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Nevada County has a higher rate of depression & suicide than the CA average, but less mental health providers. The possible reopening has already led to considerable anxiety and depression in the community with worries about property values, loss of well water, noise, traffic, environmental impacts and increased health problems. This opinion pieces was originally published in The Union. Much has been written about the negative public health, environmental and quality-of-life impacts from the possible reopening of the Idaho-Maryland Mine. An additional concern is its negative impacts on mental health for individuals and the community. Nevada County has a higher rate of depression and suicide than the California average, combined with a lower percentage of mental health providers per capita, according to the 2019 Community Health Needs Assessment (www.mynevadacounty.com/DocumentCenter/View/27995). The pandemic has led to an even greater demand for mental health services, and there has been an alarming increase in overdose deaths. It is clear from the number of people mobilized in opposition to the mine that the possible reopening has already led to considerable anxiety and depression in the community. Worry about property values, loss of well water, noise, traffic, environmental impacts and increased health problems is widespread. Additionally, the possible reopening of the mine is yet another divisive issue in the community. At a time when our cohesiveness is challenged on many fronts, this is an issue for which there is a clear solution, and that is to deny the Rise Gold proposal. Cheryl Morris Grass Valley

Ray was surprised when the draft environmental report concluded there would be “no significant issues” with explosives. He gives multiple recent examples where human error caused disastrous explosions with ammonium nitrate. He also questions why our County would take such a risk. This opinion piece was originally posted in The Union. Like many concerned residents in our community, I have been struggling to gather information from the Idaho-Maryland Mine Project Draft Environmental Impact Report. After recent news items about disastrous explosions related to ammonium nitrate used for explosives to mine for gold and use in fertilizers, I decided to see what the report says about explosives. I have reviewed section 4.7 – Hazards and Hazardous Materials section of the report and was shocked at how they could possibly conclude that there are “No significant issues.” This is explosives materials they are addressing — how could there not be issues? West Texas, 2013, ammonium nitrate stored in fertilizer plant detonated in a massive explosion that killed 14, injured about 200. Chinese port of Tianjin, 2015, explosions at warehouse storing ammonium nitrate and other chemicals killed over 116 people. Port of Beirut in Lebanon, 2020 a catastrophic warehouse fire caused ammonium nitrate to explode, killing over 200, injuring over 6,000 more. It was so large that it was initially registered as an earthquake 2022 headline: “Truck carrying explosives for mining collides with motorcycle, setting off massive deadly explosion in Ghana.” Resulted in 13 deaths, over 50 people injured and a small town partially destroyed. As I write this, an ammonium nitrate plant in North Carolina is burning out of control for a third day, 6,000 people evacuated and it is projected to be one of the worst explosions in U.S. history. Does Nevada County need to take a similar risk? I urge our Nevada Country supervisors to say no. Ammonium nitrate can be mixed with other substances to make bombs. It was used in Irish Republican Army bombings in London in the 1990s; the 1995 explosion that blew up a federal building in Oklahoma City, killing 168 people; and the 2002 blasts in Bali nightclubs in which more than 200 died. Many of the homemade bombs that were used against U.S. troops in Afghanistan contained ammonium nitrate. From what I’ve seen, there is not one standard, but there are a lot of detailed requirements that if followed could make the storage of explosives safer. Unfortunately Ben Mossman, who is the head guy at Rise Gold, does not have a good record when it comes to following safe practices. His Banks Island Gold Company was charged with causing a toxic waste spill in British Columbia, Canada, back in 2015. Commercial production started in January and he was ordered to stop operations in July. The company filed for bankruptcy in January 2016. It sure didn’t take him long to make a mess and screw things up. Below are some comments that I’ll be sending to the county regarding the draft report: Explosive storage: On page 4.7-27 it specifies that no mining is proposed closer than 500 feet from the surface, thus explosives in transit would be at least this far from the surface. Again, a ridiculous statement. At this point it is not known what impediments will be found in the mine shaft. It has been decades since anyone has been into the mine, so there could be huge blockages that will require explosives to blast through. Question: Can they guarantee that no explosives will ever be used above 500 feet below ground level? Report conclusion: On page 4.7-30 it states that “compliance with applicable federal, state and local regulations would minimize the potential for the proposed project to result in a significant hazard to the public or the environment through the routine transport, use or disposal of hazardous materials.” Question: Why would the county knowingly subject its residents to any risk? We all know that humans make mistakes and accidents happen. If this project is approved, it is almost a certainty that a disaster will happen. Does Nevada County need to take this risk? I urge you to say no. On page 4.7-31 it states: “It is conservatively concluded that the proposed project could result in a significant impact related to the routine transport, storage and use of explosives.” Question: Why should the community of Grass Valley subject its residents to these risks? It makes no sense, for any period of time, let alone the proposed 80 years? Please send your comments regarding the draft environmental impact report to Matt.kelley@co.nevada.ca.us. Ray Bryars lives in Nevada City. ADDITIONAL NOTE: When Ben Mossman ran Banks Island Gold, he was cited for several violations of mining regulations. In addition to the toxic spill mentioned above, one report stated that "One of the magazines [explosives storage area] was noted to be so full the door to it would not close without considerable effort." Read more about this in Rise Gold Shouldn’t Be Trusted. Here’s Why.

This retired economist says we need to look at the proposed mine with eyes wide open. Requesting an 80-year permit is extreme. The risk is very high. A large bond is most certainly a requirement, if Rise Gold can find the funds to do it. This opinion piece was originally published in The Union. I have studied with much interest and concern about the application of Rise Gold to reopen the Idaho-Maryland Mine. The potential environmental impacts are serious, as reported in the draft environmental impact report. In their application, Rise Gold is proposing extensive mining operations that could greatly alter the peaceful climate of Grass Valley, disrupt normal commerce, and re-create the very dangerous industry of underground mining. When considering the viability of such a corporate development proposal, it calls upon good business practices to ask for the credentials of the applicant, require proof of economic viability, a business history, and the resume of the representative leadership. I have learned that Rise Gold is a speculative company. They have no business history. The present stockholders are gold investors throughout the United States., Canada, off shore, and Wall Street. It is a company formed without the capital needed for the project, but raised money through loans and stock sales to get the land, pay for environmental impact report consultants, and hire a public relations firm. Some commentators on gold-driven companies say they mine stock value, and hope for gold. They are creating profits by manipulating value as they use government processes and public relations. The permit, if ever granted, would multiply stock values. That permit could then be sold. A glaring and shocking fact that I uncovered is that the Rise Gold’s present CEO has previously been embroiled in a failed mine, financed in this same way, up in British Columbia. The corporation he managed, called Banks Island Gold Ltd., declared bankruptcy when the government ordered the mine closure. The mine’s safety engineer became a whistle blower, sending photos of damage to government officials, bringing in helicopters and regulators. At that time there were 35 charges of failed compliance regarding environmental and safety standards. Court cases continue with fines and appeals of this CEO’s role in the mine failure. The mine is located on Banks Island, off shore from Prince Rupert, and is within territory of the Indian Gitxaala Nation. They are outraged with the damage, possible destruction of traditional bird, fish and animal habitat, and the mess that must be cleaned up. The costs of remuneration are hundreds of thousands of dollars, with the public and the government of British Columbia stuck with most of the cost. Banks Island Mine Ltd. did not post adequate bonds to cover such potential damages. A sad personal story is that the employees of Banks Island Mine Ltd. did not receive their severance benefits. Also there are pages after pages of unsecured creditors that were not paid. Nevada County must look at the Rise Gold application with extreme caution. I read from newspaper accounts and Rise Gold’s press releases that the application is costing a huge amount of money. There are hundreds of hours of county and related agencies staff time, and for the volunteers on the planning commission, and much angst, concern and interest of the general public. It’s very interesting that even Rise Gold itself cautions investors and states on its website: “No current mineral resources or mineral reserves have been defined … The company has not completed a feasibility study to establish mineral reserves and therefore has not demonstrated economic viability for the Idaho-Maryland Mine.” And also, very concerning is this from the Securities and Exchange Commissions reports about Gold Rise’s publicity: “ … such press releases that contain forward looking statements within the meaning of applicable securities laws … Words such as plan, expect, intend, believe, anticipate, and estimate that certain events or condition may or will occur, accordingly readers should not place undue reliance on forward-looking statements and information contained in this release.” Rise Gold stated the estimated cost of the project would be $100 million for full development. They have requested an 80-year permit, which is extreme, into the next century! That’s four generations into the future. To ensure the viability of the applicant, the county should require Rise Gold to post performance and environmental safety bonds to continue being a permit applicant. I suggest 7%, or $7 million. We need to look at this with eyes wide open. Without such safety, we could end up like other towns, and rural areas that were left holding the bag by gold mines for failed promises and non-redeemable environmental damages. Good insurance covering loss and liability is a common practice and should be required to help safeguard our county’s economic, environmental and civic vitality. Rondal Snodgrass has been a conservation land consultant in California for over 30 years and holds a degree in economics from the University of Oregon. He lives in Nevada City. NOTE: After this opinion piece was published, NID's (Nevada Irrigation District) general manager also commented on the Draft Environmental Impact Report and requested a $14M bond solely for the purpose of protecting well owners in the neighborhood of the mine. Read about it in the Union article "Hung out to dry: Well owners contend with report's findings".

