Advanced
SEARCH
Search our Library
314 results found with an empty search
- Patricia Sharp: Save our town
This Grass Valley resident shares a piece of local history regarding the huge costs and hurdles of the Magenta Drain which handles runoff from the historic Empire Mine. This opinion piece was originally published in The Union. I live in town in Grass Valley, not far from Empire Mine State Park. For the 20 years I’ve lived in this house, I’ve walked there four days a week. Anyone who uses the park is familiar with the Magenta Drain. It serves to filter out the heavy metals that accumulated in the mine water. An expenditure of over $2 million dollars created a natural filtration system that removes 60-70% of the metals out of the water. The process to clean up that site has been a long and winding one. Newmont, the previous mine owners didn’t want to pay for the underground cleanup. A lawsuit ensued in July of 2012; the State of California sued Newmont Mining to reimburse the State for the $36 million dollars it already spent remediating the toxic waste. The suit included all future responsibility for the cleanup. Newmont ended up settling with California State Parks for $15 million and the cost of ongoing and future costs for cleanup. The ordeal and expense of toxic mine waste cleanup even prompted talk from a couple of state legislators to suggest selling the 850-acre State Historic Park. The point I want to make is that industrial hardrock mining is a dirty, toxic business. So dirty and toxic that no one wants to foot the cleanup bill. It is most certainly not something that should be done in a populated area. There will be tons and tons of toxic soils trucked out, through town, spewing diesel exhaust, toxic dust floating around, impeding traffic, not to mention all the homes nearby that might lose their well water. Right out front, the owners of Rise Gold are not trustworthy. Quoting from Bob and Christy Hubbard, in The Union Newspaper opinion piece / Dec. 7, 2020, “CEO Ben Mossman’s last venture before joining Rise Gold was a profound failure, and disregard for regulations and poor management practices appear to have played a significant role in that. His company, Banks Island Gold Ltd., owned the Yellow Giant Mine in British Columbia, Canada, which polluted tribal waters, went bankrupt and left Canadians with a mess to clean up”. An industrial mining operation has no business being in the middle our beloved Grass Valley. The potential degradation to our town combined with the management record of Rise Gold should lead you, our Nevada County Supervisors, to vote NO on reopening the Idaho-Maryland Mine. Let’s not foul our nest anymore. Patricia Sharp Grass Valley
- Centennial Site: Understand The Issue
Rise Gold owns the toxic Centennial Site near downtown Grass Valley and is obligated to clean it up. That’s good for the community, but if the Mine is approved, they’ll use it to dump more mine waste. Even "clean" mine waste is hazardous. It presents health concerns for the community and limits what the City of Grass Valley can do with the land in the future. A key issue is the fact that the County's Final Environmental Impact Report excludes the Centennial Site from the full analysis of the impacts of the proposed Idaho-Maryland Mine project. This prevents the County from understanding the full environmental impacts and is a clear violation of CEQA, which requires that impact assessments be based on current conditions, not a speculative future condition. Included below: Background Final Environmental Impact Report Fails to Assess Impacts of Centennial Site Next Steps on the Cleanup Plan Background Rise Gold owns two sites, the Centennial site near downtown Grass Valley off of Idaho-Maryland Road, and the larger Brunswick site at the intersection of East Bennett and Brunswick Roads. The Centennial site is a historically toxic site that is facing EPA Superfund designation. That designation has been "conditionally deferred" for the time being because Rise Gold has agreed to clean up the site under the supervision of the CA Department of Toxic Substances Control (DTSC). The proposed Idaho-Maryland Mine project plans to use it as one of two places they’ll put their “engineered fill” using waste rock and tailings extracted from the mine. The goal is to restore the property to a healthy natural state, including reestablishing vegetation, reclaiming some wetlands, and letting existing seasonal creeks continue to flow. Per the zoning planned by the City of Grass Valley, open spaces would be developed as a mixed-use Business Park with some Medium Density Housing. Rise Gold is paying for the work. The project was started in August 2019 and is completely independent of the Mine project, which is managed by the Nevada County Planning Department. For the Centennial Site cleanup, DTSC is the lead agency. It uses different inspectors. And there is no dependency on the mine being approved. Of particular concerns is the Centennial Wetlands, which are a protected natural resource that are crucial to a functioning watershed. The currently proposed plan would destroy wetlands that shouldn't be damaged. Barbara Rivenes from Sierra Club describes the project in this video from 2020. The dates have been extended since this video was made, but most project details remain the same. Read the public comments provided by CEA Foundation, coalition partners, and respected law firm Shute, Mihaly, and Weinberger showing why the DTSC's first draft plan is inadequate. Final Environmental Impact Report Fails to Assess Impacts of Centennial Site The FEIR excludes the Centennial Site from the full analysis of the impacts of the mine project. This prevents the County from understanding the full environmental impacts and is a clear violation of CEQA (California Environmental Quality Act), which requires that impact assessments be based on current conditions, not a speculative future condition. ● The 56-acre Centennial site is the location of hazardous waste left over from past Idaho-Maryland Mine operations. The California Department of Toxic Substances Control (DTSC) is managing the cleanup, but their Remedial Action Plan (RAP) is only in draft form. It is unclear when the plan will be finalized or when DTSC might approve the clean up. ● Per CEQA, the EIR must provide an environmental assessment of the current conditions of a project site to establish a baseline in order to determine impacts. This was not done. The FEIR assumes the site will be cleaned up before it gets used to deposit new mine waste. The plan calls for placing 1.6 million tons of mine waste (assuming it qualifies as Group C) over the course of 5 years, covering about 44 acres to a height of up to 55 feet. And yet, the significant work needed to accomplish this clean-up is not disclosed or evaluated in the FEIR. Numerous aspects of this RAP draft have been questioned in public comments and the final project details are unknown. Read public comments from CEA Foundation: The Centennial Clean Up Must Be Included In the EIR. Next Steps on the Cleanup Plan A Preliminary Endangerment Assessment (PEA) was published in 2020 that evaluated the contaminants and guided the planning for the Centennial Site. The first draft of a Remediation Action Plan (RAP) was published in July 2021 and the public was invited to comment. Under CEQA, this is a "Mitigated Negative Declaration", which examines the impacts and proposed mitigations (such as how to mitigate the damage to wetlands that will get dug up during the cleanup.) DTSC has not published a schedule for the second draft yet. Learn more about comments on the Centennial Site provided by CEA Foundation and coalition partners. Read more about the Centennial site.
- Dr. Newsom on Health Risks of Mine
Learn about the potential public health risks of reopening the Idaho-Maryland Mine. Join Dr. Christine Newsom as she explores questions about how compromised air quality, water quality, or noise could affect health - including psycho-social effects - in a community that is already struggling with poor ratings for air quality, respiratory disease, heart disease, asthma, depression, and suicide. Dr. Christine Newsom practiced as an internist in Nevada County for almost four decades, taking care of patients with cases of pulmonary and cardiac diseases. She is now retired. She's a long-time volunteer. And she's an active community member of Nevada City and Grass Valley. This talk was given on May 27, 2021 as Dr. Newsome joined a MineWatch virtual community meeting hosted by CEA Foundation and community partners. Corrections: Some statements included in the recorded presentation deserve correction or clarification. Rise Gold plans to do rock crushing underground, not on the surface. The "processed ore" is not loaded up on trucks and sent to the Centennial site. That is actually where the gold is concentrated. What is hauled to the Centennial site is just the waste rock and tailings. This was recorded as part of the MineWatch May 2021 Community Event. You can view the entire meeting here.
- CEA Comments to Grass Valley Development Director
By Community Environmental Advocates Foundation September 6, 2020 To: Thomas Last, Grass Valley Community Development Director Grass Valley City Council Grass Valley Planning Commission Grass Valley Development Review Committee Tim Kiser, Grass Valley City Manager Regarding: Application Number 20PLN-24 Conceptual Development Review of Idaho-Maryland Mine Permit Application in the City’s Sphere of Influence Dear Thomas Last, City Council Members, et al, Please accept these comments regarding the Idaho-Maryland Mine Permit Application within the Grass Valley Sphere of Influence. Community Environmental Advocates Foundation (CEA Foundation) is concerned that the reopening of the Idaho-Maryland Mine would create serious impacts to the people of Grass Valley, to the environment, and to the local economy. Whereas the county is processing the application, it is the City that, by far, has the most to gain or lose. It is for this reason that we implore City staff, Planning Commission, and elected City Council Members to apply due diligence towards addressing the many issues this project presents and assuring that the interests of Grass Valley are fully protected. Our City- specific concerns are detailed here. An Economic Study is Essential We implore the City to request an economic study. Numerous realtors have stated that the mine will have a significant negative impact on residential home prices throughout the region. Already, just the permit application for the mine has caused housing prices to slump in the area of the mine and several owners have stated that they will move out if the mine is approved. [1] This is not surprising. People have moved to the neighborhoods surrounding the Brunswick site for the serene rural residential atmosphere. Consider driving past a 30+ acre gravel dumping and grading operation up to 90 feet high and the proposed massive 122,000 sq ft industrial facility on the way to your home. Then you would get to listen to grading and compacting equipment run every day. Or perhaps you are considering buying a home in the new Loma Rica project where you will have to drive by the 44 acre gravel operation along Idaho-Maryland Rd. Economic impacts may extend far beyond local residential housing prices. As in the case with the previous mine application, local high tech businesses may be forced to close or move out of the area due to several factors, including the impacts of vibration on sensitive equipment, the difficulty im recruiting and retaining highly trained employees from out of the area, a degradation of the aesthetic appeal of living in a quiet mountain community, and the impacts of worsening air quality due to emissions and fugitive dust from mining operations. Health impacts from poor air quality will be exacerbated by the cumulative impacts of up to 100 daily truck round trips, grading equipment operating daily to spread and compact the two large “engineered fill” pads that are proposed, and other sources including chemical emissions from ammonium nitrate blasting operations, sulfide processing, etc. The economic cost from the loss of wells can potentially include over 300 private business and residential wells that sit above the 2585 acres of mineral rights that Rise Gold may mine, and dewatering may affect wells well beyond the boundaries of the mineral rights. And at some point, as always, the mine will close and we will be left with the pieces. There are financial risks to the City in terms of infrastructure