DRMS Comment Objection Intake 9/1/2021 4:05:25 PM

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Your Phone Number* Used only to follow up. 3039070487 Extension Alternate Phone Number Used only to follow up. 3032780786 Alternate Phone Extension Connection to Operation Select all that apply Land Owner of affected land Structure Owner within 200' of affected land Mineral Owner Nearby Resident Adjacent Land Owner Concerned Citizen Government Agency Other DESCRIPTION OF COMMENT OR OBJECTION (Please be as specific as possible' Comment/Objection Narrative TO: Mined Land Reclamation Board Colorado Division of Reclamation, Mining&Safety Timothy A. Cazier, P.E., Environmental Protection Specialist SUBJECT: Dawson Gold Mine, Permit Application M-2021-046 submitted by Zephyr Gold USA Ltd. FROM: Robert H. Robinson, P.E. DATE:September 1,2021 The following comments are offered for your adjudication of the Dawson Gold Mine permit application, M-2021- 046,submitted by Zephyr Gold USA Ltd.The comments focus primarily on risks of damage to natural resources by acidic and toxic effluents,failure of the tailings storage facility,and a lack of protection for wildlife and the possible presence of rare plants and plant communities.Some of these risks probably can be addressed by permit modifications,others may be grounds for permit denial depending on the outcome of further and careful baseline characterization and project planning. Acidic and Toxic Mine Drainage 1.Section 2.4.6.3 Tailings Characterization states that"Geochemical characterization was conducted on two tailings composite samples,one representing tailings generated from altered ore and the other unaltered ore." The altered ore sample was a composite of two core segments,and the unaltered ore sample was a composite of three core segments.This Section does not describe the location of those core segments within the ore deposit,the tonnage of ore represented by each sample's core segment, nor how the core segments were proportioned to make up the composite sample. Further,the geology, mineralogy,and chemical analysis of the core segments are not discussed in the context of variations in geology and mineralization in the ore deposit.A permit reviewer has no way of ascertaining whether the geochemical samples are representative of the ore deposit,whether particular core segments where composited with others to dilute the testing outcomes,or whether there are enough samples to characterize variations in the ore deposit and timing of tailings placement in the tailings storage facility.There is no way of knowing whether or not the geochemical results are biased towards a favorable outcome for Zephyr Gold. Surface Reclamation