As demand for minerals to support new technology grows, indigenous people in the west are battling the effects of inadequate hardrock mining laws. It's an uphill battle to protect their health, culture, and ancestral landscape. This article was originally published on In These Times. STEPHANIE WOODARD JUNE 2, 2022 Contaminated water—polluted by old, closed gold mines in Montana’s Little Rocky Mountains—flows down the peaks toward the Fort Belknap Indian Community’s reservation in September 2021. Cleanup costs at least $3 million annually. PHOTO BY KATY SPENCE/MONTANA ENVIRONMENTAL INFORMATION CENTER Tribal chairman Joseph Holley looks out over the magnificent sweep of Nevada hills and mountains where his Western Shoshone people have thrived for millennia. Grey-green and bright-yellow shrubs embellish the carpet of golden fall grasses stretching to the horizon. As we traverse the area, driving and hiking, Holley points out scars on the cherished land. He shows me battered metal contraptions marking long-shuttered mines. Active mines are gigantic, steep-sided craters; widely spaced bars cover their dangerously long airshafts. ​“We keep our kids close by in these areas,” Holley says. ​“They could easily fall through.” The access road to one mine destroyed stands of medicinal plants cultivated by an ancient Western Shoshone doctor. A mine’s crew gouged a trench across a hill where tribal members seek visions. Centuries-old rock shelters and hunting blinds have been demolished. Holley has long spoken out against the hundreds of mines — for gold, silver, copper, barite and other minerals — that have torn up much of his tribe’s ancestral landscape. He says mining is killing his people. ​“It’s taking away our culture. It’s taking away our places of spirituality.” He describes it as a slow death, occurring over generations. Joseph Holley, chairman of the Te-Moak Tribe of Western Shoshone Indians, surveys a sacred desert place in Nevada. PHOTO BY JOSEPH ZUMMO These operations are called hardrock mines, which unearth metals and minerals other than coal and other fuels. In addition to damaging the land, the hardrock-mining industry is a major source of toxic waste in the United States, according to the Environmental Protection Agency (EPA). Cyanide, arsenic, mercury, acids and other substances used to obtain and process ore seep into aquifers and rivers, foul the land and are carried on the wind. After a century-old copper-mining facility on the Tohono O’odham Nation in Arizona closed in 1999, for example, the Department of Health and Human Services found the mine had added enough arsenic to local drinking water to cause nausea — and skin, bladder and lung cancers. The General Mining Law of 1872 set the stage for today’s profit-driven destruction by allowing hardrock miners — individual and corporate, foreign and domestic — to pay minimal fees to stake a claim, submit no royalties on their takings and do little or no cleanup afterward. Unlike coal miners, who pay the federal government between 8% and 12.5% of the gross value of what they have produced, hardrock miners have tendered no royalties on $300 billion’s worth of minerals extracted from public land over 150 years. Passed by Congress in an era when miners used pickaxes and simple machines rather than today’s voracious industrial machinery, the General Mining Law dangled easy riches as a way to lure settlers across the continent and push aside the Indigenous inhabitants. It also includes no protections for land, air or water. U.S. Rep. Katie Porter (D‑Calif.) calls the law a sweetheart deal for the hardrock mining industry. Tribes and environmentalists want the law reformed, with requirements for mining companies to consult with local communities about minimizing harm and to clean up any mess. Mining firms have a different view. The Society for Mining, Metallurgy & Exploration, a leading industry group, supports streamlining regulations instead, noting it can take 7 – 10 years to get permits for a mine. According to the group, ​“America is hindered by a costly, inefficient and often redundant regulatory structure that thwarts domestic investment, expansion and job creation.” Despite industry’s complaints, approvals of new hardrock mines have been progressing at an increasing clip over the past two decades. According to the congressional watchdog, the Government Accountability Office (GAO), the Bureau of Land Management gave the go-ahead to 728 hardrock-mining operations between 1920 and 2018. A full 500 of these approvals have occurred since 2000, according to data from the GAO’s natural resources and environment team. The bureau, part of the Interior Department, oversees almost 80% of mines on federal land. Much of today’s hardrock demand is driven by new technology. Copper and gold are critical to a range of modern technologies, and uncommon minerals, such as the lithium used in rechargeable batteries, will be essential to the transition to fossil-free energy. The United States currently has only three lithium mines, and the White House is advocating for more domestic production of lithium and other minerals that the U.S. Geological Survey identified as critical in a 2022 report. While the Biden administration emphasizes sustainable alternatives to mining, it has also opened the door to more extraction by invoking the Defense Production Act in response to Russia’s invasion of Ukraine. With a new mining boom looming, tribes and environmental groups are pushing alternatives, such as mineral recycling, and sounding the alarm about the patchwork of regulations that allow companies to stake claims without warning or consultation. The Little Rocky Mountains, just south of the Fort Belknap Indian Community’s reservation in Montana, were once verdant, tree-covered peaks sheltering a lively array of wildlife. Today, they are a pale-yellow slash on the tribe’s southern horizon. For years, orange-tinged streams poured off the slopes onto the tribal land below. The contamination came from a gold mine that had operated in the mountains from the 1860s until 1998. The mine used cyanide to extract the gold. The process produced tremendous amounts of toxic runoff, which included not just cyanide but acids created when the rocks were exposed to air. That all made its way into local tap water. In the late 1990s, the mine’s owners declared bankruptcy and decamped, punting cleanup costs to the American taxpayer. The U.S. government then banned mining on federally owned land in the Little Rockies — which comprised most of the mine — and began remediation. After more than 20 years of cleanup, the tab is at some $77 million and counting, according to Bonnie Gestring, northwest program director of the environmental nonprofit Earthworks. The water flowing off the mountains is now treated for toxins, which must be removed in perpetuity at a cost of as much as $3 million each year, Gestring says. Still, tribal members thought they had left behind the worst of a century and a half of damage — until October 2020. As the bans on mining on the land came up for renewal, the Trump administration’s scandal-ridden Interior Department caused a two-day delay in the bans’ publication in the Federal Register, a required step for them to remain in effect. This 48-hour gap left the federal land legally unprotected and, in those few hours, a mining company staked several claims. Then, in 2021, the tribe discovered that another agency — Montana’s Department of Environmental Quality (DEQ ) — had approved one mining-exploration project and was poised to greenlight yet another in an adjacent portion of the Little Rockies. This tract is not federally owned, so the state of Montana oversees related mining permits. The tribe was not brought into the decision-making, or even informed it was occurring. ​“We found out about this in the newspaper,” says tribal council member Dominic Messerly. In a January 2022 online meeting with the DEQ, scores of Fort Belknap tribal citizens and supporters — Native and non-Native — expressed their adamant, heartfelt opposition to any mining in the Little Rockies. Tribal citizens described lives enhanced by fasting, praying and herb gathering in the mountains. ​“Those are our churches,” said Jeffrey Stiffarm, tribal chairman. After the meeting, the DEQ took a step back and announced more study of the area was required and a mining permit would be subject to those investigations. But, thanks to the 48-hour gap in the mining bans, the claims on the adjacent, partially remediated federal land remain in place. Al Nash, spokesperson for the Bureau of Land Management’s Montana/​Dakotas office, which facilitates publication of the bans, tells In These Times the regulation gap was unintended, caused by ​“some unexpected delay in completing the process to publish the public notice.” Nash did not respond to questions about the possibility of correcting the delay and revoking the claims. “The whole sequence is suspect,” says attorney Derf Johnson of the Montana Environmental Information Center. Luke Ployhar, owner of the mining company — Bozeman-based Blue Arc LLC — says no backchannel communications tipped him off: He has private land in the area, had been watching the federal land for years, saw the opportunity and moved on it. Ployhar says that any mining that results from the exploration projects will result in jobs for the region. The Interior Department has serious explaining to do about the 48-hour gap, according to Sen. Jon Tester (D‑Mont.). As spokesperson Roy Loewenstein tells In These Times, ​“Sen. Tester believes there are some places that just don’t make sense to mine. The Little Rockies have huge cultural significance for the Fort Belknap Indian Community, and they’ve already seen devastating impacts on water supply from irresponsible mining in the area.” Steve Daines, Montana’s Republican senator, did not reply to repeated requests for comment. Fort Belknap Indian Community has formally requested an investigation by the Interior Department and was joined in its bid by Earthworks, the Montana Environmental Information Center and environmental group Trout Unlimited. The Interior Department has only acknowledged receipt, according to Johnson. The Interior Department’s Office of the Inspector General denied In These Times’ Freedom of Information Act request for more information, saying that the incident is under investigation. Securing answers will be cumbersome at best. In hardrock mining, there is no comprehensive nationwide accountability or transparency, says Talia Boyd, cultural landscapes manager for the nonprofit Grand Canyon Trust. Multiple federal and state agencies oversee narrow slices of large, dangerous projects with extensive human and environmental impacts. The Bureau of Land Management, Environmental Protection Agency, Forest Service, Nuclear Regulatory Commission, various state agencies and others may be involved in any particular project. No agency has across-the-board oversight, or even across-the-board information. A 2019 analysis from the GAO found that a range of federal agencies collected varied arrays of data on existing and potential mining sites and minerals, with no clear picture of the industry as a whole. “Who actually regulates any of this?” asks Boyd, a Navajo Nation citizen. The Biden administration agrees. A White House memo noted in February, ​“There is no single federal agency with authority over domestic mining,” and laid out new ​“fundamental principles for domestic mining” to reform the General Mining Law of 1872. Secretary of the Interior Deb Haaland is forming a working group to refine these ideas — ​“to update mining policies to reflect our current realities,” as she puts it. Derf Johnson is adamant: The 150-year-old law has to be scrapped and replaced with appropriate systemic change. If we do nothing more than alter rule-making, ​“It’s just eating around the edges,” he warns. Hardrock mines have been required, since the 1970s, to reclaim damaged land and, since 2001, to post bonds to ensure they could pay for the reclamation. But bonds set by the state and federal agencies that permit the mines have generally been insufficient, according to the GAO. Moreover, responsible parties — such as the former mine owner in the Little Rocky Mountains — typically declare bankruptcy instead of doing the cleanup. After a bankruptcy, Holley observes, mining companies tend to just ​“change their name, come back and start up all over again.” The House’s 2021 budget reconciliation bill imposed mining royalties and set aside $2.5 billion for cleanup, but the provisions were stripped from the Senate version by Sen. Catherine Cortez Masto (D‑Nev.), who said the use of a short-term budget process would create ​“uncertainty for the industry.” Roll Call reports the National Mining Association, which opposed the royalties, nearly doubled its federal lobbying expenditures in 2021, to $2.1 million. According to data from the research group OpenSecrets, the industry’s total 2021 lobbying expenditures were $18.5 million. The Native communities on the front lines of hardrock mining’s harms, like Fort Belknap, have far less money to advocate for themselves. When the federal government first set aside tribal reservations, often in remote deserts and plains, they were thought of as worthless. After coveted minerals were identified in these areas, the federal government set about breaking treaties and diminishing reservations. Mines then proliferated in and around many tribal lands. Today, in the 12 western-most U.S. states, more than 600,000 Native people live within about 6 miles of hardrock mines for uranium/​vanadium, gold, copper and lead, according to a 2017 study in Current Environmental Health Reports. Numerous tribal nations and their citizens are trying to warn the public at large about the dangers of hardrock mining, by speaking to the press, forming alliances with major environmental groups and bringing lawsuits. Intense public interest in the Standing Rock Sioux Tribe’s 2016 objections to an oil pipeline has created more appreciation of Indigenous issues and opinions, according to attorney Robert Coulter, Potawatomi citizen and executive director of the Indian Law Resource Center, in Helena, Mont. ​“The great victory of Standing Rock,” he says, was that the public ​“believed the Indians were right.” Coulter explains that the non-Native population came to understand that Indigenous people may not claim to own a river or the land around it but feel they have the obligation to protect them. National media has responded with more reporting on the Indigenous struggle against hardrock mining, though coverage is uneven. The battles at Fort Belknap and by the Western Shoshones have received mostly local attention, for example, though a few fights have grabbed the spotlight and pushed the federal government into action. One such case, covered by the New York Times, NPR and other outlets, is the years-long battle of the San Carlos Apaches to block an Arizona copper mine. In 2014, it looked like Oak Flat, a rugged desert landscape sacred to the tribe, would be handed over to a copper-mining conglomerate whose mine would produce a sinkhole about 2 miles wide and 1,000 feet deep. Since then, tribal citizens and supporters — including some 40 tribal governments and 150 regional and national organizations — have rallied, marched and occupied the holy place. In March 2021, President Joe Biden irked Republican members of Congress when he withdrew the Trump administration’s approval of the Oak Flat mine and called for further review. To achieve permanent protection, Rep. Raúl Grijalva (D‑Ariz.) introduced the Save Oak Flat Act. Wendsler Nosie Sr., a San Carlos Apache activist and former tribal chairman, has been a leader in the effort to protect Oak Flat from what he describes as ​“total annihilation.” He offers a national perspective as well as a tribal one. “The United States needs us Native people,” Nosie says. ​“Without us taking the lead on these issues, there would be chaos.” The Biden administration is bringing Indigenous perspectives into federal decisions. Among Native appointees to top positions in the administration are Deb Haaland, secretary of the Interior, from Laguna Pueblo, and Charles ​“Chuck” Sams III, head of the National Park Service, from the Cayuse and Walla Walla tribes. Biden also reestablished the annual Tribal Nations Summit in Washington, D.C., and reinstated the advisory White House Council on Native American Affairs. And he has advocated for updating the General Mining Law of 1872, the source of so much damage to tribal lands. Meanwhile, the administration has moved to protect a few places from mining that are especially important to tribes, such as Bears Ears and Grand Staircase-Escalante, in Utah, and the Boundary Waters Wilderness in northeastern Minnesota. Cleaning up the many abandoned mines in or near traditional homelands is also on the agenda, with $11 billion over 15 years in the 2021 Infrastructure Investment and Jobs Act. The EPA warns, however, that $35 billion is needed to complete the work. Congress is listening to Indigenous people as well. On Capitol Hill in March, the House Natural Resources Committee held a hearing on tribal/​federal co-management of public lands. Committee chair Grijalva has introduced a bill to strengthen federal requirements to consult with tribes on matters that concern them and, with Sen. Martin Heinrich (D‑N.M.), has introduced a bill to overhaul the General Mining Law. Heinrich calls the 1872 law ​“antiquated.” Grijalva agrees, adding that modernizing the law isn’t extreme or anti-industry. ​“It’s just common sense.” Earthworks’ Bonnie Gestring is heartened by these plans, saying they can lead to stronger safeguards against future travesties, such as the mining in the Little Rocky Mountains. As it stands, she says, the General Mining Law of 1872 fails ​“to provide even basic protections for our shared public lands and the communities that call those lands home.” At the same time, Biden appears open to more mining. Russia’s invasion of Ukraine led him, in March, to invoke the Defense Production Act in support of more domestic mining, ostensibly to reduce dependence on Russia and China for minerals. Grijalva and House Natural Resources Committee vice chair Rep. Alan Lowenthal (D‑Calif.) are dismayed. Job one, they told Biden, is reforming the General Mining Law. Advocates say the transition to green energy makes reform even more urgent. ​“Our current mining law was put in place before we even knew what a car was, much less an electric one,” says Grijalva. “Paradoxically, the energy transition is already causing an increase in global mining — even as we hopefully begin to leave fossil fuels underground,” says Thea Riofrancos, author of Extraction: The Frontiers of Green Capitalism (forthcoming from W.W. Norton). ​“That’s because ​‘green’ technologies, like lithium batteries and solar panels — that allow us to harness renewable energy — are themselves made with metals that come from the earth’s crust.” Riofrancos argues the only way to reduce mining’s damage is to reduce demand for it — to reduce our newfound reliance on lithium batteries for electric cars, for example, through expanded mass transit and to repair, reuse and recycle batteries and other technologies. Earthworks offers data to support this. The group reports that recycling could reduce demand for lithium by 25% and cobalt and nickel by 35% by the year 2040. Some minerals are already substantially recycled — copper at a global rate of 45%, says Earthworks. The Biden administration also supports the notion of recycling. One administration initiative will recover essential minerals — lithium, cobalt, nickel and graphite — from used lithium-ion batteries. Another will capture industrially important minerals from coal ash and other mining waste, and another will extract lithium from geothermal brine. In the end, these projects may take the pressure off small tribes fighting installation of new lithium mines in culturally significant areas of Nevada and Arizona. However, recycling will not meet the needs of the energy transition right away, says Riofrancos. Given the inevitability of more mining in the short term, she says it’s imperative to listen to tribes and their concerns. Joseph Holley, of the Western Shoshones, says mining crews bulldozed a gash across a hill where tribal members seek visions in Tosawihi, a sacred desert place in Nevada. PHOTO BY JOSEPH ZUMMO While the nation is making its way toward its domestic-mineral goals — and approving mines as it does — the federal government could help tribes, especially smaller and more remote ones, in their battles to protect people and the land, according to Joseph Holley. ​“Get out here, see what’s happening, and give us some damn help,” he exclaims. ​“For us to hire a million-dollar lawyer, it’s not happening.” In These Times lobbed Holley’s demand over to the Interior Department. Are the department and its agencies interested in supporting not just larger tribes but small, isolated ones? Richard Packer, of the Bureau of Land Management press office, says Haaland and Biden have ​“challenged” the bureau to take its consideration for tribal authority ​“to another level.” Packer says the bureau is ​“contemplating” ideas such as ​“co-management” and ​“the significance of treaties.” Holley is not surprised at the ambiguous response. For years, Holley says, the Bureau of Land Management refused to hear his tribe: ​“They never listened, they never took notes, they never took us seriously.” After Haaland was chosen to take over the Interior Department in 2020, the Bureau of Land Management ​“went bananas,” Holley says. ​“They sent letters, wanted you ​‘to be a part,’ wanted you ​‘to share.’ … It put fear in them because there was a Native in there.” But currently, on the ground in 2022, things are back to the old normal, he says. Daniel Werk, a Fort Belknap tribal citizen and cultural liaison officer for his community’s Tribal Historic Preservation Office, took part in the January online meeting with Montana’s Department of Environmental Quality. There, he talked about how he’d prepared by reading documents from the 1990s, when reclamation was first considered for the Little Rockies. “We’re just going in circles with you guys,” Werk said. He recalled that he was 11 when some of those documents were created. ​“Now my son is 12 years old, and he’s sitting here behind me listening. … When is it going to end?” This story was supported by the In These Times’ Leonard C. Goodman Institute for Investigative Reporting. STEPHANIE WOODARD is an award-winning journalist who has written investigative articles for In These Times. Her new book is American Apartheid: The Native American Struggle for Self-Determination and Inclusion.