costs, possible failure to perform mitigations or conditions on the part of the mine operators, emergency services, bond insufficiency, etc. Will adequate safeguards be put in place to protect the City and its residents? Granted, there may be new jobs. Unfortunately, most of the jobs require mining related skills, so there will have to be an influx of people to fill those needs initially. In the long run, will the number of jobs in our area actually increase, or will the other impacts and loss of small businesses create a net job loss? There will be a lot of construction initially, but will the loss of construction in the housing market due to depressed prices result in a new long term loss of construction jobs and less new housing? If an economic study shows that the mine would hurt the community, and the county decides to approve the project, what recourse would the city have? These are all very important questions that should be answered. It is for that reason that we strongly urge the City to request an economic study as part of the Idaho-Maryland Mine permitting process so that decision makers and the public will be able to make an informed opinion. The Centennial Cleanup Is A Significant Concern The Department of Toxic Substances Control (DTSC) is the lead agency in a current cleanup project (referred to as the Centennial site) on the 56 acre former Idaho-Maryland Mine site on Idaho-Maryland Road and Centennial Drive. This is a separate project from Rise’s application to reopen the Idaho- Maryland Mine, which will be operating at a new location on Brunswick Road. Rise Gold entered into a “Voluntary Agreement” with the DTSC in order to avoid listing this property as a superfund site. [2] The Voluntary Agreement is a signed and sealed contract binding Rise Gold (aka Rise Grass Valley) to complete the cleanup under the DTSC supervision. [3] The Preliminary Endangerment Assessment (PEA) for the project has been completed and now the Remediation Action Plan (RAP) is being prepared.[4] A separate CEQA process will ensue. Soon, a Notice of Preparation will be posted and more project details will be available. It is important to note that cleanup of the former 56 acre site is required regardless of the decision on reopening the Idaho-Maryland Mine. What is known: As stated in the PEA, there are approximately 270,000 cubic yards of legacy tailings covering the Centennial site at various levels of contamination. As stated in the staff report (pg 14, pg 16) these tailings must be removed before any “engineered fill” can be deposited. The suggested solution is that these tailings will be mixed with the 1000 tons/day imported waste rock and tailings from the Rise mine project and used as part of the engineered fill. Or, if they are too contaminated for that, they will be sequestered in a pile and capped, never again to be disturbed. More testing will be needed to determine the actual volume of highly contaminated material. Obviously, the 270,000 yards of old tailings materials cannot be mixed with imported new mine waste if the mine isn’t operating to produce that waste. Also, there is potentially additional contamination of the underlying original soils and bedrock. And would the imported mine waste also have contamination to levels of concern? Clearly, the situation is complicated. The final phasing of the cleanup may significantly impact the proposed import of new mine waste to the Centennial site. It is critical that the cleanup operations be completed and that the Centennial site be left in an acceptable state regardless of whether the mine is approved or not, and regardless of whether the mine fails financially at some point along the way. There is concern that Rise may end up depleting its funding to get the mining permit approved while delaying the cleanup process, possibly leading to corporate bankruptcy before the cleanup gets completed. The DTSC was only recently even made aware that the “engineered fill” that was proposed to be used for mixing with the legacy tailings is in fact mine waste. [5] For each possible scenario of phasing with respect to the cleanup project, some provision should be made for the phase of the mining project. In other words, if the cleanup is taking place but the mine project isn’t approved, a reclamation plan that does not involve bringing in waste rock and tailings from the Rise mine project needs to be prescribed. Or if the mine is approved and producing waste rock but the cleanup project is delayed, a provision for transporting the mine waste to some other site needs to be prescribed. Impacts of each phase need to be addressed, as for example, transport of mine waste to another location will affect traffic, road conditions, dust and other associated impacts. The City should be concerned about the location and profile of contaminated legacy tailings that are to be sequestered on site and capped. Is the location a suitable one when considering the long term usage scenarios of the site? What methods will be used to provide continuous monitoring and maintenance of the contaminants to prevent erosion or leaching, etc? Will the new mine waste create a new problem for future use? Is it acceptable to have a 33% slope on the fill area? The City should be concerned about the details of the engineered fill profile and future land use scenarios. Centennial Zoning Issues The DTSC and Nevada County Planning are designating the 56 acre Centennial site “Industrial zoning” because the County has it shown that way. However, the LAFCo designation and City of GV have pre- designated the Centennial site as Business Park (BP) and Urban Medium Density Residential (UMD). If the cleanup is done to industrial standards as currently proposed, it may be unsuitable for use as BP and UMD usage. Therefore, if the city ever wants to use any portion of this land for BP or UMD, the level of cleanup that is done now needs to be up to the standards for BP and UMD. Otherwise, the higher level of contamination that is acceptable in industrial land will limit the City’s ability to use the land as planned. A change to the stricter criteria for acceptable BP and UMD contamination levels should be immediately requested to preserve the ability to use the land as planned. Otherwise, a defacto zoning change will take place outside of normal zoning change processes. Note that the Nevada County General Plan Policy 1.8 allows Grass Valley to determine the designation. Someone representing the City just has to raise the point. Is the City going to request the change to BP and UMD? Annexation for the 56 acre Centennial site is long overdue. City annexation would provide the city with the appropriate full control of all aspects of the land use. Has the decision to not annex been formally made? If so, what was the basis of the decision to not require annexation at this time? Hazards 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. These explosives will be transported on local highways and roads to the site. Up to 28,000 lbs. of explosives will be stored onsite underground. Diesel fuel storage will consist of a 30,000 gallon above ground storage tank. A number of other chemicals will be utilized for processing the gold using the sulfide flotation system and other activities. Emergency responders will need MSDS sheets and information on locations and manner of storage of all chemicals on site, including those used in drilling, water treatment, gold extraction and so on. Additional first responder training and support systems will be needed. Traffic To move mine waste to the Centennial site, the plans indicate that haul trucks would be making an average of 50 round trips daily (up to 100 max), exiting the Brunswick site with a left turn onto Brunswick Rd, passing the East Bennett Rd intersection, and then turning left on the steep downhill stretch of Brunswick to enter Whispering Pines. Is this acceptable? Only 11 years are allocated to haul via Whispering Pines to the Centennial site or to be dumped onsite at the Brunswick site. For the remaining 69 years, trucks would haul via Highway 49 by entering Glenbrook Basin. Is this acceptable? How will this impact traffic on Brunswick Road at the proposed intersection for the Loma Rica SDA and the Sutton Way intersection, for example? A full traffic study should be conducted under the guidelines of the City’s current needs and long term planning, not the County’s. Trail The City is currently in the design and engineering phase of construction of the Wolf Creek Trail. Wolf Creek and the proposed trail pass through the Centennial Site. The proposed project must indicate how it will enable and enhance the City’s plan to create a public trail, with an improved riparian habitat, along the Wolf Creek/Idaho Maryland Road corridor. Other Additional concerns are listed in the CEA Foundation NOP comments which were submitted to the County and are provided as a supplement to this document. As guardians of the health and well-being of Grass Valley, we implore you to seriously consider each concern listed in this document and its ultimate impact on the community which you represent. Thank you, Ralph Silberstein, on behalf of CEA Foundation A local resident conducted an informal survey of well known and large volume realtors in the area and asked for their professional opinion as to the impact. He contacted multiple local realtors with multiple firms. 100% of them agreed it would have a negative impact on values. A well know realtor at Century 21 said that in her professional opinion “reopening the mine depending on the property, could reduce values near the mine by from $50,000 to $100,000 or more”. Others estimated the reduction in terms of 20% to 25% or more. A realtor at Coldwell Banker said “While it would impact the properties close to the mine the most, it would negatively impact all property values in the area. I’ve had multiple potential buyers decide not to purchase here at all when they learned the mine could reopen”. “The same home in a nice area compared to one next to a railroad track would have far different values. No one wants to live next to a mine” said another agent. “The most important factors in values are “location, location, location. Next to a mine is not a good location”, several others stated. Another realtor told us “We had a property in escrow recently, but the sale fell through when the buyer found out that the mine could reopen”. (Contact names available upon request.) US EPA Transmittal of Preliminary Assessment Report,Sept 26, 2019; https://www.envirostor.dtsc.ca.gov/public/final_documents2?global_id=29100007&enforcement_id=60472136 Cleanup Agreement, Signed by RISE Aug 13, 2019; https://www.envirostor.dtsc.ca.gov/public/final_documents2?global_id=60000716&enforcement_id=60458269 Link to PEA: https://www.envirostor.dtsc. Per email correspondance with Dean Wright, Aug 17, he states “I am not aware of any plans for new tailings or waste rock to be added to the Site. Several of the remedies being looked at include a “cap” of clean soil but it’s not yet known where that material will originate. Regardless of it’s origin, any material brought on site will be sampled to ensure it meets required standards.
- Idaho-Maryland Mine Mineral Rights Map
Wondering where the Mine is? Are the mineral rights under your feet? Check out these helpful maps. General map Parcels in the vicinity of the mineral rights area 1. The mine would be located at two sites; the Brunswick Industrial Site is 119 acres, at the junction of East Bennett Street and Brunswick Road and along Brunswick Rd. This is where the ore processing facilities and mine access shafts are planned. The second, 56-acre Centennial site, which was the site of the old Idaho-Maryland Mine and processing facilities, is along Idaho-Maryland Rd, east of Centennial Drive. The underground mineral rights cover a huge area, about 2585 acres. These mineral rights extend west under Highway 49 and completely under Sierra Nevada Memorial Hospital, east of Brunswick Road under the Nevada County Airpark, north as far as Plaza Drive near apartments and senior care facilities on Sutton Drive, and to Highway 174 and much of Cedar Ridge. The subterranean mining operations can potentially include all of this area and to within 200 feet of the surface. 2. The map below show parcels in the vicinity of the mineral rights area. The black line shows the mineral rights boundary. Dark red indicates parcels within 1000 feet. Aqua shows parcels within a half mile. Parcels with wells have a heavier gray border than parcels without wells. To zoom in, download the PDF below the map.
