DRMS Comment Objection Intake 9/1/2021 6:57:46 PM

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IQIIUJ WILIIUUL ICUCIQI CIILJ.CILJ.CIIICIIL HUM LIIC UULJCL. As admitted in the permit application,the development of the Dawson Gold Mine, even at the size currently proposed,will impact the hydrology of the area and reduce surface flows in Grape Creek.7 Grape Creek is a significant tributary to the Arkansas River Basin and is a source of drinking water to residents of Canon City and other communities downstream of its confluence, including communities that are low-income 7 Dawson Gold Mine application,Section 2.7, Exhibit G, p 35;available in permit file at https://dnrwebiink.state.co.us/drms/O/edoc/l 336840/2021-07-02_PERM IT%20F I LE%20-%20M2021046.pdf? search id=fd 7c5e2a-36f0-4 bdf-9e7d-0b4354d beb39. 6 43 CFR§3809.11 and 40 CFR§ 1500.1 5 Section I, Memorandum of Understanding Between The Bureau Of Land Management And The Division of Minerals And Geology, Dec. 18,2002;available online at https://drive.google.com/file/d/l 3fgyJxyQM HeFfTITMyG7I DMJ8O7x2X9N/view. 4 Fremont County Historical Society newsletter, November 2014,available online at https://www.fre monthe ritag e.com/wp-conte nt/u p load s/2015/02/F H S_N ewsletter-N ov2014.pdf or disproportionately non-white and which raise significant questions about fairness and equity under Environmental Justice doctrines.Grape Creek also provides excellent habitat for spawning brown and rainbow trout,which are put at risk by any increase in sedimentation that is the expected result of any new road development and surface disturbances at the mine site.This will result in the long-term degradation of the health of the fishery.That in turn degrades the backcountry and quiet-use experiences currently enjoyed by anglers and visitors to Grape Creek and the long-term economic resiliency of Canon City.Visitation to the area will likely be reduced as surface disturbance,visual impacts,dust and noise increase. The Dawson Gold Mine permit application does not comply with the statutory requirements of HB19-1113.These amendments,signed into law by 8 Gov. Polis on April 4,2019, require that the operator demonstrate through substantial evidence a reasonably foreseeable end date for water quality treatment.Zephyr proposes a mine design that will require active pumping and dewatering of the mine during operations,yet there is no analysis or discussion of how water will be managed once operations and dewatering of the mine have ceased.9 The creation of a permanent mine pool underground is likely to result in a long-term decline in ground water quality and the formation of new seeps that create water discharges offsite as the mine pool reaches equilibrium at an undetermined point in the future. Despite claiming that the mine will not produce acid-generating material,the application does not contain a sufficient demonstration of a lack of impacts. Impacts to the surface and ground water hydrology of the site must be minimized both during and after the mining operation.10 The limited water quality analysis conducted by Zephyr for the permit application shows that manganese will increase in ground water as a result of mining operations; however,state and federal requirements forbid any degradation of existing ground water quality and there is no discussion of how this contamination will be addressed.The application also reveals that nickel and selenium in the discharge water will exceed surface water quality standards for Grape Creek,yet the treatment of these constituents is not envisioned,as the application simply states that a sediment pond will be constructed.11 The Division must require a more robust analysis on these points and HB19-1113 requires that an end date to the treatment plan be demonstrated.Another faulty assumption is made when Zephyr states that the development rock will be non-acid-generating without recognizing that the downward development of the mine will pass through unknown zones containing sulfide minerals;there appears to be no analysis of this material at all,and,as the mine pool develops,a degradation of water quality is likely to occur that is unacceptable.12 12 Appendix to Dawson Gold Mine application,Section 2.1,p.3:"Development rock did not undergo long term leach testing due to the absence of sulfides and its associated potential for accelerated metal release due to oxidation."Available in the permit file online at 11 Ibid, Exhibit G,Section 2.7.3.1, p 38. 10 Mineral Rules and Regulations for Hard Rock, Metal,and Designated Mining Operations: Rule 3.1.6 and Rule 6.3.3(1)(h)(i). 9 Dawson Gold Mine application,discussion in Exhibit G,pp 34-36;Section 2.13, Exhibit M,p 53:"This application will likely be amended as the mine develops."Available in the permit file online at https://dnrwebiink.state.co.us/drms/O/edoc/l 336840/2021-07-02_PERM IT%20F I LE%20-%20 M2021046.pdf? search id=fd7c5e2a-36f0-4bdf-9e7d-0b4354dbeb39. 8 CRS§34-32-116(7)(q)(ii)