The editor of the Grass Valley Union newspaper criticizes Rise Gold's sleazy marketing and underscores their CEO's questionable past. By Don Rogers, publisher of The Union, Lake Wildwood Independent, and Sierra Sun. Rise Gold’s PR is a disaster so far. Just sayin’. Prepaid postcards with prewritten positive responses to reopen the Idaho-Maryland Mind mailed to a few perceived friendlies? Sign here and send on to the county as if original? Maybe the Nevada County Board of Supervisors is that gullible or jaded, I dunno. Or the company is more interested in out-of-town investors and wholly unconcerned about the local population, counting more on this community’s quiet apathy than overwrought protest. Remaining politely reasonable while letting opponents punch themselves out with wild exaggerations is textbook public relations, by the way. Too bad Rise’s flaks can’t follow the script. The marketing-infused survey last summer was sleazy enough. The prepaid postcard scheme is straight out of LA. In baseball, we’d have to call this an 0-2 count. Here is Ben Mossman’s biggest whiff. HISTORY HAUNTS Reopening a gold mine is Sisyphean, for sure. History literally is against you. The legacy ain’t pretty. Neither Grass Valley’s nor Rise Gold’s own. We’re still cleaning up from careless and poisonous mining, as well as recalcitrant mining companies, going back to the Gold Rush. Mossman, the CEO of Rise Gold, still faces criminal proceedings in Canada from a mine his last company abandoned after allegedly flouting environmental regulations and leaving a toxic spill for the locals to deal with. He was fined $15,000 for minor offenses, which were set aside along with a lower court’s acquittals, in a British Columbia Court of Appeal ruling in late 2020. New trial to come. My point here is that the last thing Rise needs in a public relations strategy is flim-flam. Read the rest of the article on The Union website. Don goes on to explain why he believes the science is in Rise Gold's favor and despite community concerns, it is possible the mine might be able to reopen, BUT WE BEG TO DIFFER! The community is currently reviewing the DRAFT Economic Impact Report with a deadline for comments on April 4. They're finding major flaws in the scientific analysis, missing mitigations, and inadequate mitigations. The next draft is likely to show many more significant impacts that can't be mitigated away.

Want to know where things stand in the proposal to reopen the Idaho-Maryland Mine? The Union's newspaper's publisher sums it up. Don discusses what the community would gain compared to the risks it would assume if the mine was reopened. Here are a few excerpts. Read the full column in The Union. If Rise Gold continues on its titanic quest, the county supervisors eventually will have to consider the iceberg. I realized this recently while one of the opponents of the proposal to reopen the Idaho-Maryland Mine, John Vaughan, took me through a critique of the company’s sunny sales pitch about jobs and all those millions of dollars surely rippling outward from an operating mine. The company’s early pattern is to exaggerate benefits, as the opponents’ is to take the bleakest view. Meantime, the county awaits the results of its own economic study, due out anytime now. This will be the next step, the next run of the gantlet toward a decision, the next battle. I wonder whether real flesh-and-blood local supporters will finally come out of hiding to buttress the strongest case for the mine. If a boxing match, Round 1 was nearly a knockout for opponents, who rose in real numbers to decry the draft environmental impact report’s results with the county Planning Commission. But Rise still seems to be tottering along, and so the process continues as the CEO preps for perhaps his final criminal trial over his previous mine with the spill that went bankrupt and he abandoned in Canada. No jobs there in years. Buoyant factors for the community’s benefit are exclusively economic: jobs, tax revenue. Risk factors span economic, environmental, the gold business, quality of monitoring, regulatory enforcement, ability to clean up accidents, those wells, the history of the CEO, the company itself, the odds of reality proving modeling wrong. Some risks weigh heavier than others, of course, and elements such as heavy truck traffic around the mine, carbon emissions and impact on immediate neighbors are not risks but certainties. There might be some argument about promises to clean up a nearly century-old tailings heap and establishing a fire station at the mine, but are those benefits or simply what’s required? Which raises the question of what should be required of the mine owners to balance against the various risks inherent in the proposal. Given that, the prospects look far from unsinkable and the reward dubious for the real impact on just the neighbors, never mind the sheer weight of all the risks. Yes, iceberg fits.

The CEO of Rise Gold sent an email to a county employee calling the county “naive” in its dealings with the Nisenan. Spokeswoman Shelly Covert's response is well worth reading. This article was originally published in the Union and was quickly followed by R.L. Crabb's cartoon. Rebecca O'Neil April 14, 2022 [Excerpt] The CEO of Rise Gold Corp. inadvertently sent an email to a county employee calling the county “naive” in its dealings with the Nisenan. Ben Mossman’s comment was in response to an April 4 letter by attorney Frank Lawrence, who makes the argument that the consultant who wrote the draft environmental impact report for the Idaho-Maryland Mine failed to consult with the Nisenan. The tribe is on the state’s Native American Heritage Commission’s Tribal Consultation List, making it entitled to “meaningful consultation,” Lawrence states. “The revised DEIR must propose meaningful mitigation for the badges and incidents of the genocide, the theft of Tribal ancestral lands, the theft and destruction of Tribal natural and cultural resources, and the destruction of the Tribe’s traditional way of life,” Lawrence states. Mossman’s reply wasn’t intended for Lawrence, said Jarryd Gonzales, spokesperson for Rise Gold, in an email. “The county is so naive in trying to assist this group to gain status,” Mossman stated, referring to the Nisenan in an email reply to county planner Matt Kelley and Lawrence. “Welcome to Canada.” “Rise Gold CEO was forwarded Mr. Frank Lawrence’s April 4 comment letter by a team member. In error, Mr. Mossman sent a short reply that was not intended for Lawrence,” Gonzales said. Read the rest in the Union.