- Fast Facts: Aesthetics
Many people are concerned about the impact of the reopening of the mine as it relates to aesthetics. Here are a few facts pulled from Rise Gold's application materials. A large build up pad of “engineered fill” composed of mine waste rock and tailings will be created at the Centennial site, covering 44 acres of the 56 acre site. Industrial buildings covering 122,000 square feet are proposed for the 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 foot long enclosed conveyor system. Tailings will be stockpiled onsite while waiting for transport. "Subjective" The reports descriptions of the viewsheds are in their owned words subjective. The Aesthetics Technical Study includes both the IMM site and the Centennial Industrial Site The Photographic Simulations are powerful. Those that stand out are View Point 1&2 (view from Sierra Nevada Memorial Hospital looking toward Demartini RV Sales and View Point 8 (post fill at the IMM site from the Brunswick entrance.) In both cases the post fill dominates the viewshed. Approximately 1.6 million tons of fill will be placed at the Centennial Site and 2.2 million tons of fill will be placed at the Brunswick Site Regarding reclamation: “The Brunswick and Centennial Industrial Sites fill slopes will be revegetated with an erosion-control seed mix to reduce erosion and maintain fill slope stability. The fill pads will be maintained until they are used or sold for future industrial purposes.” i.e. a dead zone [1] https://www.mynevadacounty.com/DocumentCenter/View/31023/Applicants-Project-Description, pp. 16-17, Nov 2019 [2] https://www.mynevadacounty.com/DocumentCenter/View/31023/Applicants-Project-Description, pp. 17-19, Nov 2019 [3] Introduction, https://www.mynevadacounty.com/DocumentCenter/View/33582/Aesthetics-Technical-Study---Added-3-9-2020 [4] 2.1 Overview https://www.mynevadacounty.com/DocumentCenter/View/33582/Aesthetics-Technical-Study---Added-3-9-2020 [5] 3.3 Photographic Simulations https://www.mynevadacounty.com/DocumentCenter/View/33582/Aesthetics-Technical-Study---Added-3-9-2020 [6] Project Description pages 15 and 16 "Centennial Industrial Site" and "Brunswick Industrial Site" [7] Groundwater Hydrology and Water Quality Analysis Report – Added 4/24/2020
- The long haul: Reports focus on Idaho-Maryland Mine’s impact to roads, noise, property values
Truck traffic is a big concern if Rise Gold reopens the mine. This Union article by freelancer, Shira Moolten, takes a closer look at claims and concerns about traffic, road quality, noise, property value, and environmental impacts. She includes some insightful quotes from Sierra Fund's CEO, Elizabeth "Izzy" Martin. If the Idaho-Maryland Mine reopens, haul trucks will become a familiar sight on Grass Valley roadways for the next 20 years, according to project plans submitted by Rise Gold Corp. to Nevada County. The trucks will make up to 100 trips a day, averaging 50, from 6 a.m. to 10 p.m., seven days a week. They will be transporting engineered fill, or barren rock and sand tailings, generated from tunneling underground. The proposed plans designate two routes for the trucks: one route between the Brunswick and Centennial sites, along Brunswick Road and Whispering Pines Lane; and one route between the Brunswick site and Highway 20/49, along Brunswick Road, for engineered fill to be delivered to potential customers. The Centennial site, where engineered fill will be used as part of a restoration project, is expected to take five years to complete, during which time the trucks will be divided between the two routes. For the next 15 years, the number of trucks on the road will not decrease, but will move entirely to the Highway 20/49 route. For many, the trucks represent one of the key issues surrounding the reopening. MineWatch Nevada County has listed the trucks as one of its eight main reasons to oppose the mine. “I think the trucks would be the most egregious, worst thing we’d notice right away,” said Elizabeth Martin, CEO of the Sierra Fund and former member of the Nevada County Board of Supervisors. Whether they’re the biggest concern, she said, depends on where someone lives. “If you use those roads all the time, it will be the only thing you’re upset about,” she said. “If you don’t use those roads as much, but your well has gone dry, well, that will be the thing.” The evidence so far is mixed... Shira Moolten, freelancer for The Union Read the rest in The Union -- then check out the following response by Donald Rivenes - I Have a Different Understanding, dated September 15, 2021: A recent article in The Union by a freelancer contained statements that were wrong. First, engineered fill from the Rise Gold mine is not part of a restoration project. Fill is proposed to be put at the Centennial site after completion of an independent voluntary toxic cleanup project at Centennial. The article said: “The Centennial site, where engineered fill will be used as part of a restoration project …” Second, haul trucks would be going down Brunswick Road toward Highway 20/49 for 70 years, not 15 years. The February 2020 Rise Gold Air Quality report indicated that in regard to long-term operations, engineered fill would be trucked to the Centennial industrial site for five years, to a pad at the Brunswick industrial site for five years, and off-site to support local construction projects for 70 years. The Union article said: “The Centennial site … is expected to take five years to complete, during which time the trucks will be divided between the two routes. For the next 15 years, the number of trucks on the road will not decrease, but will move entirely to the Highway 20/49 route.” Please set the facts straight on this important issue. Donald Rivenes
- Fast Facts: Impact on Endangered Species
If the Idaho-Maryland Mine reopens, the Centennial site that harbors the endangered Pine Hill flannelbush and other plants will be impacted by planned engineered fill operations. A population of Pine Hill flannelbush ( Fremontodendron decumbens) exists on site and is listed under the federal Endangered Species Act (ESA). “Of the sixty individual mature and flowering Pine Hill flannelbush plants identified within the Centennial Industrial Site, it is estimated that 18 mature plants will be removed as part of the placement of engineered fill. The take of such ESA listed plants will require mitigation and consultation with USFWS.” With respect to mitigation by transplanting of the PH Flannelbush: “metrics of successful establishment, which would include a minimum of 80% survival of the transplants after 2 years of transplanting the species.” And additional restrictions apply. Note that adjacent habitat is needed for protection of the PHf. “The recovery plan for Pine Hill flannelbush (USFWS 2002) reports that the habitat in which this plant occurs is naturally and artificially limited, and conservation of not just the populations, but adjacent vacant habitat is beneficial to long-term persistence. Location of Pine Hill Flannelbush Occurrences overlaying an aerial photo Centennial site topo map of Engineered Fill with Pine Hill flannelbush locations shown [1] www.mynevadacounty.com/DocumentCenter/View/30464/Centennial-Industrial-Site---Impact-Assessment-Technical-Memo (See also Review Summary on centennial Impact Assessment Tech Memo)
- Centennial site needs cleanup
October, 2020 Listen to Barbara Rivenes from the Sierra Club as she explains the EPA's requirements for cleaning up Centennial site and how that relates to the proposed reopening of the Idaho-Maryland Mine. From a CEA Foundation virtual community meeting. Transcript below. UPDATE: The Remediation Action Plan (RAP) for the Centennial Site is now expected to be released in the Spring of 2021. Hi and welcome. Greetings to you all. I'm here tonight to talk on behalf of Sierra Club as well as - I'm a CEA board member. My topic is the Centennial M1 industrial site. That is one of the two sites purchased by Rise Gold for this project. Did you all know that the state of California has over 40,000 abandoned mines? The Centennial site ranked first as the top priority abandoned mine by the EPA, because of the proximity to our communities and also because of the known contamination and physical hazards that are on the site. This Centennial site located near downtown Grass Valley off Idaho-Maryland Road near Ferguson's Plumbing. It’s a historically toxic site that is facing EPA Superfund designation. This site is 56 acres with two-thirds of the site covered with tailings from the Idaho-Maryland Mine, which operated until 1956. Though it was much quieter during the war and afterwards, in fact it then closed in the mid 50's. There is an estimated two hundred and seventy thousand cubic yards of legacy tailings which are toxic, which have to be removed in order to use the site for new dumping or placing new mine waste. The superfund designation has been conditionally deferred for the time being because Rise Gold signed a contract with the California Department of toxic substance controls to clean up the site. But it's important to understand that these are two completely separate projects at this time. During the Idaho-Maryland Mine NOP process in the summer of 2020, CEA asked the county to include the cleanup in its EIR…truly because the Centennial Site is an integral part of the mine project and needs to be remediated before the rest of the project can proceed. That's an important point. We have to get it cleaned up and our leadership needs to understand that it has to be remediated. Currently, the department of toxic substance control have just given Rise Gold a timetable of their cleanup process which suggests that it will not be until early 2021 when reclamation work can actually begin. Cleanup costs are still unknown, but even by reasonable estimates, it could be put at over two million dollars. Centennial will have its own environmental impact report with negative deck before the actual cleanup begins. Its slated to begin this fall. That's when the process of the EIR for that particular remediation will go on and the public will have a chance to talk about it. And then by the time they get all of that finished, then the work will not be finished - they’ll work through the winter and then will not be finished until the spring. The DTSC is not looking for the overall mine project since it's outside their scope of work at this time. However, it was brought to their attention that a very large volume of mine waste will ultimately be brought in from the Brunswick Mine Site. The Centennial site, once it's cleaned up, will actually be the recipient of 1,040,000 engineered fill, reaching a height of 30 to 70 feet above the current ground level. Bear in mind that 10 feet is the standard height for a one-story building. Therefore, we face the possibility of seeing anywhere from three stories to seven story buildings. That sort of bulk in that area. The zoning of the site is M1, which is light industrial, which is the county zoning. Centennial site is in the Grass Valley sphere of influence for future planning. Grass Valley’s planned sphere of influence zoning is business park, keeping with the rest of the Whispering Pines Business Park and surrounding neighborhoods. Rise Gold has asked the county for a rezoning for both sites combining M1 with ME, which will allow mineral extraction (ME), which will allow processing, stockpiling of mine minerals, waste disposal, and the reclamation. Right now, there is no ME attached to that. That is something that the county will have to approve – and Rise Gold has asked for – we'll see what happens with that. Rise Gold has not requested that Centennial be annexed to Grass Valley as part of the sphere of influence. Their project would not fit very well into the land use zoning of the Whispering Pines Business Park. It's very important for us to realize that these are being treated like two separate projects, but they really are one project. One cannot go forward without the other. Well, Centennial could get cleaned up of course, but the mine cannot go forward. It needs a place to put all those tailings. 1,040,000 of them. Thanks for listening. In conclusion, I’d like to take a moment to show you a quick map. Just to make it come home. The Centennial site is right up there off of Idaho Maryland Mine Road. Not far from downtown Grass Valley. Not far from the hospital. And yeah, it's a toxic site and it needs to be cleaned up. We can't depend on the approval of the mine project - the larger mine project to do that. Thank you for listening.
- CEA Comments on Centennial Cleanup Plan
We all want the Centennial Site cleaned up, but the proposed plan only prepares the site for dumping more mine waste and wants to destroy habitat over sensitive areas. We can do better. The following comments were submitted to the Department of Toxic Substances Control by Community Environmental Advocates Foundation. These comments are the result of a coalition effort that included the Wolf Creek Community Alliance and the Redbud chapter of the California Native Plant Society. In addition, CEA Foundation's law firm, Shute, Mihaly, and Weinberger, provided extensive legal comments. Learn more about the entire project here. September 24, 2021 Dean Wright Project Manager 800 Cal Center Drive Sacramento,CA95826 (916) 255-3591 dean.wright@dtsc.ca.gov Reg: Comments regarding the Centennial M-1 RAP and MND, Project ID 60000716 Dear Mr. Wright, Community Environmental Advocates Foundation (CEA Foundation) has been looking forward to the opportunity to fully support the cleanup of the Centennial site. This 56 acre site is only a short distance from town, and with good planning it has the potential to be developed to support smart growth within a walkable community. The central and southern portions of the property would be ideal for mixed use and medium density housing, providing a rare opportunity to meet some of Grass Valley’s housing needs as well as business and light industrial development within convenient live/work settings. It could ultimately tie in to residential development along East Bennett Rd with easy walking/cycling opportunities along East Bennett Rd and along Wolf Creek. Unfortunately, Rise Gold (dba Rise Grass Valley) has seemingly sought to use this cleanup project as a means of incorporating many of the impacts of the proposed mine. In addition to the required cleanup activities, the Remedial Action Plan (RAP) and Mitigated Negative Declaration (MND) include preparation of the site for the dumping of mine waste. Thus, rather than minimizing the destruction of valuable wetlands and riparian habitat, the RAP proposes to destroy all habitat over extensive areas. This constitutes impacts far and above what would be necessary to simply complete the cleanup. Therefore, we cannot support the project as currently proposed. Impacts caused by the mine project should be borne by the mine project, not the cleanup project. 