and gold ore, but which threatened breeding grounds for salmon in the pristine Bristol Bay region… In a statement, the Army Corps’ Alaska District Commander, Col. Damon Delarosa, said the mine, proposed for a remote tundra region about 200 miles from Anchorage, would be “contrary to the public interest” because “it does not comply with Clean Water Act guidelines.” 2) Look for and expose dirty business. "In September, the future of the multibillion dollar project appeared in doubt when secret recordings of company executives suggested that they were planning for a much larger mine, and one that would operate far longer, than what had been proposed to the Corps. The recordings were obtained by an environmental advocacy group, with two members who were posing as potential investors in the project meeting by video with two project executives. The executives described how the mine could operate for 160 years or more beyond the proposed 20 years, and how its output could double after the first two decades. In the fallout from the recordings, one of the executives, Tom Collier, chief executive of the Pebble Partnership, resigned." Read the full article here.

In a full-page Christmas letter advertisement by Rise Gold’s Ben Mossman, he assured readers his gold mine won’t have any ill effect on Grass Valley. He invited readers to send him a letter, providing his email. And yet, a letter sent to him suggesting alternative uses for the mine property went unacknowledged and unanswered. Is this the kind of business we want here? One that pretends to care but doesn’t really? Read the full letter in the Union.

Once again, a junior mining company from Canada has arrived in town with an eye to reopen the Idaho-Maryland Mine. So far, Rise Gold Corp. has not made a good impression. If you’re new to the area, or your memory fades on the subject, here’s a quick refresher: Every 5 or 10 years, gold mine investors get excited about the idea of re-opening an abandoned mine. These investment companies are often from out of state. In particular, “junior” mining companies from Canada operate in California because they enjoy funding loopholes that encourage speculation. The last such company, Emgold, threw in the towel after it was unable to complete the permitting process in 2012. Read the full "Other Voices" column in The Union here.

By Tom Behlmer, Grass Valley Resident January 22, 2021 Read this Opinion piece in The Union. Every once in a while, I run into someone in person or online who seems to be in favor of reopening the Idaho Maryland Mine. Their reasons for doing so simply tell me they really haven’t thought this thing through yet. The most common pro-mine argument seems to be based on some type of misguided nostalgia: “This town started with mining,” they say. At the time, the town thought of it as prosperity, but today, we know that hard rock mining is the single largest source of toxic waste in the U.S. We used to have above ground atomic bomb tests north of Las Vegas and we used to dump toxic DDT barrels off the Southern California coast that later leaked. The second argument, “it will create jobs,” seems reasonable at first, but a closer look opens up a long list of questions. Rise Gold states that 300 jobs will be created by opening the mine. Has this number been verified? I believe it has not. Could it be an empty promise? It would not be the first time a company has promised one thing and under delivered. Jobs for whom? Ask yourself does the local area have people with mining skills or willing to be trained to work deep under ground? Will workers from outside the area be brought in to fill these jobs? If so, where will they live when we have a very tight rental and real estate market? Will they drive up rents, pushing out local essential workers? Will this affect small businesses? With workers more able to work from home due to COVID-19, the area may see an influx of workers from urban areas boosting the local economy and lessening the need for an industrial facility. If the county wants to attract jobs, how about finding a buyer or occupant for the empty Grass Valley Group complex off of Providence Mine Road by offering tax abatement for a period? And that leads to the third argument: “You shouldn’t have bought property next to a mine,” which assumes that through some personal failing, only a few people are affected. Seriously? It was closed for almost 70 years. The property Rise wants to develop has been zoned for light industrial use — not mining — for a long time now. If we flip this around, then Rise Gold should not have bought the property with the intention to open a mine in a residential neighborhood. The reality is that the impact from the mine is likely to affect more than the homes in the immediate area. Don’t think that since you live a distance away from the mine, there is no need to be concerned. When industrial mining was done here, there were not the following issues for the community: — Awareness of the toxicity of dust containing arsenic and silica. The dust is generated by loading, transporting and off loading of ore. The discarded ore will eventually reach a height of 70 feet and would be located off of Centennial Street in Grass Valley. I would not want to be downwind of the discard pile. Also the issue of added pollution from diesel exhaust from trucks running 14 hours per day, seven days a week. — Potential devaluation of property values. Lower property values leads to less property tax for the county and lower Realtor commissions, which largely gets fed back into the local community. — Potential liability to the county if there is an environmental “mishap.” We have had two sinkholes in Grass Valley or Nevada City in the past five years. Will emptying the mine shafts of water and using explosives for blasting risk more sinkholes? There are 367 miles of tunnel under the old Empire Mine. The CEO of Rise has a checkered history at best of leaving behind messes from not adhering to regulations. Please see the commentary in The Union from Dec. 7, 2020: “Rise Gold Shouldn't Be Trusted. Here's Why.” If just three of the five Nevada County supervisors approve the permit, which would grant an 80-year operating period, the project is likely to go forward. The issue should be decided by a countywide vote. I think it would be an extreme example of government abuse of power to have it decided by three people. What’s next? This is a battle of a community against corporate interests. Your help is badly needed. If you oppose the mine or wish to prevent government overreach, please contact your local county supervisor. If unsure who it is please refer to this https://www.mynevadacounty.com/2175/Supervisorial-Districts.