This "alternative use" proposal would use the existing mine tunnels as an emergency water source and reflects on the complex geology that could affect wells beyond the predicted area. This opinion piece was originally published in The Union. It is likely our community would survive another 80 years without a gold mine. We won’t survive that long without water, which is rapidly becoming the world’s new gold. Current climate trends and over-development increase the likelihood we will face water rationing, higher rates and increased pressure to build a new dam. Are there alternatives? According to Nevada County documents, the Idaho-Maryland Mine contains between 576 to 815 million gallons of water as well as ongoing mine inflows — all to be pumped and dumped by mine operators into a local creek after improving to “drinking water standards.” The inflow is “pass through” water from natural sources. Outflow would be less than inflow due to mine operations, I believe reducing Nevada Irrigation District’s currently available downstream draw and likely leading to higher water rates for NID customers. As the mine is part of the currently stable water table system, a severe drop in mine water levels is expected to affect local wells and may, as critics point out, affect wells far beyond the areas predicted by incomplete modeling and old records. The problem is our complex geology. Where influx water comes from is an open question. Well owners and the mine get water from cracks in bedrock that collect and transfer water — but it is only guesswork as to how far and wide these cracks extend, leading to questions as to how far well dewatering could occur. Here are a few more thoughts for consideration: ∎ A Sierra College geology teacher once said that Nevada County’s geology is some of the most complicated in the state, noting that the water outflow on the public spring on Bitney Springs Road likely originates at much higher elevations. ∎ Local fracturing includes an earthquake fault three miles west of Grass Valley, running from Lake Oroville to beyond Auburn. ∎ Opening up gold-containing fractures raises more water movement questions. While the North San Juan Siskon disaster involved different geology, the principle is the same. ∎ At a city of Grass Valley-hosted forum on water issues for the previous (Emgold) proposal, mine proponents maintained that mining operations would be below existing ground water tables, so wells would not be affected. When then asked about where mine water came from, the vague response referenced uncertain geology around Wolf Creek, raising the possibility of partial creek dewatering if the mine were drained. There may be a higher and better use for the mine. As we face the prospect of extended and possibly worsening drought for the foreseeable future, new water sources will have to be found. The mine could potentially serve as a supplemental or emergency water source. In some ways, mine water storage is little different than a new dam but without eminent domain, massive construction costs, ecological negatives, etc. Effects on local stream levels would be comparable to a dam’s varying stream flow impacts but on a smaller scale. As a supplement to existing supplies, this could offset the need for a new dam for years. Estimates of the mine’s water volume range from 1,767 to 2,501 acre/feet. At California’s typical annual household usage of one half to one acre feet, the mine holds enough water to serve 2,500 or more homes for one year, making it a potential alternative revenue source for mine owners. Drawn down in drought years and recharged in wet years, the mine water would be continually renewed at no cost beyond providing water to affected well owners. Even seasonal use is possible, as summer drawdowns would be eventually restored to Wolf Creek through our sewer system (minus evaporation from garden use, etc.). Truckee just bought water from PG&E for about $38/acre foot and urban users pay as much as $1,500 to $2,000/acre foot; some farm districts pay much more. Sale of mine water could generate anywhere from $67,000 to several million dollars and becomes a sustainable local water — and revenue and job — source beyond the mine’s predicted lifespan. Add in another profitable, clean, renewable and local job-producing opportunity for mine owners: a biomass plant. The Brunswick site was identified by Nevada County’s biomass research group as a possible biomass (logs, branches and brush) energy plant location. This is the place that recently had mountains of storm damage biomass — free energy — hauled away to a distant biomass plant. It’s time for local leadership to take climate change seriously. The mine site offers better — sustainable — options than extracting sort-sighted profit. Terry Lamphier lives in Grass Valley.

Local nonprofit, Earth Justice Ministries, brings a spiritual and moral perspective to aesthetics, cumulative impacts, and the need to repair previous harm done. This opinion piece was originally published in The Union. Our organization, Earth Justice Ministries, is a local nonprofit that brings a spiritual and moral perspective to bear on issues of our day. We echo the concerns of everyone who is speaking out against the harmful effects that would come from reopening the Idaho-Maryland Mine. Our organization signed on to the coalition statement critiquing the draft environmental impact report submitted for the mine. We fully support that statement. Our statement focused on what is listed in the report as “aesthetics,” the mine’s cumulative impacts, and the need to repair harm done. Aesthetics are downplayed as a concern in the report, but beauty is a value, as in “the beauty way” of the Navajo people. A beauty that touches the hearts and minds of people. It is that natural beauty of Nevada County that brought so many of us here, and that brings so many visitors — the sights, the sounds, the smells of this place — the taste and feel of clean water, the fish in the streams, the wildlife. People come here to experience the beauty, to experience a deeper reality that puts things in perspective. To many, the natural beauty here is like church, reconnecting us to what is most meaningful in life. The final environmental impact report must adequately list in detail the mine’s specific aesthetic impacts. The aesthetic value of this region may be classified as quality of life, especially in the vicinity of the mine. There would be more truck traffic, higher noise levels, and possibly vibration from blasting. The natural landscape would be buried beneath mine waste and paved industrial areas. The final report should honestly report that such aesthetic damage cannot be quantified or mitigated. As an organization concerned about environmental harm, we support the Nevada County Energy Action Plan, which calls for gradually reducing annual residential electric use by 12% in accordance with California state goals. Rise Gold’s projected electrical use would cancel out this goal and add significant carbon to the atmosphere. The California Air Resources Board 2017 Climate Change Scoping Plan states: “Achieving no net additional increase in greenhouse gas emissions, resulting in no contribution to greenhouse gas impacts, is an appropriate overall objective for new development.” This should be our goal. The final environmental impact report must establish a net zero threshold for new greenhouse gas emissions from the project and declare that it has significant and unavoidable impacts. Mitigations cannot overcome the mine’s cumulative impacts. Those impacts would work together to decrease our quality of life by risking increased air and water pollution, dewatering wells, harming Wolf Creek, higher greenhouse gas emissions, injuring plants and animals, raising noise levels, damaging roads, and yes, wounding the beauty of this place. Even if Rise Gold’s proposed mitigations were implemented, monitored, and enforced for 80 years, such mitigation would only lesson harmful impacts, not eliminate them. The mine’s inevitably harmful impacts to our community are not acceptable at any level. Cumulative harm should be listed in the final environmental impact report as significant and unavoidable. There is still much damage to repair from the Gold Rush, including genocide committed against the Nisenan people and other nearby tribes. The earth and people were so damaged that the toxic legacy continues today. Healing from the past includes respecting the earth that gives us life, making reparations for harm done, restoring the land and air, and changing our ways so that we are in a right and good relationship with this place, its people and creatures. We cannot heal from the past if we continue adding to the harms by opening this mine. Guarionex Delgado, Brian Fry, Dianna Suarez, Sharon Delgado, Jonah Platt, Becky Gillespie, Michelle Montgomery and Josie Crawford sit on the board of Earth Justice Ministries.

The mine report uses categorization to stay below arbitrary, outdated thresholds, says Citizen's Climate Lobby Nevada County chapter Director David Whitehead. This opinion piece was originally published in The Union. All across California, communities work hard to address climate change. We develop plans for increased recycling and increased renewable energy use. We support our local farms to improve sustainable food production. We purchase low-emission cars, appliances, and sustainable energy sources. And we know we have to increase our efforts to meet our goals. Our challenges ahead are truly substantial. Four years ago, I helped form the Nevada County Chapter of Citizens’ Climate Lobby/Education, joining the efforts of other non-profit organizations already working on climate. You may have seen our chapter volunteers at the farmers markets. We have met over 600 community members who want to learn how to take climate action. We work with local churches on climate education and action programs. We lobby candidates and our elected officials to support real climate change solutions. So when I read the draft environmental impact report for the Idaho-Maryland Mine proposal, I was very disappointed. Rise Gold proposes to generate significant amounts of carbon and greenhouse gasses every year. If you take their estimates at face value, they would create over 3,500 metric tons of CO2 during construction, and over 9,000 metric tons during operations. These emissions would be new to our community, and they would undermine state of California climate goals. State Assembly Bill 32 (2006) set carbon emission goals for 2020. California’s Climate Scoping Plan (2017) sets goals for 2030 and beyond. To meet these goals, every community must reduce emissions. Rise Gold’s proposal ignores these goals. Rise Gold proposes to purchase carbon offsets in California’s cap and trade markets during “construction” only. Using categorization to stay below arbitrary, outdated thresholds, Rise Gold would not mitigate their emissions during the following 78 years of operations. Rise Gold proposes to mitigate approximately 2,500 metric tons of CO2 per year when they call it construction. Then, when they call it operations, they wouldn’t mitigate any of carbon dioxide they produce annually. They may produce more than 700,000 metric tons of the greenhouse gas over the life of the project. Particularly galling is that Rise Gold says in the draft environmental impact report that they think this plan is acceptable because the citizens of California have cut their carbon footprint since 2006, working hard to reduce carbon emissions and greenhouse gas in our communities. To give an idea of how much CO2 Rise Gold would create, 10,000 metric tons would be roughly equivalent to the emissions created by building 450 [1] new homes in Grass Valley. But it’s an imperfect comparison because many of the people buying those houses already live in California. Their carbon emissions already exist. Rise Gold proposes to create completely new carbon emissions on land that currently produces zero carbon emissions. It would be as if 450 alien households from outer space landed on the property and began polluting. Citizens’ Climate Lobby estimates that the true cost of carbon in the United States is around $80 a ton. This figure includes all the costs we citizens currently pay to emit carbon per our standard of living. Carbon offsets on the market currently range in cost from between $10 and $30 a ton. These offsets are what Rise Gold would purchase. In other words, we pay $80 a ton and Rise Gold would pay as little as $10 ton to pollute our atmosphere. Therefore, we would subsidize Rise Gold for as much as $70 a ton. They would take gold from our community and enrich themselves in exchange for creating 350 jobs and polluting our air. As we attempt to reconfigure our society to address climate change, we would subsidize Rise Gold so they could make climate change and global warming worse. The draft environmental impact report says reopening the Idaho-Maryland Mind itself would not cause climate change, and that is true. But if communities across the state and nation approve projects like Rise Gold’s proposal, there is no way we could be effective in addressing climate change. That impact is called the “cumulative impact.” Our lives and property are threatened by climate change: wildfires, drought, sea level rise, more powerful storm events, etc. Rise Gold says to us: We can’t see you. We can’t hear you. We want that gold. But their mine proposal would undermine our climate change work. We citizens would have to work much harder to reduce the horrible impacts of a warming world if projects like reopening the Idaho-Maryland Mind are allowed to go ahead as proposed. As lead agency, Nevada County must hold Rise Gold to a higher standard. To do otherwise is just irresponsible. The deadline for comments on the draft environmental impact report is April 4. Please submit a comment. David J. Whitehead lives in Grass Valley. Footnotes Per CEA Foundation, the estimate of 450 homes above would be raised to 690 homes if taking into account the EPA's more current determination that 25,000 metric tons are equivalent to approximately 2,300 homes. According to this calculation, the annual emissions described in the DEIR for the Idaho-Maryland Mine Draft Environmental Report of 8.982.87 equates to about 690 homes. In a similar calculation, this level of emissions would be equivalent to 1,656 new vehicles.