1. An Environmental Impact Report should be prepared for this project As presented in the RAP, all living things over a 37 acre site will be annihilated, and all surface soils will be reworked, mixed with crushed rock and compacted. The project will cause the destruction of all of the 4.35 acres of wetlands, 0.6 acres of seasonal streams and surrounding riparian habitat, woodlands, chaparral, grasslands, plus potentially cause long term impacts to local surface and ground waters, air pollution from equipment operations and fugitive dust. noise, traffic, and aesthetic degradation. On this basis alone there is a fair argument that the project may have a significant effect on the environment and an Environmental Impact Report is required. 2. None of the proposed Remedial Action Alternatives provide for preservation of ANY of the viable wetland habitat. As shown on the project “Site Map” (RAP Sheet 1, pg 131),most of the wetlands are located within the areas designated as “Borrow Areas” (RAP Sheet E2, pg 539). The soils within these areas are considered clean enough to be used as clean cover soil for the Encapsulated Mine Waste Area and areas C1-C15 and is indicated on the grading maps (RAP pgs 537-540). In other words, the reason for removing most of the wetlands and surrounding habitat appears to be simply to provide clean cover soil over the areas of treatment. None of the proposed remedial actions provide for preservation of any of the viable wetland habitat. The following Remedial Actions Alternatives should, at the very least, be evaluated: A. Sourcing the clean cover soil entirely from off site to eliminate the need to excavate on site soil from Borrow Areas and other non-contaminated areas. B. Identify and assess preservation of regions of the wetland habitat where feasible, such as the WTP Remainder area, and source a portion of the clean cover soil from off site to make up the difference. C. In all Remedial Action Alternatives, minimize the impact by removal of surface vegetation in incremental steps until cover soil needs are met, concentrating on deeper soil areas and minimizing biological impacts. Since not all of the designated areas may be needed, this would reduce the impact. Finish grading can be modified to accommodate this approach. 3. No evaluations of the impacts based upon the City of Grass Valley’s Land Use Designations, Zoning, Development Code, or Public Works plans were provided. The site is within the Sphere of Influence of the City of Grass Valley, slated for “Near Term Annexation”, and adjacent to the City on three sides. The DTSC should evaluate the project with respect to the following City issues: a. City of Grass Valley and LAFCo have the property designated as Business Park (BMP) and Urban Medium Density (UMD). Some analysis of this impact should be provided. In particular, some effort to not artificially constrain the potential best uses of the land should be made. For example, according to the RAP, a large portion of the 56 acre site is currently suitable for "unrestricted use". With the exception of a few hot spots, this includes much of the southern and western portions of the 56 acres. The RAP should aim to delineate between the areas which are suitable for unrestricted use, and those that are not, and it should plan to designate those areas in a such a way as to avoid unnecessarily limiting the potential uses of the entire parcel. For example, the southern portion of the Encapsulated Mine Waste falls within an area designated for UMD land use. Why not modify the encapsulated area slightly to avoid limiting that future intended use? A justification for not doing this should be provided. b. The analysis of “Aesthetics” for the project did not consider the City’s standards. However, it is the City that is surrounding much of the property and being directly impacted. The Aesthetics should consider the impacts to the City by City standards in addition to County standards. c. Similarly, analysis of noise standards should be based on the City’s standards in addition to County standards. d. Impacts on City infrastructure should be evaluated. For example: Does the proposed location of the Encapsulated Mine Waste impact potential Centennial Drive realignment plans, utility service line plans, and drainage plans? Will the plans for encapsulation fully allow for the City to realign the Springhill/Centennial intersection? The City may wish to evaluate the grade and location of the capped materials, recognizing possible conflicts of the encapsulated materials with the need for road development, utility trenches, pole placement, etc. in the future. e. How does the proposed plan impact the Wolf Creek trail project? 4. The RAP is apparently based upon the presumption that the parcel will ultimately be used entirely for dumping mine waste, followed by Industrial development. The current owner, Rise Gold clearly plans to use the site for dumping mine waste. However, there is no assurance that the mine will be approved, or that the plans for dumping on the Centennial site will be a part of the mine project if it is approved. If the RAP is intended to prepare the site for dumping of mine waste rock and tailings from the proposed Idaho-Maryland Mine, then this RAP should be incorporated in the Mine project application and Environmental Impact Report rather than treated separately. Otherwise, the cumulative impacts of the Mine project will not be adequately evaluated. But in any case, alternatives for cleaning up the site in the event that the mine is not approved must be provided. 5. The location of the encapsulated material creates potential problems for long term stability a. There exists a culvert under the built up gravel road berm on the east boundary that drains from the legacy pond to the East. The plan is to extend that culvert under the encapsulated material. It includes a transition from the existing box culvert to a round culvert, and a sharp bend in the planned culvert. This seems like a bad approach that is prone to failure in the future. b. The hydrological transmissivity of the built-up gravel road berm along the east boundary needs to be assessed. Horizontal water migration from the pond that is to the east may compromise the encapsulation, cause leaching of the encapsulated materials. Was the berm tested for transmissivity? 6. Impacts to a seasonal creek flowing from North-West property corner are not evaluated. The “Existing Drainage Culvert” system shown on RAP Figures 5, 6, and Sheets E1, E2, E3 is discontinuous and has not functioned correctly for many years. Currently, most of the Centennial site drains from the Northwest corner of the site into the Historical Drain Towers and through a culvert. But it then discharges to the surface at the North side of the paved Di Martini access road. A portion of the original drainage system, an old, damaged 4 ft. culvert, lies across a gap, about 4 feet away from the outlet. As a result, from this point, the creek runs on the surface approximately 75 feet to Wolf Creek. This seasonal creek also appears to support two small wetlands. During high water, a small fraction of the flow does enter the 4 ft. culvert and discharge to the point designated as the “Surface Water Discharge Point” on the plans, but it functions only as a partial discharge point during high flows. The proposed uniform grading would dry up this creek and wetlands, and impact riparian habitat. This needs to be evaluated. 7. Further assessment needed at the Hap Warnke site Mercury was listed as a Constituent of Potential Ecological Concern (COPEC) at the Hap Warnke Lumber Mill (HWLM) site. Considering that the site will be ideal for future development, existing degraded paved surfaces should not be considered as sufficient long term protection from exposure or mobilization. 8. Public Records were not made available Despite a Public Records Request submitted by CEA Foundation for access to all public documents relating to the Centennial project, many documents were not made available for review. These include supporting technical studies such as the Asbestos Dust Mitigation Plan, technical comments that were submitted regarding the Preliminary Environmental Assessment (PEA), and relevant facts that were provided regarding City of Grass Valley Land Use designations. 9. Avoid wetland mitigations by off site wetland creation or restoration Wetland mitigations by off site wetland creation or restoration is a poor substitute for preserving wetlands on site and avoiding the elimination of valuable habitat. If off site mitigations are utilized, they should be fully evaluated and should be at least a 2:1 replacement. A map that shows the areas of disturbance should include the biological features. In particular, protection areas for wetlands and special species habitat such as the Pine Hill Flannelbush should be clearly delineated on the map which shows disturbance areas. 10. Additional information for inclusion in the RAP Rise Grass Valley is a wholly owned subsidiary of Rise Gold Corporation, a Canadian based corporation with main offices in Vancouver, BC, but registered in Nevada. Provide a clear delineation of which portions of the 56 acre site will be protected from disturbances Cement used in Encapsulation Areas for stabilization should be certified as free of hexavalent chromium. The statement “Nevada Irrigation District (NID) uses Wolf Creek downstream of the site as a waterway to transfer water between its canals and water distribution system.” is not correct.” (RAP pg 9) The NID canal water enters Wolf Creek above the site, near Sutton Rd, and increases the flow along the site during the periods of conveyance. This information was provided previously in PEA comments. Thank you for your consideration of these points, On behalf of the CEA Foundation Board of Directors Ralph Silberstein, President CEA Foundation
- Julie Becker: Clean up the Centennial site responsibly
Local resident, Julie Becker, takes issue with Christian Stewart's opinion piece criticizing the Community Environmental Advocates’ response to Rise Gold’s Centennial cleanup project. In order for Rise Grass Valley (or Rise Gold) to reach the point of reopening the Idaho-Maryland Mine, they first have to clean up the Centennial dumping site — a site near Centennial Drive where toxic mine waste was deposited many decades ago. In a recent Other Voices column, “Enviros would stymie cleanup,” the author smears the intent of Community Environmental Advocates, claiming the group is railing against rehabbing the site in a responsible way — a claim that is way off base. The Remedial Action Plan that Rise Gold presented to the Department of Toxic Substances Control is seriously flawed and unsuitable — calling for the destruction of healthy wetlands, riparian areas, and native plant communities that cover close to 70% of the whole site. Read the rest in The Union. Julie Becker lives in Nevada City.
- Deni Silberstein: CEA favors Centennial cleanup, done right
Local resident, Deni Silberstein, takes issue with Christian Stewart's opinion piece criticizing CEA’s response to Rise Gold’s Centennial cleanup project. Read in The Union. In a recent Other Voices column, Christian Stewart expressed his opinions about Community Environmental Advocates’ response to Rise Gold’s Centennial cleanup project. CEA spends untold numbers of volunteer hours combing through hundreds of pages of technical documents, teasing out the facts — not the opinions — of what Rise’s plan for the reopening of the mine will look like, and discerning what will be its impact on our community. Here are a few examples of Stewart’s opinions, and the corresponding facts: 1. “Rise has proposed to pay for cleanup” of the Centennial site. FACT: The Centennial site will be used as a dumping ground for Rise Gold’s mine waste. But since that site is polluted from previous mining dumps, Rise must clean it up before they will be allowed to dump their own mine waste onto it. Cleaning it up is a state mandate; it’s not something Rise “proposed” to do out of the goodness of their heart. 2. “No mining is proposed at all for Centennial.” FACT: It’s disingenuous to say that “no mining is proposed” for the Centennial site — for up to five years, that site will be used, exclusively, for the dumping of Rise’s mine waste until this waste is a 70-foot high pile of rocks. At the end of this time, commercial development may occur atop this rock pile. 3. “CEA has come out against the environmental cleanup process at Centennial.” FACT: CEA is definitely not against the cleanup. CEA is definitely in favor of the cleanup. As mentioned in a previous comment, what CEA is against is the illegal use of the cleanup as a cover-up for the environmental damage that the dumping of Rise Gold’s mine wastes will cause to the Centennial site. In other words, Rise is attempting to subsume mining activities under the masquerade of the cleanup project in order to avoid having to conform to the California Environmental Quality Act. This is illegal, and lawyers have submitted a 25-page document outlining the many laws that Rise will be violating if it proceeds with the cleanup as proposed. Does this mean that Rise either needs to take the time to write a legal cleanup proposal that eliminates the site as a dumping ground for mine waste, or else take the time to include the Centennial dumping site as a component of the mine’s general, CEQA required, environmental impact report? Yes. Doing things correctly often takes more time than not. 4. Stewart says that CEA claims the Centennial site is a “protected natural resource critical to a functioning watershed.” FACT: This is true. The site is “protected” in that it is an area deserving of a fair analysis under CEQA. To disagree with this truth shows either a lack of understanding about the importance and necessity of healthy watersheds, an indifference to them, or both. 5. Stewart claims that a campaign is under way to “save the historic tailings pond.” FACT: CEA is not involved in a “campaign” to “save the historic tailings pond” except to the extent explained in No. 3 above. It is worth mentioning, however, that these tailings ponds, which killed and polluted the entire area for the decades that followed, are slowly beginning to recover. And since these damaged wetlands are all that previous mining activity has left us, it would be beneficial to the watershed to minimize additional man-made damage to them, and let them get on with their recovery. 6. The mine is the “biggest economic development project this county has seen in decades.” FACT: This is an overly-simplified understanding of what is needed for a healthy, foothill economy. CEA recommends reading a summary of the economic study done for the 2008 mine proposal (www.cea-nc.org/the-idaho-maryland-mine/impacts-to-jobs-and-housing-from-the-proposed-idaho-maryland-mine/), which indicates that a mine may not be the best business for the local economy, then waiting to see what the newly agreed upon economic study will reveal. 7. CEA is trying to kill the cleanup process of a “blighted site in the heart of our community.” FACT: See No. 3 above. In addition, CEA completely agrees that this “blighted site” is in the heart of our community, which is why CEA is working hard to prevent another mine from continuing this blighting of our community’s heart. 8. “CEA are NIMBYs enabled by CEQA.” FACT: When it comes to Canadian mining companies ripping up the heart of Grass Valley, then, yep — we’re NIMBYs! And thank goodness for CEQA! Deni Silberstein lives in Grass Valley.