Dear MineWatchers, Do you have plans this Saturday? Have you been looking for a movie on Friday night? Join us for this month’s workshop (and see a movie!) Mining Gold Again in Nevada County? — Sat. Jan. 23 at 4pm Join Nevada County leaders and conservation activists as they discuss the proposed reopening of Idaho Maryland Mine and offer actions you can take now to help prevent it. This proposal by a foreign corporation is the topic of the film, Rise Beyond Gold, which premiers in the "Local Love" film session. This Activist Center Workshop explores the impacts the community would face if Nevada County allows the mine to open. It offers insights from trusted community leaders, highlights ways to stay informed, and includes tips for influencing decision makers. Pascale Fusshoeller, esteemed editor of YubaNet and 21-year veteran of the Nevada County news scene, will moderate the panel featuring: • Jennifer Ekstrom, Filmmaker, Rise Beyond Gold • Ralph Silberstein, Community Environmental Advocates Foundation • Shelly Covert, Secretary, Community Outreach, and Spokesperson, Nevada City Rancheria Nisenan Tribal Council • Dr. Carrie Monohan, Program Director, The Sierra Fund Be sure to check out the film Rise Beyond Gold in the Film Festival’s "Local Love" session. You can watch it on Friday (or any time during the Festival) Film guide | Wild & Scenic Film Festival (eventive.org) Wondering when the public will see the environmental documents? Well, we have an update. According to recent conversations with the County, they are now reviewing revised technical documents. The County expects that the Draft Environmental Impact Report might be out in late Spring or early Summer. You can learn more about the public process and when to expect opportunities for the public to be involved with a short overview of the timeline here: CEQA Timeline for Idaho-Maryland Mine - CEA Foundation on Vimeo FUN FACTS: Did you know that a study to determine the vibrations from blasting was prepared? The analysis uses the standard of shock waves up to 0.4 inch per second as "an acceptable standard" because only 8% of the population will complain! Did you get forwarded this newsletter from a friend? Subscribe to MineWatch here.