After a year of following mine news, this conservative Union columnist still believes the negatives overwhelm any good the mine could bring to our community. This opinion piece was originally published in The Union. Almost a year ago in this column I waded into the discussion about the potential reopening of the Idaho-Maryland mine by Rise Gold Corp. At the time, I was skeptical about Rise Gold’s claims and have since closely followed the news articles, research and progress of this proposal. To date, nothing has been presented sufficient to change my belief that the negative aspects of this project overwhelm any good that may come to our community. Specific environmental issues have been discussed in depth in this newspaper, including the potential dewatering of wells situated near the mine, air quality, vibrations from blasting and other mine operations, noise and decibel levels, gravel-hauling trucks making up to 100 round trips per day for seven days a week on Brunswick and Whispering Pines, as well as trucks on our roads transporting fuel oil, diesel fuel, explosives, and other flammable supplies. Carefully researched information on those environmental issues has been presented by multiple residents in our community with far more experience and knowledge than myself. The draft environmental impact report concludes that every one of the impacts is between neutral or negative, with many significantly negative. None are neutral positive. Absent any positive impact, there must be a significant economic or quality of life benefit to offset the negative environmental aspects to justify this project. To gain more insight into the actual logistics of a project of this scope, I have been communicating with a local friend who has decades of experience as a project manager on multi-million dollar development projects in the United States and around the world. He has served as a consultant on the preparation of a number of environmental impact reports and economic evaluations and has been engaged by multiple governments on projects where response to an environmental review was required. I found his reflections on the current proposal to reopen the Idaho Maryland mine to be very valuable, as they were based upon years in the field dealing with exactly these types of scenarios. Whether the draft report understates the negative environmental impacts of this project or not, the report requires monitoring and mitigation, and currently there are no teeth included. In similar projects my friend has been involved in worth hundreds of millions of dollars, the approval by the city, state or county requires payment to the public entity for the continuous monitoring of the environmental conditions. If the Board of Supervisors were to approve this project, it should minimally require a specific performance bond to fund any mitigation that may be needed to correct deficiencies for the life of the project, which is currently proposed to be 80 years. The county would then have the legal authority to tap into the bond to mitigate problems should Rise Gold not do so in a timely manner, or if they should file bankruptcy, as they have done in the past. My friend’s recommendation for a project of this scope, based upon his experience, was that the mitigation bond should be $100 million, which could potentially be decreased by mutual agreement after several years of successful operation. He observed that Nevada County has no ability with current staff or budget to adequately monitor environmental performance, as well as to review and authenticate the reports required to be filed by the operator. Estimates for continuing monitoring of this project could require one and one-half full-time employees, at a cost of approximately $180,000 per year. The operator should be charged a fee each year to cover the cost of year-round monitoring and evaluation, and if the fee is not paid, the funds could be drawn from the performance bond. My friend also challenged the employment projections made by Rise Gold. Rise Gold’s latest glossy mailer claims that “Our project will create over 600 jobs and $50 million in new local spending annually …. Reopening the mine means over 300 new employees in safe and satisfying careers with an average expected annual earnings of more than $122,000, including benefits. The mine will also spur an additional 300 jobs through related new business in the area.” This will simply not occur, as a large proportion of the two-week-on, two-week-off employment will be out-of-area workers who will not relocate to the county, and their spending patterns will be only a fraction of those represented. My friend has just completed five years of work in the oil fracking fields of North Dakota, where $80,000,000 of county funds were spent to mitigate the impact of thousands of transient workers coming in to work two-week shifts of 12 hours on, 12 hours off. Workers coming from out of Nevada County would have a negative impact on temporary low-cost housing — of which Nevada County already has a shortage — law enforcement, road maintenance, traffic improvements, public health, and other county costs, with no resulting increase in property taxes and very little impact on sales tax. In contrast to Rise Gold’s claim that “the Idaho Maryland Mine will strengthen and diversify the local economy and provide a brighter future for Nevada County families,” it looks more like reopening the mine would only negatively impact the environment, increase the cost to the county for services, require constant monitoring, and produce only a fraction of the jobs promised for current unemployed workers. I am not convinced that Rise Gold’s claims would ever reflect reality for this community. Terry McLaughlin, who lives in Grass Valley, writes a twice monthly column for The Union. Write to her at terrymclaughlin2016@gmail.com

CEA Foundation President, Ralph Silberstein explains why GHG thresholds set in the draft environmental report are no longer relevant. To determine the level of "significance" related to emissions from the proposed Idaho-Maryland Mine, Nevada County chose a threshold of 10,000 metric tons per year, but legal experts at the respected environmental law firm, Shute, Mihaly, and Weinberger LLP, make the case for why the County needs to consider "net zero" as the threshold instead. This opinion piece was originally published in The Union. Ralph Silberstein: Idaho-Maryland Mine greenhouse gas impacts and the draft environmental impact report The draft environmental impact report for the Idaho-Maryland Mine project includes an assessment of the environmental impacts from greenhouse gas emissions. These emissions are from carbon dioxide and other greenhouse gases such as methane, which are the major contributors to climate change. To determine the level of impact from the emissions, Nevada County used a threshold. Anything over the threshold would be classified as “significant” and would require additional actions, or “mitigations,” to reduce the severity of the impacts. However, as stated in the draft report, neither the Northern Sierra Air Quality Management District nor Nevada County “has adopted numerical thresholds of significance for greenhouse gas emissions that would apply to the project.”[1] Instead, Nevada County chose 10,000 metric tons per year as the threshold. The county determined this threshold by looking at air districts for Placer County, Sacramento Metropolitan Area, the Bay Area and Southern California. The draft report calculated that emissions from mine operations would be just under the 10,000 metric tons threshold for the bulk of the mining operations.[2] The largest contributor to greenhouse gases would come from PG&E electricity, followed by emissions from trucks hauling mine waste rock and tailings off site. Consequently, the conclusion was that the emissions would be “less than significant,” and no mitigations were proposed. (Note that construction greenhouse gas emissions are calculated separately, are listed as significant, and mitigations are proposed.) WHAT CEA Foundation ANALYSIS REVEALS Each California air district has unique air quality conditions with standards that are established by an inventory of those conditions. As explained by the Baseline Engineering Consultants’ report addressing the draft environmental impact report, the thresholds that Nevada County chose to use were established by other districts prior to the 2016 California SB32 statewide update of greenhouse gas reduction targets. Those changes reset the reduction targets to reduce emissions to 40% below 1990 levels by 2030.[3] Thus the thresholds used by the other districts referenced by Nevada County are no longer relevant. In fact, at least one of the districts is undergoing review to reset their threshold to conform to the current California SB32. Nevada County’s use of the 10,000 metric ton threshold for the draft report was not adequate in the first place due to the different conditions in the various air districts. In addition, due to the changes in state targets, that 10,000 metric ton threshold is certainly not valid now. As summarized by Shute, Mihaly and Weinberger LLP in comments prepared on behalf of CEA Foundation: “The DEIR must use a significance threshold that will achieve California’s new statewide greenhouse gas reductions goals over the proposed 80-year lifetime of the project. In light of those state goals and the severity of climate change, any operational emissions over existing conditions should be considered significant. “Since 2010, scientific research has made clear that any additional emissions will contribute to the serious and growing climate crisis. See Intergovernmental Panel on Climate Change, Climate Change 2021: The Physical Science Basis, Summary for Policymakers (October 2021), attached as Exhibit I. “Recognizing this reality, in 2018 Gov. 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. See DEIR at 4.3-29. “Given these facts, the DEIR should establish a net zero threshold for new greenhouse gas emissions from the project. See e.g., CARB 2017 Climate Change Scoping Plan, attached as Exhibit J, at 101 (’Achieving no net additional increase in greenhouse gas emissions, resulting in no contribution to greenhouse gas impacts, is an appropriate overall objective for new development.’) The DEIR does not explain why the project should not be judged by a significance threshold requiring no net increase in greenhouse gas emissions.”[4] The draft environmental impact report states greenhouse gas emissions from mine operations would be just under 10,000 metric tons per year. This number was chosen as a threshold based on other air districts in California. Neither our Air Quality Management District nor Nevada County have adopted numerical thresholds of significance for greenhouse gas emissions that would apply to the project. The draft environmental impact report does not discuss the justification for adopting the 10,000 metric tons per year threshold, nor does it provide substantial evidence for applying this threshold to the project to demonstrate how it will achieve a fair share of the statewide greenhouse gas reductions goals for 2030 and beyond. Ralph Silberstein is the president of the Community Environmental Advocates Foundation. ***Footnotes*** [1] Idaho-Maryland Mine Draft Environmental Impact Report, Section 4.3, pgs 93-94. [2] Ibid, Table 4.3-23,DEIR Section 4.3, pgs 93-94 [3] Baseline Consulting Report 2.15.2022 (FINAL).pdf, pgs 18-19. [4] Shute, Mihaly, & Weinberger LLP, Comments to the Idaho-Maryland Mine Project Draft Environmental Impact Report, pg 45 (download the comment from this page).

The Grass Valley City Council hired its own consultant to review the mine report. Citing multiple deficiencies, recirculation was recommended. The Union | William Roller April 13, 2022 {Excerpts] A consulting group told the Grass Valley City Council this week that there are multiple technical deficiencies in the draft environmental impact report for the Idaho-Maryland Mine. Jeffrey Harvey, principal and senior scientist with Harvey Consulting group, LLC, pointed to a proposed 80-year permit for the mine, as well as water quality and emissions, when delivering his presentation Tuesday to the council. He recommended the county revise the draft EIR, recirculate it and again go through the public comment process. Mayor Ben Aguilar said the city is not deciding the issue, but opted to hire Harvey to analyze the document and provide adequate comment. Harvey told the council that the property is within its sphere of land use, and ought to have it reviewed before the Nevada County Board of Supervisors votes on it. A vote by that board isn’t yet scheduled. According to Harvey, Rise Grass Valley, the company seeking to reopen the mine, purchased the land and mineral rights from Emgold in 2017 and requested a permit to reopen the mine for 80 years. “The previous total granted by the city was only 20 years, made a big difference,” said Harvey. Harvey added that mine production is proposed for 365 days per year, and includes disposal of mining residuals, 150 tons per year, with some backfill to be stockpiled on mine sites and some exported to local construction sites. The Harvey Group recommended the Nevada County Board of Supervisors, which will decide whether to approve the mine’s permit request, reconsider the whole approach. “We suggest a 30-year alternative, with 10-year environmental performance reviews and adaptive management as needed,” he said. “We also recommend reducing operational size by half to 500 tons per day, still a sizable operation. And we’re looking at operational hours from 7 a.m. to 10 p.m. We’d change to daytime hours only. The Centennial Site (10344 Centennial Drive) is proposed to have mine residual fill and it’s not really acceptable for that material. It really should be permitted as a separate industrial project.” WATER, EMISSIONS Harvey said water testing should be monthly, and if results indicate problems it should be monitored more closely. Additionally, Rise plans to use diesel equipment in mines, though Harvey said underground equipment should be electric as well, as greenhouse gas receptors have not included a map where they would be located. To read the rest of the article, go to The Union.