- Jan Weaver: School busses passing proposed mine
Local resident, Jan Weaver is concerned about the Mine's impact on our children. This letter to the editor was originally published in The Union. The version below has been updated slightly for accuracy and clarity. Feb 1, 2023 I was driving down Bennett going towards the purposed Gold Rise Mine, passing the Durham Buses. Not sure if this has been raised as an issue, but these same buses, transporting our children, will be passing the mine daily. They will interact with trucks full of toxic materials. It is estimated that up to 100 trucks will be traveling to and from the mine site. It’s probable that it will take longer for the buses to get to the intersection at Brunswick. This intersection has a flashing red light, making every motorist come to a complete stop. Buses schedules are carefully planned out to ensure that the students arrive prior to the start of school. This could affect the school’s start time and bus schedules could need to be re-worked, making the school day longer. This doesn’t take into account any issues with the mine trucks themselves. It is purported that some of the trucks will be carrying explosives, while others will carry rock mine waste with worrisome levels of asbestos and silica. Although the mine will be taking precautions to reduce our exposure, we know that some of the toxin dust will be allowed to escape into the air our children will be breathing. We need to take the future of our children into account when deciding to open this mine. Jan Weaver
- John Vaughan: The tale of a wolf, and a gold mine
This delightful fable reveals the absurdity of the Rise Gold's financial promises. Vaughan is a retired CIO of Pride Industries. This opinion piece was originally published in The Union. January 31, 2023 I’m going to tell you a story. It’s a bit whimsical but I assure you the numbers are real, directly from the recently published “Economic Impact of the Proposed Idaho-Maryland Mine”. Once upon a time, there was a small idyllic community in the foothills of Northern California. The community attracted lots of visitors, many choosing to stay and raise their families, start their own small businesses, or retire. The people of the community loved it for its natural beauty, limited traffic, and small-town quality of life. One day, a wolf arrived in the community and purchased the property and mineral rights to a long-closed gold mine. Soon, the wolf submitted a proposal to re-open the gold mine, assuring the people of the community the mine would create lots of high-quality, high-paying jobs. The wolf’s proposal included spending money on locally hired employees and local suppliers while contributing to the communities “General Fund” based on profits from the mine. The wolf’s proposal promised everyone in the community, including their children, their grandchildren, and their great grandchildren, that for 80 years the wolf’s proposal would not do any environmental damage. No air or water pollution. No bad wells. No health hazards. No traffic accidents. No contaminated mine rock that can’t be sold. Many people in the community were skeptical and worried about degraded air and water quality, bad wells, negative health consequences, lower property values and traffic – as well as unforeseen events from the wolf’s large industrial operation. Over 5,500 community members and 250 businesses signed petitions or wrote letters to the community’s Board of Supervisors documenting their concerns about the wolf’s proposal. The Board of Supervisors paid attention and sponsored an Economic Report to help the Community understand whether everyone would benefit from the mine. Unfortunately, when the Economic Report arrived, the community realized that virtually all the data used to support the reports calculations came from the wolf’s proposal, like the claim the wolf would produce 108,400 ounces of gold every year for 80 years. The wolf had no current data to prove he could achieve that, so his proposal used ancient data from the 1940’s and 1950’s when the mine last operated. The wolf’s proposal said that after everything was built and ready for production, he would spend about $68 million each year to get the gold. He knew not all the money would be spent in the idyllic community. But the wolf told the people and their leaders not to worry, the community would still be much better off. The wolf also said that when he sells 108,400 ounces of gold each year at market price, he creates about $180 million in annual revenue. Nice! The wolf’s profit from $180 million after expenses of $68 million is…wait for it…almost $112million…every year, for 80 years. Happy, happy wolf! “How much of the profit stays in our community?”, the skeptical local folks asked. The wolf just smiled and said, “Well actually, virtually all $112 million profit goes to my shareholders, but don’t worry, your community will be much better off.” Then he smiled even wider and said, “But the profit feeds the community’s property tax calculations which the Economic Report says will add about $760,000 to the community’s General Fund. Good for everybody, right?” Now, in case you are not a financial analyst, you might be surprised to learn a $112 million profit gives the wolf an astounding, virtually magical return on Investment of just over 63% for one year’s work, every year for 80 years…63%...how cool is that? Cool enough to make the wolf smile bigger and bigger! This made many people in the community even more skeptical as none of them had ever received 63% interest on their bank accounts or any other investments, and a 63% return on investment each and every year for 80 years seemed truly unbelievable. But that’s what it said in the Economic Report, so maybe it’s true. Don’t worry though, the story ends well. The Board of Supervisors were much more savvy than the wolf thought. They could see the proposed “General Fund” contributions were based on a 63% return on investment every year for 80 years, which is really and truly unbelievable, so they chose to protect their community and just said NO to the wolf’s proposal. And everyone lived happily ever after (except the wolf). John Vaughan is a 55 year resident of Nevada County and a retired CIO of Pride Industries. Vaughan was a member of the powerhouse panel of mining and business leaders who reviewed the Economic Impact Report at the MineWatch Community Meeting in December 2022. The report left a lot of room for questioning conclusions about jobs, tax revenue, and impact on property values. Watch John's (more serious) presentation. See what the rest of the panelists had to say.
- Sharon Delgado: The mine is not good for children or other living things
Historic issues with mine wastewater are paid for with both public and private funds, e.g., the Mine runoff from the Empire Mine which is now being treated by a wastewater treatment system built by Empire Mine State Park and mine owner Newmont Mining. This opinion piece was originally published in The Union. On Mothers’ Day in 2006, after my husband Guari and I had moved back to Nevada County, our grown kids and grandkids gathered at Memorial Park for a picnic. I had requested it since I had happy memories of being there at the park when we raised our children. I imagined that our grandchildren would also enjoy playing at the playground and splashing in the creek. I was shocked to see that metal fencing blocked the so-called creek. Signs warned people to stay out because it contained hazardous chemicals. What a nightmare. As it turned out, it was not a creek at all, but the Magenta Drain, which handles discharge from the Empire Mine. Some weeks afterward, I saw people in Hazmat suits working to strengthen the fence. Chilling. I thought back, remembering the kids playing in the creek and wondering what they had been exposed to and how it might have impacted their health. I still wonder what ailments might be traced back to those exposures. I know now that toxic waste at the mine included mercury, arsenic, cadmium, lead, and other pollutants, and that it flowed into Wolf Creek and other area streams, where people fish and swim. In 2014, a grand jury report found that local residents’ health, welfare, and water quality may be compromised by toxic pollution caused by the Empire Mine, Lava Cap Mine, and North Star Mine, and that for over 30 years governmental agencies failed to coordinate or properly enforce cleanup required by legal settlements and abatement orders. Mine runoff from the Empire Mine is now being treated by a wastewater treatment system built by Empire Mine State Park and mine owner Newmont Mining. In other words, it was paid for with both public and private funds. This commonly takes place with mining corporations around the world. In fact, there is often no accountability for mining corporations that pollute. Cleanup from mining operations (if it happens) is often paid for by the state. It’s called corporate welfare—private gain for corporate “persons” at the expense of flesh and blood human beings, communities, and ecosystems. For example, Rise Gold’s CEO Ben Mossman is currently on trial in Canada. He faces nine federal and twenty provincial charges related to toxic spills by his previous mining company, which polluted tribal waters, went bankrupt, and left Canadians with the costs. Naturally, we oppose the reopening of the Idaho-Maryland Mine. The Environmental Impact Report is deficient in so many ways. Members of our community have spent countless hours analyzing it and uncovering its flaws. And we have prior commitments as a community that we the people have worked hard to implement. Why would any member of the Planning Commission or the Board of Supervisors vote to approve this project, which would override and negate the stated goals of the Nevada County Energy Action Plan? I entreat each member of the Board of Supervisors to oppose it. Community members, please take this time to study the issues. Go to Minewatch at https://www.minewatchnc.org/ to find out what you can do to stop this travesty from taking place. Make your views known to the Planning Commission and the Board of Supervisors. The promises of a re-opened gold mine ring hollow considering the potential health risks, disruption of community values and commitments, damage to local ecosystems, threats of further toxicity to our children and future generations, and so much more. Our beloved Nevada County has been damaged by the toxic legacy of the Gold Rush, but there is still so much beauty and life here, so much to be saved and protected. We may think that we sit on top of the natural world and try to control it, that is not true, and the natural world is not expendable for human gain. We are part of the interconnected and interdependent community of life, and as Indigenous people have always known, what we do to the community of life, we do to ourselves.
- Legal Background Supporting Denial of Idaho Maryland Mine FEIR Certification and Project
The following background was prepared by attorneys Shute, Mihaly, and Weinberger who represent CEA Foundation on our mine project responses. The County should deny the Project and should not certify the EIR. The many environmental impacts associated with the Project, as well as its inconsistency with Grass Valley’s and the County’s land use plans provide ample justification for denying the Project. If it denies the Project, the County is under no obligation to certify the EIR. Las Lomas Land Co., LLC v. City of Los Angeles (2009) 177 Cal.App.4th 83 (upholding decision to stop preparation of an EIR and specific plan where city determined the project was not consistent with its land use policies); Pub. Res. Code § 21080 (a) (CEQA applies only to projects that public agencies carry out or approve.) Denial of the Project would also be consistent with a long line of case law recognizing that public agencies may limit the use of land to protect public values without resulting in a taking of property. Penn Cent. Transp. Co. v. City of New York (1978) 438 U.S. 104, 129 (1978) (“[T]his Court has recognized, in a number of settings, that States and cities may enact land-use restrictions or controls to enhance the quality of life by preserving the character and desirable aesthetic features of a city.”)(citations omitted); id. (“[I]n instances in which a state tribunal reasonably concluded that ‘the health, safety, morals or general welfare” would be promoted by prohibiting particular contemplated uses of land, this Court has upheld land-use regulations that destroyed or adversely affected recognized property interests.”); Tahoe-Sierra Preservation Council, Inc. v. Tahoe Regional Planning Agency (2002) 535 U.S. 302, 324 (“Land-use regulations are ubiquitous and most of them impact property values in some tangential way— often in completely unanticipated ways. Treating them all as per se takings would transform government regulation into a luxury few governments could afford.”) The Supreme Court has identified two primary tests to determine whether regulation causes a taking of property. First, a taking may occur if the regulation eliminates all use or value of the property. See Lucas v. S.C. Coastal Council (1992) 505 U.S. 1003. Under that test, there must be no value whatsoever remaining in the property; even a diminution of value of 95% is insufficient. See Tahoe-Sierra, 535 U.S. at 330 (citing Lucas, 505 U.S. at 1019 n.8). The second test involves evaluation of multiple factors, including the severity of the impact of the regulation on the value of the property, the extent of its interference with reasonable investment-backed expectations of use of the property, and the character of the governmental action. See Lingle v. Chevron (2005) 544 U.S. 528, 538-39 (citing Penn Central, 438 U.S. at 124.) Courts have consistently held that Penn Central test requires elimination of nearly all value in the property. The Ninth Circuit has recently recognized that even “diminution in property value because of governmental regulation ranging from 75% to 92.5% does not constitute a taking.” Colony Cove Props. LLC v. City of Carson (9th Cir. 2018) 888 F.3d 445, 451; see also Hadacheck v. Sebastian (1915) 239 U.S. 394, 405 (no taking despite diminution in value from $800,000 to a maximum of $60,000, and property could not be used for any purpose permitted under city's ordinance). In fact, as long as permissible uses exist, a denial would not deprive the applicant of economically viable use of its property. (Shea Homes Limited Partnership v. County of Alameda(2003) 110 Cal.App.4th 1246, 1267 [finding no regulatory taking because agricultural designation allowed single family use if certain County standards were met].) Here, the entire Brunswick Industrial Site is currently zoned M1-SP (Light Industrial, Site Performance Combining District), per the County’s Zoning Code. Its land use designation is IND (Industrial) under the County’s General Plan. The applicant is proposing to re-zone it as M1-ME (Light Industrial with Mineral Extraction Combining District) as part of the project. The Centennial Industrial Site and potable water pipeline easement areas are both zoned as M1 (Light Industrial) and designated as IND. All of these land use designations provide a reasonable economic use of the property and, on their face, defeat any claim that the applicant is entitled to establish a gold mine at the site. PRINT or share this information with others using this PDF.