Hello MineWatchers - We have some encouraging news to start off the new year: Your actions made a difference! -The Mine is now one of the County’s top four focus areas this year. The Union’s front page article on New Year’s Day gave a run-down of the top four issues facing the County in 2021, listing the proposed re-opening of the Idaho-Maryland Mine as one of four, along with the vaccine roll-out, economic recovery, and PSPS/Wildfire concerns. In a switch from past articles that were decidedly pro-mine, this article sized up the debate-to-come by presenting the opposition as credible and well organized, while putting Rise Gold in a defensive position and forcing them to explain CEO Ben Mossman’s bad history. A big piece of this win is due to you -The article remarked on this community’s visible and vocal presence at board of supervisor meetings over the past few months. Thank you! Your respectful participation in our government’s process is earning us the credibility we need in order to win this fight. If you haven’t heard about Mossman’s past yet, the facts are based on Bob Hubbard’s Opinion Editorial from December, "Rise Gold Shouldn’t Be Trusted. Here’s Why." Help us stay credible - We believe that interactions with our elected officials and public servants should always be done with respect and politeness, and never with threats or intimidation. So far, most of our community has done just exactly that and we thank you for it. Please join us in encouraging a positive, productive relationship with our County’s decision makers. We have the tools to defeat this mine project if we use them wisely. Let us start the new year with a focus on civility and trying to work together. It's a new year -- time to get the word out - Join our group on Facebook and check out our new campaign website MineWatch Nevada County (MineWatchNC.org). We hope this new site will serve as a resource for everyone. It includes talking points, recent news, and fact sheets to help answer your questions and educate our community. Thank you for all that you do! The Team at CEA Foundation

By Martha Turner, Grass Valley Resident January 5, 2021 Dear Mr. Ben Mossman, president, Rise Grass Valley Inc.: How could I miss your full page ad in The Union on Dec. 23, 2020? It was a slap in the face to all of us who live in Grass Valley. You wishing us all a Merry Christmas while publishing what I believe to be falsehoods about what high standards Rise Gold Corp. will follow and presuming to know what the reopening of your mine means to our community. Read Martha's full article in The Union.

Denise Bellas, Grass Valley Resident May 15, 2020 Read this article in The Union. As a local Grass Valley resident, I want to pose questions and voice my opinions in regards to the reopening of the Idaho Maryland Mine by Rise Gold Corp. Mr. Benjamin Mossman, as CEO of Rise Gold Corp., is currently enticing investors with high expectations of gold returns, but seems to neglect an awful lot of information in their marketing campaign. I understand that their primary goal is to acquire money to restart the Idaho Maryland Mine in our town. The CEO has been in the marketing phase of pushing that forward through his many videos and website articles. I understand that our community has many views on mining. Looking forward, it seems to be very questionable as to how this will impact our town. We all enjoy the history of mining, but I doubt that very few of us would appreciate an active mine in our backyard and mining debris running through the Nevada County tributaries. As a homeowner who lives on Wolf Creek, I often see adults and kids fishing, swimming and enjoying the environment of the creek. With this in mind, I have to ask myself are the benefits of this mine worth the potential risk to Wolf Creek and our community? We will be allowing Rise Gold to release water from the mine down and into Wolf Creek. This could impact our children and our community, also our property values. I was rather upset when I thought about this scenario. So, I googled Mr. Benjamin Mossman to get an idea of how ethical he has been in the past and looking for some signs of integrity. He markets the company and the project in such a glowing way. I believe, that the past often predicts the future. I found information on one of Mr. Mossman recent past projects, Banks Island Gold Limited in Canada. As president and CEO, Mr. Mossman created a company that ended in bankruptcy, was charged with many environmental violations and had their $420,000 security bond confiscated by the Ministry of Energy and Mines to clean the polluted site. According to the Government of Canada’s website, “on July 13, 2018, Mossman was found guilty of one violation of the Fisheries Act ($7,500) and one violation of the Provincial Environmental Management Act ($7,500).” I was so upset that we are even considering a company run by this person. I personally believe, based on his past actions, I do not trust that he is a person of integrity. I do not believe that he will act in an ethical way. I do not believe he will value the preservation of our community and our environment over maximizing profits. Even in the best of circumstances, mining will impact our community. Whether through day-to-day operations or some unforeseen consequences. Because of this, I believe we as a community need to think long and hard before reopening the Idaho Maryland Mine. I have thought long and hard about this and I do not think this mine should ever be reopen. And, certainly not by a company like Rise Gold. Are they just a song and dance management, with a shady past? Can we really trust this company? I fear not. Denise Bellas lives in Grass Valley.