Nevada City singer/ songwriter Charly Price says he hopes we can keep our county from taking a big step backward!

Rise Gold wants everyone to believe that people near the mine won't be affected by vibration or risk losing their wells, but a closer look at their data reveals a very different story. Read this piece in the Union. Watch Ralph Silberstein talk about the risk to wells in this video from the March 2021 MineWatch meeting. Many people in Grass Valley live and work over the Idaho-Maryland Mine without realizing it. A lot of information about the location of the two surface sites and the project features has been circulated, but not much has been shared about the sheer size of the project underground and how that may affect us. The underground mineral rights of Rise Gold are massive, covering 2,585 acres. They extend north as far as the edge of Glenbrook Basin. To the south they run to Highway 174. On the east side they extend under the entire airport area, and on the west they run completely under Sierra Nevada Memorial Hospital. Planned underground blasting, stoping and other mining activities will potentially impact anyone living or working in this area due to vibrations from the shock waves. The report on explosives that was submitted by Rise Gold estimates the impacts of blasting, with the goal of keeping shock wave velocity below a threshold of 4/10 inch per second (0.4 in/s) at neighboring properties. This is deemed as an “acceptable standard” because, according to the studies cited, “… human complaint factors were studied and it was determined that less than 8% of people would complain.” Note that, also according to the report, people can feel 0.1 in/s. As unacceptable as it may be for those impacted, Rise claims that it can comply with this “acceptable standard” by using a time-phased technique of blasting and because the initial mining activity will be more than 500 feet from residences. However, once the mine is opened there is nothing stopping Rise Gold from drilling or tunneling anywhere within their mineral rights area and to within 200 feet of the surface. Wells are of even greater concern. Due to dewatering of the mine, there will be lowering of the ground water levels in the area. The predicted amounts of ground water drop are detailed in a hydrological study based on a computer simulation. This study shows that dewatering will lower ground water levels 5 to 10 feet over a fairly large area between Idaho-Maryland and East Bennett Roads, and some other areas. Overall, of the 334 wells identified in the study, it specifically lists 152 that will experience a 1 to 10 foot drop in water levels. What is worrisome is that this groundwater study depends on a lot of assumptions that mask the true risk. It depends on the assumption that the stratigraphy is uniform, that it conforms to their computer model throughout, and that no additional fractures, faults, tunnels, shafts or permeable rock features will be intercepted. But perhaps most concerning, the study assumes that the mining will be limited to a small portion of the mineral rights area, accounting for only one-third of the project lifespan. I think the threat to wells extends far beyond the boundary of the mineral rights. And while the blasting is a problem for anyone near active mining, the potential loss of well water is a far greater problem. It was only a few years ago that, after reassurances of no serious risks to local wells, a permit to another mining company was obtained to reopen the San Juan Ridge Mine. Early operations hit a fracture, drained off the groundwater, and ruined 12 wells in the North Colombia area. Even today, Grizzly Hill School has to truck in water because their local wells remain polluted. We cannot rule out that a catastrophic event like that could happen here. Needless to say, having your well level drop even one or two additional feet in the summer can be a make-or-break situation, and that is the smallest of impacts predicted by the study. When your well starts sucking air, there are no quick fixes! How would you establish a claim? Could you obtain compensation? How many months or years would it take to get a replacement well or get a NID connection? These are serious questions. The reality is, the study acknowledges that at least 152 wells are going to be impacted and it does not say with any certainty that the dewatering and expansion of the mine won’t cause an even greater loss for well owners, or even a catastrophe like the San Juan Ridge Mine. Simply put, this mine should not be permitted. ******* [1] “Groundwater Hydrology and Water Quality Analysis Report...”, https://www.mynevadacounty.com/DocumentCenter/View/34132/Groundwater-Hydrology-and-Water-Quailty-Analysis-Report---ADDED-4242020 , Sheet 1, Pg 137 of 151. [2] Project Overview Mineral Rights Map, https://www.mynevadacounty.com/DocumentCenter/View/33570/Project-Overview---Mineral-Rights-Revision-1---ADDED-392020 . [3] “Project Elements and Current Conditions”, https://www.mynevadacounty.com/DocumentCenter/View/30401/Project-Elements-and-Current-Conditions [4] Stoping – A technique for removing ore bearing rock. Rise plans to use long hole stoping, which involves working a mass of rock above an open area and blasting to cause it to fall in a massive collapse. [5] “Environmental Factors of Blasting Report”, https://www.mynevadacounty.com/DocumentCenter/View/30457/Environmental-Factors-of-Blasting-Report , pg 7. [6] “Environmental Factors of Blasting Report”, pg 10. [7] “Groundwater Hydrology and Water Quality Analysis Report...”, Sheet 1. [8] Itasca, “Predictions of Groundwater Flows...”, https://www.mynevadacounty.com/DocumentCenter/View/34136/Groundwater-Model-Report---ADDED-4242020, Fig 5-4, (pg 67 of 93). [9] Itasca, pg 6 (pg 18 of 93). [10] Itasca, pg 10, 19, 21. [11] Itasca, pg 34 [12] “A Brief History of the San Juan Ridge Mine”, San Juan Ridge Taxpayers Association, https://www.sjrtaxpayers.org/history/

This piece paints a vivid picture of how our lives would change due to the scope and impact of living with a major industrial operation. If our elected officials vote to reopen the mine, they need to go in with their eyes wide open. This opinion was originally published in The Union. As we consider whether our elected officials should allow Rise Gold to reopen and operate the Idaho-Maryland Mine, we need to go into the decision with eyes wide open. The facility is projected to operate for 80 years, which means that kids and grandkids who are still a twinkle in the eye could be born and die before the mining operations end. So we owe it to them to think this through. Let’s be frank, gold mining is a major industrial operation. Its scope and impact is unlike any other business we have in the area, so we have nothing to compare it to, except rose-colored visions of the past. The mine closed in 1957, so most people who’ve lived here all their lives don’t know what it means to live in an industrial town. Although I raised my family here, I was born and raised around Detroit and worked in an auto factory there, so I’ll offer another perspective. First, prepare to give up the quiet. Heavy industry yields to nothing, because time is money, and money is everything. Enjoy those quiet mornings on the porch before work, drinking coffee, reading The Union, and listening to birds sing? Forget it. Diesel trucks will be loading rock and hauling it away. Think of the brief noise when Waste Management picks up trash in your neighborhood and extend it for the full day, every day. Although I live miles from the freeway, I hear the traffic from there just fine, so I’m sure I’ll hear the noise from tons of rock dumped into metal truck beds all day long, and so will you. And those kids I mentioned earlier? They’ll never know what it’s like to live in a place where you can hear the wind whisper in the trees and the morning bird songs uninterrupted. But hey, there’s money to be made. Then there’s the dust and the smoke. Every industrial facility releases its own unique mix of particulates into the air, and this one will be no exception. Dust from crushed rock and diesel soot don’t respect property boundaries, so we’ll all share in the bounty. The health effects from this stuff are numerous, but beyond that, once it lands, it tends to coat everything, making a whole town just a little more grimy, even inside buildings. If you’ve visited the owner’s cottage at the Empire Mine and seen those heavy curtains they used at the front entrance to try to keep the dust and noise out, you’ll get the idea. But I’m sure those future kids will have fun drawing things in the dust on the back windows of everyone’s cars. And of course, there are the unavoidable toxins and emissions that come from industrial operations onto the land and into our air and streams. If you think California’s environmental laws are going to protect us from bad operational decisions (like those Rise Gold’s CEO is defending himself from in a Canadian court), think again. There are thousands of families all over California with industrial facilities within spitting distance — sometimes literally — of their homes. Their kids carry around inhalers because the emissions from the facilities have given them lifelong asthma. Do our environmental laws keep that from happening? Nope. When their parents complain, are pollution controls added? Rarely. Are the facilities shut down? No. They just roll on. Why? Because corporations don’t play by the same rules as the rest of us. If you or I burn toxic trash or make noise all day or dump our garbage on someone else’s property, someone calls the police and they force us to stop or arrest us. When a corporation does it, it’s called doing business. They pay a fine — a built-in cost of doing business — or if they’re sued, they hire a pack of lawyers and drag it out in court for years or decades while continuing to make noise and pollute. And by the time the whole thing is settled, those little kids we were concerned about in the first place are adolescents who weren’t able to play in the polluted river or are having trouble breathing. And when Rise Gold decides to change its operational plan to increase its profit at our expense, they won’t be consulting local citizens or elected officials for our permission. If you like living in an industrial town, the world’s full of them — take your pick. But what we have here is rare. And once it’s gone, it’s gone forever. Mark Wilson lives in Nevada City.

Rise Gold's biological assessment report on the 129 acre Brunswick site says they "did not record any observation of deer," but their next door neighbor, Mike Shea, calls them out on their absurd claim and talks about how privately-funded reports can easily distort science. Read the original op-ed in The Union. The video below was added in February 2022. Here is Mr. Shea's explanation: That report stated, “The field survey did not record any observations of deer.” This is no doubt an accurate statement if it means the botanist didn’t see any actual deer. But any deer hunter walking the property would have noticed the deer trails, scat, and bedding areas located there. It’s pretty unbelievable that the botanist didn’t see any of this. Yet they chose to word their report in such a way to give the false impression that there are no deer on the property. They could have said, “There are numerous signs that deer live on the property, but no deer were observed.” See the difference? The survey goes on to say, “The Brunswick area does not contain any known major deer migration corridors, known deer holding areas, nor critical deer fawning areas.” Well if they didn’t see any deer, of course they can conclude all that. I live next door to the property and can attest that bucks, does and their fawns live there, along with many other animals — rabbits, skunks, squirrels, coyotes, raccoons, and the occasional bear. But who will our county supervisors believe? Me, a homeowner, or Rise Gold’s paid botanist? Would Rise Gold submit a report that doesn’t support reopening the mine? There’s no way we can know. And isn’t it strange that all the potential issues their report did identify were either “less than significant” or things that could easily be mitigated? They want to build an industrial-scale processing facility and underground gold mine and run it for 80 years, but nothing is going to go wrong. No fires, floods, tunnel collapses, toxic atmospheric contaminants, dust or gas explosions, or premature blasts? That’s not realistic. Rise Gold doesn’t want to open a mine here for our benefit. They hope to make the corporation’s owners and investors rich. They will do what other corporations do to make money and cut costs where they can. (In case you weren’t aware, both Rise Gold Corp. and Rise Grass Valley Corp. are not incorporated in California, they are both incorporated in Nevada where there is no state income tax.) And the motivation of those of us against the mine? We aren’t doing it for financial gain. We are trying to protect the place where we live and that we love. In his June 8 op-ed in The Union, Ben Mossman claims that the majority of information given by people who oppose the mine is “either biased or misleading and based neither on science nor logic.” Seems like the same could be said for him. Mike Shea lives in Cedar Ridge.