- Mine Waste and the Water Pollution Problem
The Final EIR for Rise Gold’s Idaho-Maryland Mine is inadequate because it fails to address the potentially significant impact of mine waste disposal. January 10, 2023 The Mine project plans to export 1000 tons of tailings and waste rock per day. This mine waste will be dumped into 2 Engineered fill piles over the course of the first 11 years. After that, the mine waste will be disposed of through off-site sales. There are significant issues with the disposal of mine waste due to the potential to pollute groundwater and surface waters by leaching hazardous chemicals. This falls under the jurisdiction of the Regional Water Quality Control Board. The Water Board classifies mine waste by Groups A, B, and C. Only Group C, which has relatively low levels of contaminants, is clean enough to be used for off-site sales. Groups A and B require more stringent controls. The Water board requires mine waste testing to determine classification. In response to the Draft EIR, the Water Board stated: “The applicant shall not sell or utilize waste rock and tailings from the Project for construction aggregate or fill purposes offsite unless such material has been tested and confirmed to qualify as Group C mining waste...” [1] In the EIR, the Water Board and numerous other parties identified that there was insufficient testing to determine whether the mine waste would be Group C, suitable for off-site sales. Per the Water Board comments: “...the alternative scenario that the mining waste is not suitable for off-site use should be examined.” The Water Board goes on to state that Rise should assess any constraints or challenges associated with waste disposal in case they can’t do off-site sales for construction aggregate. They conclude with: “The Draft EIR should be revised to address this comment.”[3] Rise Gold acquired a collection of drill cores and samples from Emgold Mining when they purchased the mine. In addition, they did over 67,500 linear feet of exploratory drilling. Yet, from all those samples, they chose to test only 11 feet to characterize what will be over 25 million tons of waste rock that will be produced over the life of the mine. [2] Disposal of mine waste is a critical element of the project with the potential for causing significant long term impacts. Yet no further testing was produced for the Final EIR. This is inexplicable. CEQA requires that the EIR “…give the public and decision makers the most accurate and understandable picture practically possible of the project’s likely near-term and long-term impacts.”[4] This Final EIR fails to do that. --- You are being asked to approve a project without knowing if any portion of the mine waste will qualify as Group C. Currently, there is no realistic plan for continued mine operations if you can’t sell the mine waste. The Final EIR response uses speculative, unproven assumptions stating that the mine rock “...would not be mined until mine waste characterization has been performed to ensure the rock will be suitable for off-site sale. Rock types that are not suitable for off-site sale would likely not be mined, and if mined, the waste rock would be placed underground” [5]. Mine waste classified as Group A and B requires specific management that must be determined by the Water Board, and cannot automatically be placed underground. Backfilling with waste rock and tailings is the exact scenario which has led to polluted ground water discharges in so many mines in our area. This new element, the placement of Group A or B mine waste underground, was not included in the Draft EIR. Even disposal of mine waste on the project sites for Engineered fill (Centennial for 5 years, Brunswick for 6 years) requires testing and will have to meet the Water Board’s approval. Quoting the Final EIR: “The barren rock and sand tailings would undergo testing as part of obtaining [Water Discharge Requirements] WDRs for use in the Engineered fill pads, and compliance with water quality objectives will need to be demonstrated to the [Water Board ] prior to that placement .” [6] The project description fails to provide an adequate means of interim storage for mine waste. The viability of the entire project is dependent upon the safe disposal of mine waste under Group C. There were numerous core samples available that could have undergone static and long-term dynamic testing, yet, subsequent to the release of the Draft EIR, no additional testing was done. Even if the mine waste is all Group C, it is hard to believe there will be no need to stockpile any of it for shipping off site.1,000 tons/day will be coming out of the shaft. That’s about 50 truck loads/day. Construction aggregate is seasonal. Most construction shuts down in the winter. The Final EIR is inadequate because if fails to address the potentially significant impact of mine waste disposal. Again, critical testing after project approval does not provide an “…accurate and understandable picture…of the projects likely…impacts”. ////References//// [1] FEIR Page 2-61 (p134) [2] 1000 Metric tons per day x 365 days per year x 75 years = 27,375,000 tons. [3] FEIR Page 2-233, 234 [4] https://casetext.com/regulation/california-code-of-regulations/title-14-natural-resources/division-6- resources-agency/chapter-3-guidelines-for-implementation-of-the-california-environmental-quality-act/article-9-contents-of-environmental-impact-reports/section-15125-environmental-setting [5] FEIR Page 2-60 [6] FEIR Page 2-59, 2-60 Master Response 11 PRINT or share this information with others using this PDF.
- Nevada County General Plan Goals and Policies Justify Denial of the Idaho Maryland Mine
The Idaho Maryland Mine project is inconsistent with numerous Nevada County General Plan goals and policies which provide justification to deny the project independent of the environmental analysis. Land Use Element GOAL1.5 - Within Community Regions, ensure that development reflects our small-town character, the characteristics of the land and the natural environment. GOAL 1.6 - Allow for growth while protecting, maintaining and enhancing communities and neighborhoods. Policy 1.8.3 - Within the City/Town spheresof influence, the Nevada CountyGeneral Plan Land Use Maps will generally reflect the City's/Town's General Plan land use mapping. In some instances, the County may provide for a less intensive land use due to infrastructure capability, environmental constraints or effect on land use and development patterns outside the city's sphere. However, the County's Plan will not preclude implementation of the City's/Town's Plan by providing for a significantly more intensive land use than the City's/Town's Plan. GOAL 1.8 - Coordinate with the cities/town in land use planning and development within their spheres of influence. Policy 1.7.10 - The County shall provide for facilities for the management of hazardous waste produced on-site in the Commercial, Business Park, Industrial, and Public land use designations, and shall provide for facilities for the management of hazardous waste produced on or off-site in the Industrial and Public land use designations. All facilities shall be located in a manner consistent with criteria established in the State-approved Nevada County Hazardous Waste Management Plan approved by the County. Economic Element Goal 2.1 - Provide for a strong economic base while protecting and maintaining communities and neighborhoods. Objective 2.4 - Encourage economic development which favors a high economic multiplier effect. Policy 2.9 - In support of the County Economic Policy, develop and implement an ongoing, aggressive business recruitment and marketing program featuring the County’s strengths in areas such as education and quality of life. Target the program to prospective types of business (particularly those that are entrepreneur-oriented) that are best suited to provide significant long-term job opportunities in industries such as biotechnology, electronics and communications, and energy-related products. Objective 2.14 Encourage protection and enhancement of the natural scenic beauty of this County in support of the tourist trade. Safety Element GOAL CC-10.13 - Build Climate-Resilient Communities and Protect Neighborhoods, Public Infrastructure and Natural Resources Through Mitigating Climate Change. Policy CC-10.13.4 - Require new discretionary development to include an analysis of potential affects to climate change impacts and water resources in the project review process. Projects shall reduce or limit impacts as feasible. GOAL HM-10.5 - Protect public health, safety, natural resources, and property through regulation of use, storage, transport, and disposal of hazardous materials. Policy HM-10.5.5 - The County will actively promote prompt clean-up or remediation of properties contaminated by mine waste or other hazardous materials and shall not grant any discretionary or ministerial land use approvals to develop or change boundaries or reconfigure parcels believed to be contaminated, unless and until the nature, extent, type and location of the contamination is determined and satisfactory arrangements are made for clean-up or remediation, in accordance with Nevada County standards or State regulations. Noise Element GOAL 9.1 - Provide for the health, safety, and welfare of the people of Nevada County through a set of policies designed to encourage an environment free of unnecessary and annoying noise. Policy 9.1.10 - Strongly discourage those General Plan amendments and zone changes that would likely create land use conflicts relative to noise. Aesthetics Element Goal 18.1 - Promote and provide for aesthetic design in new development which reflects existing character. Water Element Goal 11.1 - Identify, protect and manage for sustainable water resources and riparian habitats. Policy 11.2 - Encourage the protection of resources which produce water for domestic and agricultural consumption. Objective 11.2 - Preserve surface and sub-surface water quality and, where feasible, improve such quality. Policy 11.4 - Cooperate with State and local agencies in efforts to identify and reduce to acceptable levels all sources of existing and potential point-and non-point-source pollution to ground and surface waters, including leaking fuel tanks, discharges from storm drains, Chapter 11: Water Element Volume I - Page 11-4 Nevada County General Plan auto dismantling and dump sites, sanitary waste systems, parking lots, roadways, logging and mining operations. Objective 11.3 - Preserve and, where economically feasible, restore the density and diversity of water dependent species and continuous riparian habitats based on sound ecological principles. Mineral Management Element Goal 17.1 Recognize and protect valuable mineral resources for current and future generations in a manner that does not create land use conflicts. Policy17.6 Encourage extraction of mineral resources in compatible areas prior to intensified urbanization or conversion to other incompatible land use development. Policy 17.11 - Recognize the importance of water conservation and quality for the present and future needs of the County by: 1. Requiring the conservation of on-site water during mining operations. 2. Requiring that off-site water discharge complies with State water quality standards. 3. Requiring that any increase or decrease of off-site discharge is not detrimental to the downstream environment or downstream water users. Policy 17.14 - Already existing development - commercial, residential, and community - as well as undeveloped private lands, shall be protected from adverse environmental effects caused by mining through enforced use permit conditions and mitigations measures, or denial of the projects. The County shall be the enforcement agency. PRINT or share this information with others using this PDF.
- The Centennial Clean-Up Must Be Included in the EIR
The Final EIR for Rise Gold’s Idaho-Maryland Mine Project is significantly flawed because it does not include the plans to cleanup the Centennial site. Jan 24, 2023 California Department of Toxic Substances Control (DTSC) is managing the cleanup of the 56 acre Centennial site, which is polluted by the mine’s historic operations. After it is cleaned up under what is known as a Remedial Action Plan, or RAP, Rise intends to dump mine waste there for about 5 years. But, currently, the cleanup is not done. Under CEQA the current conditions of a project must be assessed so that the environmental impacts and appropriate mitigations can be determined. The current conditions of the Centennial site are largely unknown because most of the current conditions aren’t included in the EIR. Instead, Rise has included in its EIR what it assumes to be a baseline of the future conditions that might occur after the cleanup. Adding to the inadequacy of this approach, an approved RAP does not even exist at this time. But even if the RAP had been finalized and approved by the DTSC, using a future condition for establishing a baseline in an EIR is almost never valid. Including the Centennial cleanup in the EIR would have addressed most of these problems because the initial conditions of the site would be described adequately and the steps necessary to prepare the site for mine waste would have been set into the context of the project as a whole. This would have provided a means of determining potential impacts and defining mitigations correctly. As it is, the true impacts of the project cannot be determined. For example, the draft RAP recognizes that 44 acres will be buried in mine waste and it includes stripping off acres of soil from areas that are not contaminated to provide clean soil to put over the capped contaminated materials and other work areas, destroying wetlands and woodlands. How much of this habitat destruction is really necessary for the clean soil, considering that the mine plans to dump 1000 tons per day of fill on the site? If the cleanup was included in the Mine project, this habitat destruction could be assessed and probably significantly reduced. In conclusion, Rise’s EIR project description is legally inadequate because it does not include the cleanup, which is plainly part of the Project. Instead, the EIR is left guessing as to what the true impacts of the mine project might be. This Final EIR is inadequate under CEQA. Thank you, Ralph Silberstein CEA Foundation ***Addendum*** The FEIR continues to maintain that the Centennial clean-up project is a separate project. The DEIR’s project description is legally inadequate because it excludes the required cleanup of existing contamination on the Centennial Site, which is plainly part of the Project. FEIR p. 2-798, 2-803-05. CEQA defines a “project” broadly to include the “whole of an action,” rather than “each separate governmental approval.” CEQA Guidelines § 15378(a), (c). Where two actions are integrally related or where one is conditioned on another, they must be considered together as one project; segmenting their analysis is a way to evade a complete impact analysis, and is accordingly forbidden. Nelson v. County of Kern, 190 Cal.App.4th 252, 271 (2010). The FEIR merely restates the same faulty justifications from the DEIR for the decision to piecemeal the Centennial cleanup from the IMM Project. The County’s assertion that the IMM project can proceed regardless of whether the Centennial cleanup is completed (DEIR at 1-7, FEIR at 2-8) ignoresthe fact that one of the objectives of the IMM Project is to reclaim the Centennial Site for future industrial use. DEIR at 3-42, 3-46. The DEIR also uses an inconsistent baseline: for certain impact areas, the DEIR pretends that the Centennial cleanup has already occurred, while for others, it uses the current contaminated conditions as the baseline. DEIR 4.0-1. CEQA requires that the baseline “describe physical environmental conditions as they exist at the time the notice of preparation is published,” and it prohibits the use of hypothetical conditions. CEQA Guidelines § 15125(a). Accordingly, the DEIR’s use of a hypothetical baseline for various impact areas in which the Centennial cleanup has already occurred renders its analysis legally inadequate and unsupported by substantial evidence. FEIR p. 2-801.The FEIR contends that it was not using a future conditions baseline, but instead the “conditions expected when the project becomes operational.” FEIR at 2-295. However, there is no evidence that that the Centennial cleanup will have occurred such that it can be “expected” by the time the Project is operational. The FEIR’s reliance on Citizens for a Sustainable Treasure Island v. City and County of San Francisco, 227 Cal.App.4th 1036 (2014), is misplaced. FEIR 2-9. In that case the issue was not whether the Navy’s cleanup should be studied as part of the subsequent development project, but instead whether the project proponent had properly disclosed how it would manage and dispose of hazardous materials in the event it took responsibility for the cleanup. Id. at 1058-59. Furthermore, the project proponent in Treasure Island had included “exhaustive information” in the EIR about the presence and location of hazardous substances and adopted mitigation measures in case it were required to undertake some cleanup efforts. Id. at 1056, 1059. Because it was impossible to know whether the project proponent would have to undertake cleanup efforts, it was appropriate for it to defer environmental assessment. Id. at 1059. Here, in contrast, the County provided virtually no information about the contamination on the Centennial site and the process required to remediate it, despite the fact that the Project objectives include increasing the usable land on the Centennial Site to allow for its future use as industrial land. DEIR 3-12. SM&W PRINT or share this information with others using this PDF.