Don Rogers - The Union July 19, 2020 Ironically enough, the way to clean up the environment around the old Idaho-Maryland Mine might well be reopening it. You’d think nearby residents and environmental advocates would be eager — or at least willing — to explore this possibility before trying to smother the baby in the crib. To see whether tailings polluting the ground these past seven decades might finally be removed. Whether a million gallons a day of fresh drinking water might be welcomed in a thirsty county. All this under strict state scrutiny. Read the full article in The Union. Read Ralph Silberstein's response.

Ralph Silberstein - CEA Foundation July 23, 2020 Columns published by a community newspaper generally endeavor to address issues in a factual and respectful manner. The publication of columns such as The Union publisher’s July 10 piece “Not so fast with writing off the mine” seem to cross the line in a way that is a disservice to the community. Here are just a few of the many points that were misguided: Regarding the claim that people should support the mine because it will clean up the existing tailings: the legacy tailings are being cleaned up regardless of whether or not the mine project is approved. The clean-up is an ongoing project under the California Department of Toxic Substances Control (DTSC). Even if the permit to open the mine is never granted, RISE is required to clean up the tailings. That is a good thing. No one is trying to stop that. Read the full "Other Voices" column in The Union.

Tom Behlmer - Grass Valley Resident August 25, 2020 If Rise Gold is serious about being a good neighbor, they should use electric trucks instead of diesel for the 50 to 100 round trips each day, seven days a week. Electric trucks are made by Volvo, Daimler, BYD and Nikola. This would reduce noise, soot and pollution. Second, for those whose wells are dewatered, require Rise to reimburse the homeowner for water until the homeowner’s well can be safely restored and to secure this obligation with a bond. The hydrology report says only a few wells are at risk. Then why is Rise unwilling to reimburse for water to all affected home owners? These two mentioned items should be a requirement imposed on Rise by the Nevada County Board of Supervisors before considering a permit. Read full "Other Voices" column in The Union.

As a resident whose property is bisected by South Wolf Creek, I write to express my vehement objection to approval of this gold mining operation. Impacts to the creek would be severe due to the extensive dewatering. Riparian habitat, ground water, and wells along this beautiful and currently healthy creek would be immeasurably harmed in the near term and for generations to come. We are still monitoring Nevada County from the effects of mining operations of the 20th century. Read full Letter to the Editor of The Union.

By Bob Clark, Grass Valley Resident October 5, 2020 If you are thinking of buying shares of Rise Gold think again. As you probably know Nevada County is considering issuing permits to a Canadian Company called Rise Gold to reopen mining in Grass Valley. The reason for this letter is because of my decades of knowledge and experience in the finance industry and my desire to protect you and my neighbors from what would most certainly result in financial loss. Perhaps you have considered buying shares in Rise Gold thinking this could be your get-rich-quick opportunity. Regardless of if you are for or against the mine, please don’t. Please consider the following facts: Read Bob Clark's complete "Other Voices" column in The Union.

FAST FACTS The Idaho-Maryland Mine was acquired from Emgold Mining by Rise Gold Corp, another junior mining company from Canada. The new owner has recently completed exploratory drilling at the New Brunswick site. This site is situated at the headwaters of the pristine South Fork Wolf Creek near where Bennett Street intersects Brunswick Road.