Local resident Robert Hubbard concludes that the Noise section of the Draft EIR is only as good as its data and is based on best-possible conditions, not real life. This opinion piece was originally published in the Union. The recently published draft environmental impact report for the proposed reopening of the old Idaho Maryland Mine needs careful scrutiny. Taken at face value, it concludes that the project would have no impact on the community that could not be mitigated. The report is based on language and measurement values provided to it by Rise Gold, and is correct in its conclusions only to the degree that that language and those measurement values are correct. The real-life conditions could be quite different from the conclusions in the report. Evaluating the level of impact should be based on worst-case conditions, not best-possible conditions. The ambient noise levels used in the study are currently four to five years old. The operations at issue will not start occurring for several years in the future, so these noise levels will likely not reflect the actual ambient noise at the time operations actually start. The conclusions are questionable. The Nevada County General Plan, Table 4.10-4, notes: “(The noise) standards shall be measured only on property containing a noise sensitive land use as defined in Policy 9.8 and may be measured anywhere on the property containing said land use. However, this measurement standard may be amended to provide for measurement at the boundary of a recorded noise easement.” Rise Gold has chosen to measure and compute noise levels at what they call “the nearest receptor,” which in the case of the multi-acre parcels surrounding the mine operations is the residence on the property located at the greatest distance from the mine operations. To provide a realistic level of the impact on the property, those measurements and computations should be made at the property boundary, rather than the far end of those properties. The draft environmental impact report also says: “Assuming a bulldozer, grader, excavator, front-end loader and compactor were operating concurrently at the Brunswick and Centennial industrial sites, … it was assumed that all of this equipment could be operating concurrently, but that the equipment would be spread out over the sites during the site clearing/construction operations. As a result, average noise levels were predicted for the Brunswick and Centennial industrial sites … assuming the noise sources were distributed throughout the sites, … based on the closest proximity of the equipment to the sensitive receptor locations.” This seems to be a false assumption, since these machines work jointly to accomplish their task, and would sometimes be operating in close proximity. The impact report is full of statements that use “is assumed” and “is projected to be” as given fact in arriving at its conclusions. Sound level calculations for the the report’s tables are based on values for construction noise from The FHWA Roadway Construction Noise Model, and shown in Table 4.10-10. These values differ substantially from sound levels shown in the Noise Navigator Sound Level Database, published by the University of Michigan Department of Environmental Health Science. For example, where the noise model shows compactor and front end loader sound levels at 80dBa, the Noise Navigator chart lists them as 92 and 93dBa. An earth scraper in Table 4.10-10 is listed at 85dBa. In the Noise Navigator chart, it is 107 to 111 dBa. The noise level values on the Noise Navigator chart are twice and four to five times those on the chart used in the impact report. The actual machines to be used, the true sound levels of those machines, the real numbers of those machines in use at any given time, and their locations around the working locations at any given time are not actually known. The impact report describes a sound monitoring plan that says: “If the results indicate that the county noise standards are being exceeded either by individual equipment or processes, or cumulative noise generation of the entire facility, operations shall cease until additional engineering controls can be implemented as needed.” At this point, Rise will have sunk several million dollars into construction and development costs prior to starting operations. Are we to believe that they will just shut down until they can solve the problem, or will they continue to operate and pay fines levied as “the cost of doing business?” These issues must be resolved before any permit is issued. Robert A. Hubbard is retired symphony musician who lives in Grass Valley. This letter is based on comments prepared for the Nevada County Planning Commission about the Draft Environmental Impact Report.

I received a letter from Rise Gold dated Feb. 11 stating, “We are reaching out to you to provide further information” on the proposed reopening of the Idaho-Maryland mine. Awesome. I’d love more information about the mine, since I live off East Bennett Road and directly on top of mine. I’ve been reading the 1,000-page draft environmental impact report, and it’s tough slogging. So many significant impacts! Anyway, here’s some tidbits from the Rise letter: “The county has determined that no domestic water wells will be drained by mine dewatering.” That’s funny since previous impact reports to reopen the mine stated several nearby wells would likely experience complete dewatering. Then there’s this gem: The current report says Rise Gold plans to explode 1,860 pounds of ammonia nitrate seven days a week under my home. But not to worry. Their letter says that the blasting will be “unnoticeable and undetectable.” I’m thinking not. And the finale, their real estate consult concludes there would be “no negative impact on home prices.” In fact, employment from the mine could drive nearby home prices higher! I guess living next to a highly industrial 24/7 rock crushing plant is desirable. Who knew? Jim Otto Grass Valley This opinion piece was originally published in The Union.

While Mr. Rogers does not like Rise Gold’s advertising, he seems to believe that the science presented in the draft environmental impact report proves that reopening the Idaho Maryland Mine is as clear as Rise Gold’s advertising claims. Mr. Rogers seems to support reopening the mine because the science claims it’s OK. Let’s take one example from the draft report: The “significant and unavoidable” scientific conclusions that traffic at “SR174/Brunswick” and “Brunswick Road/Sutton Way” cannot be mitigated. Average injury accidents/year for the past three years in Nevada County was 405 (CHP Data), including 13 fatalities. With “significant and unavoidable” traffic issues, it is statistically likely that more accidents will occur at these intersections. Is one more fatality acceptable? How about just one more injury accident? Maybe in Mr. Rogers’ neighborhood there are no accidents or fatalities attributable to “significant and unavoidable” traffic issues. Maybe in Mr. Rogers’ neighborhood only one well goes dry from dewatering the mine. Maybe only a few families’ property values go down. The negative impacts from the Rise Gold mine may be acceptable in Mr. Rogers’ neighborhood, but they are not acceptable in ours and should not be in yours. John Vaughan Grass Valley This opinion piece was originally published in The Union.

November, 2020 Listen to Christy Hubbard, a Grass Valley homeowner, talk about neighborhood impacts from a CEA Foundation virtual community meeting.

Reviewing Rise Gold CEO's past decisions, Ken concludes that "he is extremely unlikely to be a good steward of the operating permit for the Idaho-Maryland Mine, nor will he protect the essence of what makes Nevada County a paradise." This opinion piece was originally published in The Union. The Idaho-Maryland Mine project is generating more controversy than any other local topic. Discussions of pros, cons and what might happen are becoming louder and more emotional. I am not interested in speculation. I believe the most accurate predictor of a person’s future decisions are those made in the past. Instead of joining the noise and confusion of these discussions, I wanted to get to know Ben Mossman, CEO of Rise Gold, what decisions he made in Canada, and what could happen in Grass Valley. Before Mr. Mossman came here, he was president, CEO, CFO and director of Banks Island Gold, which operated in Banks Island, Canada. This is a timeline of that project: March 2014: Banks Island Gold receives approval from the Canadian government to run a small underground mine. Banks Island Gold publishes on their website that the mine will produce 75,000 metric tonnes of ore annually. In Canada, this amount triggers a full environmental assessment. When Banks Island Gold files its mining application, it only shows 73,000 tonnes/year, just beneath the environmental assessment threshold, avoiding a full environmental study. This practice is known as “project splitting,” breaking a project down into smaller chunks to intentionally avoid a rigorous review. Mossman takes advantage of this loophole, setting up his mine to operate with minimal environmental assessment and oversight. January 2015: Banks Island Gold begins commercial production of the Yellow Giant Mine. June 25, 2015: The Canadian Ministry of Environment, after receiving information from a whistleblower, conducts an on-site inspection. This inspection allegedly uncovers effluent discharges of contaminated water and silt into the local waterways, plus a number of alleged permit violations. July 15, 2015: The Canadian Energy and Mines Ministry orders the entire Banks Island Gold operation to immediately shut down because of the effluent leak and alleged permit violations. July 24, 2015: Banks Island Gold issues a press release acknowledging the July 15 shutdown order. July 28, 2015: Banks Island Gold issues a press release saying they are continuing to process ore, in violation of the Canadian shutdown order. Aug 4, 2015: Banks Island Gold issues a press release stating that as of July 31, the operation had shut down. January 2016: Banks Island Gold files for bankruptcy. Mr. Mossman walks away from the site, abandoning it. Consequently, the Canadian government is now responsible for toxic cleanup costing more than the cleanup bond. That is the story of Banks Island Gold. Shut down by the Canadian government after only seven months in operation. One year from start to bankruptcy. Mr. Mossman left behind a toxic legacy the Canadian government and indigenous Gitxaała Nation must clean up. As of 2021, the site was still considered by BC Mining Law Reform as one of British Columbia’s “Dirty Dozen” top polluters. In a nutshell, I see that Ben Mossman opened a gold mine, manipulated permit requirements, made a mess of the environment, declared bankruptcy, shorted his employees, left town, and then moved to Grass Valley. To open another mine. To do it all again. History always seems to repeat itself. Bottom line: Mr. Mossman’s past patterns of behavior demonstrate to me that he is extremely unlikely to be a good steward of the operating permit for the Idaho-Maryland Mine, nor will he protect the essence of what makes Nevada County a paradise. I respectfully ask the Nevada County Board of Supervisors to consider this when it comes time for them to vote on the future of Nevada County. Ken Bernstein lives in Nevada City.

