DRMS Comment Objection Intake - DEV 3/2/2022 (2)

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Extension Alternate Phone Number Used only to follow up. 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 You are providing a comment or objection to the public record of a permitting action currently under review by the Division of Reclamation, Mining and Safety.This form is not intended for reporting of possible violations or illegal activity. Please be as specific as possible. Comment/Objection Narrative Most of my comments are centered on the Reclamation Cost Estimate and Approach. In my professional life, I clean up contamination from historic hardrock mines in Colorado and the Western US.One of the main problems with new proposed mines is that grossly underestimate what reclamation costs will be during initial permitting process.This is the same for this application. -Page 72-Cost Summary work-After removing the demolition and mobilization costs from the proposed direct cost total of approximately$207k,reclamation costs for grading,top soil cover and revegetation come out to be $63,224.That is a very low number for 7.25 acres lined out in their proposal. For a similar project proposed near Monarch Pass,reclamation costs were approximately$90,000 for 2 acres.This equates to$45,000 per acre,which would be$326,250 for the footprint included in this application.This estimate includes grading, erosion controls,and mixing of amendments which this application lacks.Given the and environment and disturbance that will occur at this site,the applicant should plan to include soil amendments like fertilizers, compost, biochar,etc to promote native vegetation growth and bufffering over the first couple growing seasons. Adding a 15%contingency to the$326,250,the total for just the revegetation aspect should be more like $375,187.50.With this figure added to the mobilization/demolition,a final reclamation estimate of$520,269.50 would be more representative of what reclamation costs would be in this area. Unless the applicant is willing to update these numbers,their current reclamation costs are inadequate. -The applicant should propose alternatives in the reclamation plan if a perennial discharge were to be created as part of the development.While it is unlikely given their hydrogeology research, most mines will incur some sort of draining adit or perennial water source during development. Perpetual water treatment can cost millions of dollars and should be factored into the NPDES permitting process and application.Surface reclamation is not the only thing that might need to be undertaken if this mine moves forward.That potential should also be addressed in the reclamation plan. Permit Number* Enter valid letter and then numbers,for example M1977999, M1999777UG or C1981201. M2021046 Permitting Action Type Select revision type or leave blank if comment pertains to a new permit application or NOI Permit Type New/Reclamation County Fremont Enter one county only