By Ralph Silberstein - Community Environmental Advocates Foundation January 20, 2020 While Canadian mining company RISE Gold Corp was promoting the gold mine potential and alluring prospects of gaining permits to reopen the Idaho-Maryland Mine (IM Mine) in Grass Valley, CA, federal and state regulatory agencies were focusing on the polluted tailings that cover most of the 56.4 acre site and taking steps leading towards a Superfund Designation. There has been little public disclosure of the contaminated legacy IM Mine tailings, but correspondence from the EPA dated Sept 26, 2019 indicates that IM Mine’s potential designation as a Superfund site was conditionally deferred because RISE entered into a cleanup contract with the California Department of Toxic Substance Control (DTSC).[1] On August 13, 2019, RISE Gold CEO Ben Mossman signed agreements to cleanup the site, also known as the Centennial site.[2] According to the DTSC records, RISE has been dealing with this issue from at least as early as March 13, 2019, when the first Scoping Meetings with the DTSC took place.[3] Tests conducted in 1993 by Vector Engineering showed elevated levels of arsenic, chromium, copper, mercury, lead, and nickel over two large areas of the legacy tailings, one area originating from the Mercury gold extraction processing that took place prior to 1926, and a second area being from the Cyanide extraction processing that took place from 1936 until the mine closed around 1956.[4] More recent reports from the DTSC determined that lead, arsenic, nickel, and mercury are present at hazardous levels.[5] Contaminated tailings cover roughly 2/3 of the 56.4 acres with depths ranging from 2 to 20 feet. As an additional complication, RISE Gold’s recent bid to re-open the mine includes plans to use the site for disposal of 1.6 million tons of mine waste rock and tailings as “engineered fill” over the course of 5 years, covering 44 acres and creating a built-up area 30 to 70 feet above current grade. However, a recently posted geotechnical report indicates that the legacy tailings are not structurally adequate for use underneath the engineered fill, so they have to be completely excavated before the dumping can take place.[6] The full extent of the contamination within the tailings is not yet clear, but even if some of the tailings are clean they will all have to be extracted and then remixed with other aggregates before they would be stable enough to be built upon as planned.[7] Rise Gold has not yet revealed what procedures will be used to get the legacy tailings off the bedrock and safely dealt with before the new waste rock and tailings from mine operations can be deposited. Nor is it clear whether the contaminated tailings will need to be sequestered separately on site, whether they can be integrated into the engineered fill, or whether they need to be trucked to a waste disposal facility. According to the agreement, the entire remediation process will be overseen by the DTSC. However, Nevada County and other government agencies will be overseeing all operations with respect to the IM Mine re-opening permits, which is independent of the DTSC permitting and is a separate project with a separate time frame. [1] US EPA Transmittal of Preliminary Assessment Report,Sept 26, 2019 [2] Cleanup Agreement, Signed by RISE Aug 13, 2019 [3] Ibid., Exhibit E [4] “Contaminant Assessment of the Bouma-Erickson-Toms Property”, Vector Engineering, Nov 1993 [5] Centennial Geotechnical Report, NV5 [6] Centennial Site History, DTSC [7] Idaho-Maryland Mine Project Description, Nov 2019, pg 16

