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

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Zephyr has proposed construction of a filtered tailings storage facility that relies on a design prepared by Amec Foster Wheeler,the same engineering firm that designed the failed tailing impoundment behind the Mount Polley disaster of 2016.13 The Dawson Gold Mine impoundment relies on an upstream construction design, broadly considered to be the most unstable form of construction for tailing impoundments. Even though Zephyr proposes to filter the tailings so that the moisture content of the waste impoundment is reduced, it still has a chance of failure and,should it fail, may cause significant devastation, potentially sending one million tons of tailing waste downhill into Canon City and into the Arkansas River.14 The proposed buttress design of the impoundment is not sufficient to guarantee that it will be stable nor to prevent failure. Furthermore,Zephyr makes the unsupported claim that the material is benign,and the exclusion from the impoundment design of an underlying liner and leak detection system make it likely that contaminated material will eventually leach into groundwater supplies, despite the lack of analysis on this point.Zephyr's conclusions appear to be based on the removal of 100 percent of the sulfide minerals offsite, but this is simply unrealistic in actuality when the economic realities of gold mining mean that lower-grade material is often left behind and not fully processed to completely remove acid-generating sulfides. These issues are a significant flaw in the proposed design of the mine and its workings and are grounds for denying the permit for failing to meet minimum standards to protect the environment. Last but not least are this mine's serious and significant impacts to the residents of the Dawson Ranch,Wolf Park and Eagle Heights neighborhoods and other homes located between 1.4 to 4 miles downwind of the mine's main portal area.This area includes approximately 600 homes that are inside Canon City's municipal limits,and these residents will suffer from the extreme changes to their quality of life if a gold mine is constructed next door to them,as well as residents of the broader Canon City region. The permit application contains no serious analysis of the air quality degradation that will result from the mining activities within an airshed with frequent and regular high winds, nor the water quality and hydrological impacts that could affect their drinking water supply.The development of Dawson Gold Mine is an intolerable loss in the quality of life for these residents that simply should not be allowed. We appreciate your consideration of these comments and respectfully request that the Dawson Gold Mine permit application M-2021-046 be denied and a hearing be 14 Dawson Gold Mine permit application, p.29(p 46 of packet PDF), reporting TSF design capacity of 1 million tons.Available in permit file: https://dnrwebiink.state.co.us/drms/O/edoc/l 336840/2021-07-02_PE RM IT%20F I LE%20-%20M2021046.pdf? search id=fd7c5e2a-36f0-4bdf-9e7d-0b4354dbeb39 Steven H. Emerman,"Potential Groundwater and Surface Water Impacts from the Proposed Dawson Gold Mine, Fremont County,Colorado, USA,"Aug.25,2021.See discussion p.33.Available in permit file: https://dnrweblink.state.co.us/drms/O/edoc/l 341820/2021-08-31_PERM IT%20F I LE%20-%20M2021046%20 (3).pdf?searchid=8fbe08a3-9ec4-4bdb-bf3c-f53141 cef988 13 Engineers face discipline over Mount Polley disaster,Alaska Highway News,June 3,2020: https://www.alaskah ighwaynews.ca/bc-news/engineers-face-discipline-over-mount-polley-disaster-3508189 (enclosed) https://dnrwebiink.state.co.us/drms/O/edoc/l 336841/2021-07-02_PERM IT%20F I LE%20-%20M2021046%20 (2).pdf?searchid=fd7c5e2a-36f0-4bdf-9e7d-Ob4354d beb39. scheduled before the Colorado Mined Land Reclamation Board.Thank you again for the opportunity to submit these comments. Sincerely, Michael Gromowski Leader Arkansas Valley Conservation Coalition 403 Greenhorn Drive Canon City,CO 81212 dawsongoldmine@gmail.com (414)719-4434 Allison N. Melton Senior Attorney Center for Biological Diversity P.O. Box 3024 Crested Butte,CO 81224