- Idaho-Maryland Mine Greenhouse Gas Emissions Are Significant
The Final EIR uses an unsupportable, obsolete threshold measure to justify its conclusion that the mine’s greenhouse gas (GHG) emission impacts will be “less than significant”. Feb 7, 2023 The Idaho-Maryland Mine Final Environmental Impact Report (EIR) is inadequate in its assessment of greenhouse gas (GHG) emissions. A valid threshold for GHG emissions was not set in the EIR. As stated in the EIR, CEQA Guidelines allow a lead agency to determine its own thresholds for environmental impacts (including GHG emissions), and “explicitly provides that an agency may consider thresholds adopted by other agencies provided that such decision is supported by substantial evidence.”[1] The Northern Sierra Air Quality Management District has not set thresholds for GHG emissions, so, as lead agency, Nevada County simply applied the 10,000 Ton/year [2] carbon-dioxide- emission threshold chosen by some other air districts for this project. However, the justifications for adopting these thresholds are unique to each air district. These other air districts have prepared detailed GHG inventories to identify and evaluate strategies for achieving the statewide GHG reduction goals within their districts. Nevada County cannot simply assume that the justifications used by other air districts to adopt their thresholds also apply in Nevada County. Hence, the EIR failed to provide “substantial evidence” required by CEQA by just relying other districts for setting the threshold. In fact, the EIR provided no evidence beyond just copying what other districts used. But this is doubly wrong because the other air districts originally adopted the 10,000 Ton threshold to achieve the older statewide GHG goal under California Assembly Bill 32, which is no longer consistent with the current statewide GHG reductions goals.[3] In 2015, the California Supreme Court determined that a project’s GHG emissions should be evaluated based on its effect on California’s efforts to meet its long-term climate goals.[4] Then, in 2017, the California Air Quality Board Climate Change Scoping Plan stated “Achieving no net additional increase in GHG emissions, resulting in no contribution to GHG impacts, is an appropriate overall objective for new development.”[5] And in 2018, Governor Brown signed Executive Order 55-18, calling for the state to achieve carbon neutrality as soon as possible and no later than 2045, and to achieve and maintain net- negative emissions thereafter.[6] In view of this, the mine’s 9000 tons/year of emissions for 80 years should be considered significant and unmitigated. The mine is proposing an 80 year project, and no consideration was given to meeting the state’s GHG emission goals. The EIR should have established a net zero threshold for GHG emissions from the proposed project. For example, in considering current goals, the recent Draft EIR for another mine - the analogous Sargent Ranch Quarry project within the Bay Area Air District uses a net-zero significance threshold for operational GHG emissions.[7] This EIR should have done the same. The EIR does not explain why the Project should be exempted. Nevada County Energy Action Plan The Nevada County Energy Action Plan’s (EAP) goal is to reduce the projected annual grid supplied electricity the county will use in 2035 by 51% and the annual natural gas use by 30% through energy efficiency measures. The mine’s electricity use is equal to adding the energy use of 5,575 homes in Nevada County. This almost eliminates the results of any energy-saving measures planned by the county. This project will consume 49,000 Megawatts of electricity, in direct conflict with the County's energy reduction goals.[8] The FEIR states “...although the EAP is not a Qualified GHG Emissions Reduction Plan under CEQA the project was nevertheless determined to be consistent with the EAP.”[9] This statement is essentially false. [10] In fact, the Mine operation is antithetical to the County’s Energy Action Plan. The Nevada County Planning Commission and the Board of Supervisors should ask the question: Are we serious about the Energy Action Plans? If so, this mine should not be approved. In conclusion, the EIR for the mine fails to correctly identify a valid threshold for GHG emissions by assuming an outdated 10,000 Ton threshold without any substantial evidence, failing to consider the current State goals, and it would also effectively undo a large part of the goals of the Energy Action Plan. Under CEQA, this EIR is totally inadequate in addressing the significant impacts of greenhouse gas emissions from Rise Gold’s proposed mine. Thank you, Don Rivenes Ralph Silberstein CEA Foundation [1] FEIR Page 2-115, 2-116, per CEQA 15064.7(c) [2] “Ton” used herein is Metric Ton Carbon Dioxide Equivalent emissions (MTCO2e) [3] SB-32 California Global Warming Solutions Act of 2006 [4] Center for Biological Diversity v. Department of Fish & Wildlife (2015) (62 Cal.4th 204), https://ceqaportal.org/ceqacase.cfm?cq_id=1612 [5] California Air Quality Board 2017 Climate Change Scoping Plan, page 101 [6] Executive order 55-18 signed by Governor Edmund Brown September 9, 2018 [7] Santa Clara County, 2022 Sargent Ranch Quarry DEIR 3.8-10 [8] FEIR Appendices, p1945, Appendix M, Dudek, 1.2 [9] FEIR Response to Comments Page 2-753 [10] Nevada County Energy Action Plan, Page 2 PRINT or share this information with others using this PDF.
- Send Your Comments to The County Supervisors
By Traci Sheehan - Community Environmental Advocates Foundation We're on a mission to be the most vocal group in Nevada County. Your written or spoken comments to the Nevada County Board of Supervisors (BOS) can make a huge difference. You can send comments directly to all five of the supervisors by sending an email to bdofsupervisors@nevadacountyca.gov at any time. Or, for maximum impact, consider writing a letter that can be read in 3 minutes live at the Supervisor's meetings, which are held on the 2nd and 4th Tuesdays of each month. Why should I make a comment to the County? Nevada County has five supervisors, who will ultimately be responsible for the decision about whether to approve Rise Gold's application to open the mine. The community's review of the Draft Environmental Impact Report (DEIR) in April of 2022 revealed signficant issues and we're currently waiting to see a revised report. Nevada County Supervisors could make a decision as early as 2023. It is up to citizens to ask questions and voice concerns about the project. How do I submit a comment for the Board of Supervisors meeting? The best way to make a comment to the Board is in-person, but you can also call in or send a letter in advance of the meeting via email. Here are your options: Attend the meeting at the Eric Rood Administrative Center in Western County at 9:00 am. The Chair will invite public comment at the beginning of the meeting. You will be asked to give comments from the designated podium and limited to a maximum of 3 minutes. Comment live during the meeting by calling (530) 270-3474 by 9:00 am. Email your comment to BOS.PublicComment@nevadacountyca.gov. Mail your letter to Clerk of the Board, 950 Maidu Avenue, Ste. 200, Nevada City, CA 95959. For more information, see the County's Public Comment Guide. How do I format my comments? Your comments should be no longer than 3 minutes and focus on 2-3 points you’d like to make. We suggest writing your key bullet points or scripting your entire comment. Begin by stating your name, the neighborhood or district you reside in, and the issue you are commenting on. View this simple district map... or go to the County website to find out what Supervisorial District you live in. Add your personal experience or give context by explaining why you are involved and care about this issue, what your profession is, or why you like living in Grass Valley or Nevada County. Make a clear statement of what you want the BOS to do or consider. For example “The County needs a more thorough environmental analysis because...", or "The County needs to work with well owners and the community to make sure there are safeguards to protect well owners. ” What if I'd like to comment in person, but can't wear a mask? Masks are required to enter a County building. However, a remote kiosk center is provided outside of the Eric Rood Administrative Center for individuals unable to wear a mask. How do I send comments directly to my supervisor? Most people prefer to send to comments to all supervisors at this address email bdofsupervisors@nevadacountyca.gov. They also accept comments by mail. Nevada County Board of Supervisors Eric Rood Administrative Center 950 Maidu Avenue Nevada City, CA 95959 It helps to include information about what district you are in. Click on this simple map will help most people figure it out. It that doesn't work, click here to see several more ways to explore with precision. If you prefer to write to your supervisor only, here are their individual email addresses. Heidi Hall, Supervisor District 1, Heidi.Hall@nevadacountyca.gov District 1 includes Nevada City and the unincorporated areas of Banner Mountain, Cascade Shores, Deer Creek, and the Highway 174 corridor. Ed Scofield, Supervisor District 2, Ed.Scofield@nevadacountyca.gov District 2 includes the communities of Alta Sierra, Lake of the Pines, and unincorporated areas along Highway 49. Lisa Swarthout, Supervisor District 3, Lisa.Swarthout@nevadacountyca.gov District 3 includes the City of Grass Valley, Cedar Ridge, the Brunswick Basin, Squirrel Creek, and unincorporated areas along Highways 49 and 20. Susan Hoek, Supervisor District 4, Sue.Hoek@nevadacountyca.gov District 4 includes the communities of Penn Valley, North San Juan, Rough & Ready, Lake Wildwood, Spenceville, and unincorporated areas along Highways 20 and 49. Hardy Bullock, Supervisor District 5, Hardy.Bullock@nevadacountyca.gov District 5 includes the Town of Truckee, and the communities of Soda Springs, Washington, Graniteville, Hirschdale, Boca, Floriston, and unincorporated areas along Highways 49, 20, 89, and Interstate 80. What should I talk about? Here are some ideas to spark ideas on your comments. Please put these concepts in your own words. Add personal experience and your own concerns. It's OK if others have talked about a subject before. The Board needs to hear a chorus of voices, not just one alone. Water: Water is a precious resource. All the more so because of the current drought. Rise Gold's plans to dewater the mine puts wells, creeks, and aquifers at risk. Air: Nevada county already gets an F rating when it comes to air quality and 2 times the average in lung disease. Fugitive dust from rock crushing and transport and diesel exhaust from constant truck traffic will make a bad situation truly terrible. Neighborhood quality of life: There will be more truck traffic, higher noise levels, and vibration from blasting. Aesthetics will also be seriously compromised as natural settings get buried beneath mountains of mine waste and a paved industrial area. Economic risk: The few jobs gained are offset by big compromises to air, water, and quality of life. Even with the most state-of-the-art mining technologies, the risks posed by gold mining are too great to risk putting it directly under this community's feet. Trust: Rise Gold is a 16 year old company that has never opened a mine and never made a profit. Their current financials are weak. And their CEO’s prior venture polluted tribal waters, went bankrupt, and left Canadians with a bill to pay for cleanup.