By Community Environmental Advocates Foundation Grass Valley, CA - December 22, 2019 The county staff are currently reviewing the application and preparing to start the CEQA process. The application overview can be viewed here. The project details per the applicant’s documents can be viewed here. CEA Foundation (aka formerly CLAIM-GV) was among the agencies and groups that were contacted and invited to submit preliminary comments to provide additional information at this early stage. A comment letter was produced by the collective efforts of CEA Mining Committee and submitted on Dec16. The Mining Committee drew heavily upon experience from prior mining projects to produce this document. See:IdahoMarylandMine_App_CEA_comments_13Dec2019 Download This is the start of the permitting process which will probably take more than a year. Once the application is deemed complete and a CEQA Notice of Preparation (NOP) is recorded, public scoping meetings will follow in which possible impacts are identified for study for the Draft Environmental Impact Report (DEIR). At this preliminary phase, CEA has identified many areas of great concern. Most notable: Possible misguidance to investors – The obstacles to permitting and high costs of development and operations are not adequately delineated. Significant GHG emissions – Initial electric usage will be at least 50 GWH/yr, or about 20% of Nevada County’s total usage. Significant fossil fuels will also be used. It needs to be net zero. Impacts of dewatering – Among other things, plans to dewater into South Fork Wolf Creek were rejected in prior DEIR process due to impacts of permanent flood stage downstream. Ground water risks – Potential pollution risks from operations, tailings, explosives, gold processing and threat to local wells beyond the area currently identified. Truck traffic – Up to 16 trips/hour for up to 80 years. Noise – 24/7 Operations, high velocity fans, aggregate trucks loading, etc. Subterranean reclamation – Risks of toxic leaching over time from 500 tons/day of slurry backfills Economic impacts – Negative impacts on local housing, tourism, high tech businesses Regulatory challenges – Constant monitoring will needed on numerous operations. Habitat loss -Replacing large areas of forested woodlands with barren gravel fill, including “engineered fill” covering 75 acres to depths of 30-70 feet. Sept 29, 2019 – RISE Gold has obtained over $3.5M in funding and is preparing to apply for a mining permit. As in the previous case with Emgold Mining Co, this junior mining company from Canada is spinning a fantastic story about the prospects of the Idaho-Maryland Mine and finding speculators willing to throw their money at the project. (See risegoldcorp.com) June 1, 2019 – The noise stopped. RISE Gold apparently completed their exploratory drilling operations. This is a great relief to the area residents who have been suffering from the noise. Drilling Noise – Residents in the area have been very impacted by the 24/7 drilling noise. Numerous complaints were made to Nevada County officials for noise violations. However, since a previous sound study by an independent acoustical consultant showed that the sound levels were marginally within legal limits, County officials were not responsive. Residents then challenged the validity of the sound study due to the placement of the metering and due to the fact that the drilling operators had full knowledge that the metering was taking place. Measurements of the noise by residents showed noise levels in excess of the legal limits during the hours of 10:00 PM – 7:00 AM. Supervisor Dan Miller made a site visit and agreed that the noise level in a neighboring house was unacceptably loud. As no action was being taken by the County, in May 2019 a number of people made public comments to the Board of Supervisors requesting that the drilling at least be shut down during the night. Unfortunately, no code violations were issued and no initiatives were undertaken by the BOS. Apparently, in order to compel action with the county, the residents would have to pay for a costly sound study to show that noise levels are in violation. 10/1/18 RISE violations continue — CEA Foundation continues to monitor the activities of RISE Gold Corp, the new owner of the Idaho Maryland Mine. RISE has now acquired most of the land that was previously owned or lease-optioned by Emgold, in addition to some other parcels. Since Fall 2017 they have been doing extensive drilling at the “New Brunswick” site located near the intersection of East Bennett and Brunswick Rd, adjacent to the old SPI site. (Millsite Rd). In mid-September 2018, RISE moved their drilling operations from near the old SPI site to the newly constructed pad at the west side of their holdings (12603 East Bennett Rd). In setting up their equipment, RISE again violated the 100’ setback from the creek! This was in spite of having been required to hire a biologist to prepare a Biological Management Plan as a consequence of prior violations last winter (see below). Also, there has been some controversy regarding their method of measurement for establishing the 100’ setback. County ordinance requires that the setback be measured from the high water mark or the top of bank, which is apparently not the case here. The County is now requiring the biologist to reflag the correct setbacks and possibly restore a larger area in the riparian zone. Local residents have filed complaints about noise from the drilling operations. To mitigate that, RISE has constructed a sound wall.

By The Union September 17, 2020 See original article here.