Rise Gold promises a feast of plenty with protection for environment & health (take air, for instance), but a history of mismanagement and environmental degradation doesn’t cut it. Life is messy. Even in the best of times, the careful plans we lay out for ourselves get derailed. Faced with an economic setback, a dishonest associate, a natural disaster or a serious health problem, our plans begin to fall apart and things slip through the cracks. Even more messy are complex business plans. Take, for example, an underfunded penny-stock company attempting to reopen a gold mine cheek-to-jowl with a small rural community still trying to overcome the environmental legacy of its previous generations of mining. Rise Gold’s slick mailers hope to convince us that every one of the more than 25 significant environmental and health impacts identified in the draft environmental impact report will be mitigated, and that they will protect our community from those impacts continually, 24/7, for the next 80 years. That’s a bold promise. One might consider it utterly unbelievable. In an environmental impact report, the applicant (here, Rise Gold) lists mitigation measures it has identified to prevent or lessen the adverse impacts of its operations. Of course, success of these measures is based on a variety of economic, human, ethical and supply chain assumptions. That is, that all the ducks will line up in an orderly row to ensure compliance. But as we’ve seen repeatedly over the past couple of years, life is messy. Shifting economic decisions alter business decisions. Humans make mistakes, act foolishly, and behave unethically. Critical equipment and supplies become unavailable, forcing new operational decisions and making required maintenance impossible. So any mitigation measures laid out in the draft environmental impact report are only a promise made before one shovelful of dirt is turned, one ounce of water is drawn, or one cloud of emissions wafts into the air — nothing more. Given these unavoidable uncertainties and the significant impacts on our community, we must ask two questions: Does the draft environmental impact report accurately characterize the situation? And Do those in charge have a track record of impeccable behavior in ensuring their heavy industrial facility will meet our health and environmental guidelines for today and the next 80 years? The draft report’s 1,070 pages contain far too many issues to address here, so we’ll focus on one: Does it accurately characterize the area’s current air quality? It’s questionable. The air monitoring data for ozone and small particulate matter is from monitoring equipment located about a mile northwest of the project site. Rise Gold didn’t conduct air monitoring at the project site or in any other direction emissions from their operations will travel. Years ago, citizen ozone monitoring conducted at various locations around the Grass Valley/Nevada City area confirmed that ozone levels vary widely here due to our topography. So it’s clear that Rise Gold’s use of data from a single air quality monitor is insufficient to characterize at least the ozone in our area. For other air pollutants, the draft environmental impact references a monitoring station in Yuba City — 31 miles away. As for Rise Gold’s track history, there isn’t much. The company, formed for this project, has never operated a gold mining operation. Yet to approve the proposal, the county supervisors (and their constituents) are expected to believe that this group is capable of cobbling together a team that can implement the numerous, complex mitigation measures outlined in the draft environmental impact report from the get-go, with no slip-ups. And then there’s the history of Rise Gold CEO Ben Mossman’s former mining management in British Columbia. In less than two years, his Banks Island Gold Ltd. operation had polluted the local environment enough for the Canadian government to shut it down. When the company’s safety manager identified safety issues in the mine, he was let go. And when they went bankrupt, scores of employees were left unpaid. And the security bond didn’t come close to covering cleanup costs. Now Mr. Mossman and Rise Gold and their marketers want to set the same table for us, promising us a feast of plenty. They want us to believe they’ll protect our environment and health. But ladling sweet promises over a stale history of mismanagement and environmental degradation doesn’t cut it. Let your county supervisor know that you’re not falling for their hype, and ask them to vote no on approving the mine. Mark Wilson lives in Nevada City. This opinion piece was originally published in The Union.

A Grass Valley resident discusses various alternatives for the site which were dismissed from the mine report as "not feasible". He concludes that a business and industrial center would be vastly preferable, for which the site is currently zoned. This opinion piece was originally published in The Union. I have many concerns with the draft environmental impact report on the proposal to reopen the Idaho-Maryland Mine. One that stands out is the lack of inclusion and review of the already approved (Ordinance 1853, February 1994) Nevada County business and industrial center alternative, which with existing zoning could include a 54,000-square-foot business park, 242,000 square feet for service business/light manufacturing and 238,000 square feet for Industrial uses (DEIR pages 6-11/12). The draft report’s Chapter 6 “No Project” section discussing “Alternatives Considered but Dismissed from Further Analysis” (pages 6-8) is incorrect and incomplete. Analysis of the currently permitted alternative notes examples of negative impacts that are extremely unlikely to occur in the real world. In the summary section for the business and industrial center alternative (pg6-13), the draft report concludes a negative impact and rejects this option assuming noise, traffic, aesthetics and air quality would be the same or worse for this alternative vs. reopening the gold mine. Unlike the Rise Gold project, in virtually all cases for the types of businesses that would actually locate there (using existing zoning) the traffic and noise would be daytime, mostly weekdays, not 24/7, comprised largely of passenger cars and small trucks. Diesel truck traffic would be substantially less than the 236 trips a day for the Rise Gold project (page 4.12-34). The impact report identifies distribution facilities, auto dismantling yards and planing mills as examples of business that would “cause substantial noise, traffic, aesthetic and air quality impact.” While these business types are permitted under existing zoning, the likelihood of such ventures at this location is extremely low. They require easy access to major freeways like Interstate 80 and therefore are not realistic for this site. In the case of large 24/7 distribution facilities, anything further than 10 to 15 minutes from a major freeway is not feasible and 238,000 square feet is far too small. Even if you attracted a distribution facility tenant, 238,000 square feet would not support enough loading docks to create the same diesel truck traffic as the Rise Gold mine. Additionally, for distribution facilities and other permitted businesses, at the scale available at this site, the semi-truck traffic would be limited to weekday or daytime use as small to mid-size facilities are unlikely to operate 24/7. The draft report also notes that “milling and planing facilities would potentially create noise similar or greater to the proposed project.” Frankly, that’s hard to believe as there was a saw mill/ planing mill at that site for decades and there is already a planing mill on East Bennett Road. Regarding air quality and traffic: The impact on air quality would be reduced with business and industrial center tenants reflecting what would happen in the real world vs. the unrealistic scenarios in the draft impact report. The report suggests that car and truck traffic to and from a business and industrial center would generate the same pollution as projected traffic to and from the proposed mine, which includes 236 semi-truck trips/day. Each diesel semi-truck emits as much pollution as 150 cars (cleanairtrust.org/trucks.dirtytruth.html). Producing the same emissions as 236 diesel trips a day day requires 35,400 trips a day from cars and light trucks, an unlikely scenario for businesses that might actually occupy the business and industrial center. Regarding aesthetics: Given the site is already zoned for the buildings and businesses noted, aesthetic issues could be easily mitigated and included in a proposal for development of all or part of the business and industrial center. Virtually all of the businesses listed in “Examples of Permitted Uses” (pages 6-12/13) already exist or have existed in Nevada County without hundreds of local residents protesting about potential traffic, noise, water usage or pollution. It seems like a reasonable model to follow to do more of what we already know how to do without changing the nature of our community for the next 80 years. I believe many of the people who oppose this mine would support a “No Project” alternative with the business and industrial center as the best outcome. Assigning a “not feasible” label to the business and industrial center alternative using unrealistic assumptions makes it appear the impact report authors have not done their homework. I’m not saying that the business and industrial center should be built now (or ever). That’s not my decision. But to reject this alternative without a detailed review using real world scenarios and real world outcomes makes no sense. Rise Gold’s advertising postcard claims the “science is clear.” That’s debatable. What is clear is this is the wrong project for Nevada County. John Vaughn has been a resident of Nevada County since 1967. His water is served by a well approximately 100 yards from the southwest edge of the Rise Gold mineral rights area.

Authored by CEA Foundation Now Is the Time: Let the County Know What YOU Think About the Mine and the Draft Environmental Impact Report (DEIR) DEADLINE: Comment letters are due to Nevada County by April 4, 2022 In May of 2020, the Nevada County Board of Supervisors voted 5-0 to authorize the preparation of a Draft Environmental Impact Report (DEIR) to study the risks associated with re-opening the Idaho Maryland Mine – a project led by Canadian Company, RISE Gold. That July, the County published a Notice of Preparation (NOP) outlining what will be studied in that DEIR and the community provided comments and feedback on what the analysis in the DEIR should include. The DEIR is now and out and it’s time for the public to make comments on what it contains. Our comments are due by April 4th, but you should know that we are working to get an extension. Make sure your voice is heard. Here’s how: • Identify your own areas of concern (eg; impacts to air, wells, traffic, noise…) • Consider reviewing the Project Summary, Executive Summary and Table of Impacts and Mitigations (hyperlinks provided at the end of this sheet). • Then go to the specific chapter on your impact of concern and read it thoroughly. • Write a comment letter. • Send your letter to the Nevada County Planner, Matt Kelley, no later than April 4th. Why should I send a comment letter to Nevada County about the Mine? This project has many potentially significant environmental impacts that are listed in the DEIR. It’s up to concerned citizens like you to tell the County’s staff and consultants what you are most concerned about. They must respond to each comment letter. What points should I make in my letter? Focus your letter on what concerns you the most. Some people focus on the environmental impacts of the mine on the land, water and wildlife. Others are very concerned about air pollution, traffic impacts and neighborhood safety. Some want to see what impacts there might be to climate change. You want to make your specific requests and questions clear, for example “I’m concerned how this proposal impacts wells in the area. The FEIR needs to analyze all the wells potentially impacted by the project. The impact analysis on wells in the DEIR is ….(choose any of the following language: missing, invalid, inadequate, underestimates impacts, proposes inadequate mitigation measures). Some tips for writing an effective comment letter: If you have special expertise or education on the issue you are discussing, note that. A related job or volunteer experience, special understanding of local conditions, years lived in the area, or if you live close to the mine; all give you special expertise, so note any of these. Focus your requests on what you want analyzed and what environmental impacts you want considered or considered in greater detail. Explain the WHY for each of your conclusions. If you think the impacts proposed will not mitigate impacts explain WHY. If you think the project impacts in your subject area simply cannot be mitigated to an acceptable level, explain WHY. Be specific on impacts and mitigations. Example of a good comment: “The discussion of water quality impacts related to loss of wetland vegetation on DEIR page 5-7 is inadequate because potential loss of cover vegetation due to road widening required near the creek is not discussed. Mitigation should include a 100 foot centerline of creek setback from the road construction zone.” (Notice: Includes citation, very specific impact noted, solution recommended.) Less specific comment not as effective: “The DEIR is completely inadequate because it does not adequately discuss impacts to water quality. The project should be decreased in size.” Make sure that your specific requests are clear, concise and singular (bullet points are fine). Including your opinion on the mine, is valid and OK but is not a factor for staff in developing the Final EIR – so make sure that your personal opinions don’t distract from your clear, concise requests to the County. Include your name and contact information in case the County needs to contact you to clarify a point. DEIR comments are divided into various categories. Reviewing these categories may help spark your thinking and may help organize your comments. The comment categories are: Aesthetics Agriculture and Forestry Air Quality Terrestrial and Aquatic Biological Resources Cultural Resources Tribal Cultural Resources Geology / Soils Greenhouse Gas Emissions Hazards & Hazardous Materials Hydrology / Water Quality Land Use / Planning Mineral Resources Noise Population / Housing Public Services Recreation Transportation and Traffic Utilities and Service Systems Economic Study* Water Supply Analysis** *An economic study is not required under CEQA, however the County has commissioned a Study. **A Water Supply Analysis is included in the Appendices of the DEIR Where do I send my letter? Send your letter (email or regular mail) to Nevada County by April 4, 2022 at 5pm to: Mr. Matt Kelley Senior Planner Nevada County Planning Department 950 Maidu Avenue, Suite 170 Nevada City, CA 95959-7902 (530) 265-1423 Via email:Idaho.MMEIR@co.nevada.ca.us Do you have a sample letter I can use as a template? It’s always best to use your own words. You can start with your personal experience like how long you’ve lived in the area, and briefly share your connection to the project. Most important: Be specific about your key concerns and questions about the project. Please help us track the impact we are having – send a copy of your letter to: DEIRcomments@cea-nc.org This information sheet is available online at: https://www.minewatchnc.org/post/how-to-write-deir-comments Want to learn more about key topics and impacts? Visit www.MineWatchNC.org A copy of the DEIR is available at the Nevada County Library and on the County’s project website. Visit Idaho-Maryland Mine Draft EIR | Nevada County, CA (mynevadacounty.com) Draft EIR in Chapters: Idaho-Maryland Mine Draft EIR | Nevada County, CA (mynevadacounty.com) The Executive Summary and Table of Impacts and Mitigation Measures: 2_Executive-Summary (mynevadacounty.com)