- Ray Bryars: Economic Impact Report
This local resident shares what he learned about the concerns shared when community experts reviewed the Economic Impact Report for the Idaho-Maryland Mine. This opinion piece was originally published in The Union. Jan 20, 2023 Experts review the Economic Impact Report for the proposed Idaho Maryland Mine. The report was prepared by Robert D Niehaus (RDN). I attended the excellent Webinar discussing the recently released Economic Impact Report for the Idaho Maryland Mine that Community Environmental Advocates Foundation (CEAF) organized on December 20th. A group of very knowledgeable presenters conducted detailed analysis in a number of areas. The amount of information was overwhelming, so this is an attempt to list some, of their concerns — There are many more. Well monitoring to provide a baseline for the DEIR was a requirement when the most recent San Juan Ridge MIne, also known as the Siskon Mine was approved. A similar requirement must be placed on Rise Gold to ensure that over 300 wells are monitored for at least 3 years. CEAF is concerned that there are many unanswered questions in the Environmental Impact Report (EIR). Therefore it cannot be considered “Final”. Dr David Chambers noted that a Technical Report NI 43-101 has not been completed for 5 years. So this is all we have to go on. It showed that there is not enough information to specify any mineral resources and mineral reserves. It is highly unusual to ask for a production permit without these being defined. Dr Chambers claims that he has never seen such a lack of information. Economic impact of Waste disposal. This is a problem because selling mine waste is difficult due to liability risks. Testing is required, but the current samples are not adequate. Most buyers will be reluctant to buy since there are many lower risk alternatives. Characterization of mine waste is suspect since It was not tested properly. Distilled water was used instead of the typically used, weak acid solution. Since there has not been proper testing of mine waste rock. If it could not be sold, where would the 2 million tons in 11 years of mining go? Financial assurance must be a requirement. It is common that mines have catastrophic events that end up being a burden on the community. We need to be assured that if there is a catastrophic event or the mine closes, it is done properly so there is not an impact to the community. The caveat is that historically, financial assurance, never covers catastrophic events. However there should be enough money put aside to compensate the community in case a catastrophe occurs and the the mine goes bankrupt. Does anyone seriously believe that there can ever be justification to permit a mine operation for 80 years? There is nothing that would justify this. Rise claims that it will be 3 years to get to full production. This is contrary to the reality that typically the industry takes 6 — 7 years after the permits are obtained. This will have a huge financial impact and should be seriously considered. Note that the time to get permits was not considered. The CEAF experts feel that spending patterns of construction and mine workers is overblown. Construction workers will likely be from outside the county, will probably share accommodation and spend much less than expected in the community. Their estimate is that spending would be 1/4 of that claimed. The cost to mine that Rise Gold is using is 1/2 of the industry average. This is way too optimistic and should have been seriously questioned in the Economic Impact Report. James Steinmann’s conclusion on the Economic Impact Report: “The input data is questionable, the benefits are substantially overstated, the costs of operation are understated and the risks are ignored”. Charlie Brock a local Real Estate expert strongly contests the conclusion that there will be no effect on real estate values. The consensus of surveyed agents was that there will be long term detrimental effects. Another expert estimated that even a small (5-10%) negative impact on tourism plus the impact on property values would be far greater than any positive financial impact that the mine claims. The comparisons with other mines that was used for looking at the impacts on property values was seriously misleading. There were none that had the same housing density, so close to the mine. We have approximately 2000 homes within 1/2 mile from the mine. Not discussed, but important, is that Economic Impact Reports for other mine operations, commonly include a comparison of the economic impact of alternative uses for the property. This may be an intentional omission since there are likely many other uses for the site that could provide greater benefits, with very much less risk and environmental impact. What is the estimated cost for installing the infrastructure, construction of buildings, purchase and installation of equipment and excavation down to a point where gold can be extracted? A detailed economic report should include a timeline of expenditures and income to show the breakeven point. The cost to first cleanup the Centennial Site was not included, but it should be completed to show the true economic picture. The mine intends to dump mine waste rock on this site. The Remedial Action Plan for the Centennial Site will not be complete until sometime in 2023. Since the use of this site is a major part of the project plan, it seems wrong to move forward until this is finalized. To see the CEA Webinar go to: “The Other Side of the Story” You are encouraged to write your concerns to your supervisor and attend Planning Commission and Supervisors meetings. Look for public meeting dates, your participation is important. bdofsupervisors@co.nevada.ca.us Idaho.MMEIR@co.nevada.ca.us Ray Bryars, Nevada City.
- Fast Facts: Mine Dewatering, Wells & NID
There are around 300 wells that could be impacted by dewatering of the mine “Before exploration and mining can proceed, the volume of water contained in existing workings must be removed from the underground workings. Removal of the static water within the flooded mine workings is referred to as the ‘initial dewatering.' Once the initial dewatering is completed, continued pumping is necessary to remove the groundwater that will constantly flow into the mine through fractures within the bedrock. For the purposes of this report, this is referred to as ‘maintenance dewatering.’” "In approving mining projects which according to expert opinion may threaten the existing quality or quantity of surface or subsurface water which supply adjacent homes and businesses, the County shall require the operator to guarantee a comparable supply of water to such homes or businesses through accessible forms of security or alternate sources of water. " "Where water quantity and quality problems occur, an immediate water supply shall be provided by the operator until the source of the problem is determined. The burden of proof shall be on the operator to show that the mining operation did not create the water problem. If it is determined that the operator is at fault, impacted owners shall be compensated by the operator.” NID would not require well owners to destroy their wells as long as the homeowner pays for a double check valve, to be installed at the meter. The cost is about $600-$800 ( 2008 dollars) and about a $5 monthly fee to pay for the annual check and upkeep and replacement of rubber seals. NID does not want one of the mitigation measures to be that the lateral pipelines are built but not used. They need to flow water and have users at the end of it otherwise the chlorine and water quality of the system is affected adversely. The NID hook up fee per parcel is roughly $8,000 (2008 dollars). The proposed NID pipeline overview map does not indicate any NID water service to parcels on the south side of E. Bennett Rd. [1] Groundwater Hydrology and Water Quality Analysis Report https://www.mynevadacounty.com/DocumentCenter/View/34132/Groundwater-Hydrology-and-Water-Quailty-Analysis-Report--p. 45 -- Added 4-24-2020 [2] & [3] Land Use Technical Study, Goals/Objectives/Policies https://www.mynevadacounty.com/DocumentCenter/View/34134/Land-Use-Study-- p. 46, policy 17.12 -- Added 4-24-2020 [4], [5] & [6] Tim Crough/Bill Gahn -From December 5, 2008, NID meeting notes. Attendees - Tim Crough (NID), Bill Gahn (NID), Nancy Weber, Bob Bogart (CLAIM-GV), Gary Pierazzi (BARC), Mike Pasner (WCCA), Mary Anderson (Mink Ct./Beaver Dr.) [7] NID Pipeline Overview https://www.mynevadacounty.com/DocumentCenter/View/30403/Pipeline-Overview---NCE p.1
- Geoff Eido: Wells Run Dry Official Music Video
Singer/songwriter Geoff Eido as he calls on citizens of Nevada County to learn more about the dangers of reopening a gold mine under Grass Valley's feet.
- Jeff Kane: Mine's economic report shows County's lack of due diligence
Writing for the Concerned Citizens Roundtable, Jeff Kane reveals several weaknesses in the Economic Impact Study commissioned by the County, including lack of due diligence on the applicant. This opinion piece was originally published in The Union. December 30, 2022 Opinion - Jeff Kane: The Idaho-Maryland mine economic impact report shows Nevada County's lack of due diligence A plumber came to our home to bid a job. We explained what we needed and then we checked him out. We asked how long he's been in the trade. We requested references, and whether he's insured and bonded. We wanted to know if he's facing liens or litigation. Is he adequately prepared to perform and complete the job? In sum, can we trust him? This basic business principle is called due diligence. The proposed Idaho-Maryland Mine's Economic Impact Report exemplifies an unconscionable failure of due diligence. In commissioning the Report, Nevada County inexplicably restricted the study's scope. The Report's author, Robert D. Niehaus, Inc. (RDN), states, "The scope of our study is to focus on total economic effects as modeled by IMPLAN [a widely used planning software] and fiscal effect on county tax revenues and overall effect on property values." That's what it does in its ninety pages, but it dodges and ignores other crucial issues. The Report is less than responsive to many relevant questions. For example, when asked if there are other mines operating 24/7 which are surrounded by residential properties, RDN explains that there are "no perfect comparables," and there the matter drops. RDN states that it didn't explore loss of tax revenue to the County if local wells fail--thus decreasing property values--because the Draft Environmental Impact Report claims potential well failure is fully mitigable. In other words, don't worry, it'll be okay. When asked what might be the County's costs in addressing opposition to the the mine, RDN replies that that's an environmental issue, beyond the study's scope. Also beyond the study's scope, says RDN, is healthcare costs. Medical expenses and lost work time due to the mine's massive toxic airborne emissions are, according to the Report, environmental, not economic, issues. RDN didn't study the mine's effect on County tourism, as, it states, that's taken into account by IMPLAN's "inter-industry linkages." That is, at the end of the day a buck is just a buck: income from mining will offset the loss of our tourist industry. Another unaddressed economic issue is the $3.5 million cost of cleaning up the Centennial Site. It was not included in the Report since even though RDN agrees it should factor into the final decision, it was not within the scope of this study. The Report ignores or dances around a number of crucial issues, but its starkest weakness is omission of the economic background of the applicant itself, Rise Grass Valley (RGV). Nevada County administration didn't ask RDN to explore any aspect of RGV's insurance, bonding, or even sufficiency of capitalization. Nor did it ask it to examine RGV's CEO's previous venture (Banks Island Gold, Ltd.), which went bankrupt, thus failing to pay numerous creditors and dozens of its employees. The County didn't ask RDN to inquire whether RGV lost its financial support because it was shut down by the British Columbia government for environmental and safety infractions, or whether company officers were under legal indictment. RDN's Economic Impact Report, then, is necessarily partial and misleading, representing a disastrous failure of due diligence. Why would we hire a plumber whose last job left an arguably criminal mess, is embroiled in serious litigation, stiffed his creditors, is grossly under-funded, and carries a loan, due this year, with an interest rate (25%) granted only to the highest-risk borrowers? So before we tumble into a thicket of economic argument, we'd do well to consider why we'd ever choose to conduct eighty years of business with this particular company in the first place. The Economic Impact Report states that if for any reason RGV was unable to function after being granted a permit, another company could step in and the economic impact would be no different. But we'd be as ignorant of that new entity's background as we are of RGV's. It would be like our prospective plumber dropping out in favor of another we'd never vetted. Considering that the mine application has, over several years, cost County employees and citizens significant time, work, and money, we should require future applicants to prove themselves before we grant them any attention: show adequate capitalization, an appropriate cash bond, full insurance, and a clean financial, environmental, and safety record. The Economic Impact Report's deficient scope and the Environmental Impact Report's numerous unmitigatable damages to our community together beg our supervisors to just say no. The Concerned Citizens Roundtable, Nevada City: Rob Agrimonti, Yasha Aginsky, Charlie Brock, Jeff Kane, Scott Kellermann, Brad Miller, Randall Newsome, Thomas Nigh, Tim Ogburn, Kathy Ogburn, Rondal Snodgrass