By Ralph Silberstein - Community Environmental Advocates Foundation July 25, 2020 Once again Grass Valley has to deal with a Canadian junior mining company trying to open the Idaho-Maryland Mine. Rise Gold Corp’s application to re-open the mine is not yet deemed complete by Nevada County Planning Department, but a review of currently available documents provides a into the nature of the project and the many ways it would impact our community. Here’s just one. Mining will take place 24 hours a day, 7 days a week at the New Brunswick site at the corner of East Bennett and Brunswick Rd. About 1500 tons of waste rock and tailings will be removed from the mine daily. Of this, 500 tons per day will be mixed with cement to form a paste backfill and re-deposited into the mine. The remaining 1000 tons per day will be loaded and trucked over to the 56 acre former mine site along Idaho-Maryland Road (between De Martini RV Sales and Centennial Drive). This means that waste rock and tailings from the mine will be transported by trucks making up to 100 round trips per day, 16 hours per day, 7 days per week. There are a lot of residences in that area. To get to the Centennial Drive site, the heavily laden gravel trucks will turn left onto Brunswick Road, pass through the East Bennett Rd intersection and turn onto Whispering Pines Lane to reach Centennial Drive. Then, using bulldozers, graders, and rolling compactors, a mountain of gravel will be formed covering 44 acres up to 70 feet high. A subsequent second mountain of tailings is also planned for on the southern portion of the New Brunswick site along Brunswick Rd. These operations will run for at least 11 years. Grass Valley has designated the Idaho-Maryland Road site as Business Park and Urban Medium Density Residential, but Rise Gold intends to get this changed to Industrial. Given the housing shortage, and considering the anticipated development of hundreds of homes at Loma Rica Ranch just beyond this site, one might ask why the City of Grass Valley doesn’t just summarily tell the mine to go away now and save a whole lot of trouble. It would be incredibly bad judgment to put a “reverse” gravel quarry at this location just while Loma Rica will be trying to sell homes. Just think, if the proposed Dorsey Marketplace is approved, the 172 units of high end apartments will be built directly above and looking down on this dusty noisy gravel operation as well. What makes sense is to stick with the Grass Valley General Plan, not allow a rezone. We need to promote a walkable housing and business park community at this close-to-downtown location. It is one of the few places left in our city where this kind of infill development can take place. It would be a bad idea to go with mine waste mountains instead.

By Ralph Silberstein - Community Environmental Advocates Foundation Grass Valley, CA – March 11, 2020 Rise Gold Corp’s application to re-open the Idaho-Maryland Mine is not yet deemed complete by Nevada County Planning Department, but a review of currently available documents provides a glimpse into the nature of the project and how it may impact our community. The main mine access and processing facilities will be located at the 119 acre New Brunswick site located at the corner of Brunswick and East Bennett Roads. Operations will also utilize the 56 acre Centennial site on Idaho-Maryland Road west of Centennial Drive to dispose of mine waste.[1] Mining will take place 24 hours a day, 7 days a week. About 1500 tons of waste rock and tailings will be removed from the mine daily. Of this, 500 tons per day will be mixed with cement to form a paste backfill and re-deposited into the mine. The remaining 1000 tons per day will be deposited at the Centennial site and at a 31 acre area along Brunswick Road just south of the processing facility and bounded by neighborhoods on Cedar Ridge Drive, Elk Lane, and Mink Court. Waste rock and tailings from the mine will be transported by trucks making up to 100 round trips per day, 16 hours per day, 7 days per week. To get to the Centennial site, they will turn left onto Brunswick Road about 0.4 miles south of East Bennett Rd, pass through the intersection of East Bennett and Brunswick and turn left onto Whispering Pines Lane to reach Centennial Drive. At the Centennial site, an area of 44 acres will be built up with “engineered fill” to depths of up to 70 feet, eventually forming a 37 acre graded surface that may be utilized for future development. Similarly, the mine waste dumped at the Brunswick Road site will eventually cover an area of 31 acres and be built up as much as 90 feet to form a 21 acre graded area for possible future industrial uses. The trucks will be loaded with rock with a front-end loader. Hauling will take place 6:00 AM – 10:00 PM, 7 days a week. After the rock is dumped, it will be graded and compacted 7:00 AM – 3:30 PM, 7 days a week, using bulldozers, graders, and rolling compactors. [2] This activity will take place continuously for 11 years or until both build-up areas are maximized. After that, mine waste materials will have to be hauled out via Brunswick Road to Glenbrook Basin in order to access Hwy 49 for transport to sites not yet identified. In terms of energy use, the permit application estimates a PG&E power net load of 6000 Kilowatts (KW). Planned diesel backup power generation capacity is 6000 KW. Electricity utilization is estimated at 42,757,000 Kilowatt-Hours (KWH) per year.[3] This is equivalent to the electric use of about 5000 houses.[4] Full operations of the mine, including fuel for equipment, electricity, and other operational uses are estimated to produce around 9,000 metric tons of greenhouse gas emissions per year.[5] Cement, explosives, diesel, and various other chemicals will be regularly transported to the site and stored. Cement will be mixed with tailings and pumped back underground and used to backfill mining voids. By one estimate, the backfill paste will use approximately 25 tons of cement daily. Explosives will include ANFO (Ammonium Nitrate and Fuel Oil), and Ammonium Nitrate Emulsion. Up to 28,000 lbs. of explosives will be stored onsite underground.[6] Diesel fuel storage will consist of a 30,000 gallon aboveground storage tank. A number of other chemicals will be utilized for processing the gold using the sulfide flotation system and other activities. Industrial buildings covering 122,000 square feet are proposed for the New Brunswick site. Noteworthy among these would be the gold processing plant with dimensions of 425 feet by 70 feet and 65 feet high, and the shaft headframe building with a height of 165 feet. Running between these buildings will be a 365’ long enclosed conveyor system. Tailings will be stockpiled onsite while waiting for transport. The application to re-operate the Idaho-Maryland mine states that 312 jobs would be created by the mine operations. Of those jobs, 242 jobs are specialized technical positions likely taken by people recruited from outside the area. The remaining jobs, truck transport of mine waste, and mineral processing, could provide 70 jobs for current local residents. Content provided by Community Environmental Advocates Foundation (CEA Foundation) [1] Project application documents may be viewed on the Nevada County website here. Unless noted, see Idaho-Maryland Mine Project Description, Nov 2019 [2] Noise and Vibration Analysis, Table 9 [3]Air Quality and greenhouse Gas Emissions Analysis Technical Report for the Idaho-Maryland Mine Project, Feb 2020, pgs 73-74 [4] Average energy usage per CA residence = 667 KWH / month = ~8000 KWH / year. IMM will use equivalent to 42,757,000 / 8000 = 5344 houses. https://www.electricchoice.com/blog/electricity-on-average-do-homes/ [5] Ibid [3] [6] Environmental Factors of Blasting Report for the Proposed Idaho-Maryland Gold Project

FAST FACT The grading work that was done was reportedly not in conformance with the submitted plans, resulting in failed inspections failing in December/January. In addition to failing to protect against storm runoff into South Fork Wolf Creek, grading work was done in violation of the 100′ setback from the creek and a large number of trees had been logged and staged within the setback. Because of these violations and encroachment into the setback zone, a comprehensive Management Plan, to be prepared by a qualified biologist, was requested. (as per Nevada County Land Use and Development Code Section L-II 4..3.17.) County reported back that RISE must submit revised plans showing accurate depiction of work completed, erosion control measures, 100ft setback, and site survey. This submission and a biologist recommendations will be reviewed by county.

FAST FACT In addition to the County grading violations, Idaho-Maryland Mine owner RISE Gold Corp failed to submit the required timber harvest plan and timberland conversion document, as per the local CalFire (CDF) Forester in charge of permits.

By San Juan Taxpayers Association Matt Kelley, Senior Planner Nevada County Planning Department The following are comments of the San Juan Ridge Taxpayers Association on the Notice of Preparation of an Environmental Impact Report for the Idaho-Maryland Mine Project. We are an organization that includes many residents of Nevada County who regularly visit Grass Valley and rely on its businesses, agencies and schools, and as we do not have significant urban development in our area, consider Grass Valley to be part of our home. Read full article by San Juan Taxpayers Association here.

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. To: Matt Kelley, Senior Planner Nevada County Planning Dept. 950 Maidu Ave Nevada City, CA 95959-8617 Regarding: 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//