2024-04-03_REVISION - M1990057 (31)

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Sanitation District's supply lines. If not,water purchased from Parkville Water would have to be trucked to the mil which may not be feasible,and the truck traffic associated with such an endeavor would certainly have a negative impact on our community.Another alternative would be for the applicant to seek a water augmentation plan and withdraw water from the aquifer at the mill site.This approach could have a significant and negative impact on nearby residents who rely on well water for domestic use. •Wildfire Wildfire is a perennial concern in Lake County, particularly during the drier summer season.We are not confident that the applicant has a plan in place to address potential hazards at the mill associated with a wildfire. In addition to potential threat from wildfire, it is unclear what steps the applicant will take to ensure that this mill site is secure from trespass,vandalism,and/or theft. •Mine Dump Material Management The mine dumps at the Penn Mine complex,where the applicant plans to source material for processing at the mill,are stable. Disturbing these dumps could entrain soil contaminated with heavy metals into the environment through dust and/or surface water runoff presenting a risk to human health and the environment.Trucks loaded with mine dump material will be covered for transport, but more detail is needed on how exposures wil be managed as the material is excavated.The applicant should also detail how the surface soil beneath the mine dumps will be reclaimed. •Bond Requirement In the event of completion of the project,dissolution of the company,or changes to the economic viability of the project,does the State ensure sufficient bonding to cover safe closure of all mining and processing activities? Will the State ensure that the applicant has sufficient insurance in case of a catastrophic event? In addition to these technical issues,we have several concerns about the proposed project's impact to our community: The CJK Mill's intention to reprocess waste rock from the historic mining district using a cyanide leach process raises significant apprehensions for us. Such a process inherently poses risks to water quality,a paramount concern given the proximity of the proposed mill to the Arkansas River.As you are undoubtedly aware,the Arkansas River has endured its share of environmental challenges stemming from historic mining in the area. It was only after our community was listed as a Superfund Site and endured years of environmental remediation that the Arkansas River was distinguished as a gold medal fishery.This designation not only reflects the ecological resilience of the river, but also underscores its importance as a cherished resource for recreation, tourism,and biodiversity. Permitting the CJK Mill to operate with its proposed methods presents a direct threat to the hard-won progress achieved in restoring the Arkansas River. We object to the applicant's characterization of this project as environmental remediation. No data has been provided to indicate what level of contamination may be emanating from the Penn Mine complex, nor is there any indication of how removing waste dump material might impact the environment. Furthermore,the Environmental Protection Agency's most recent Five-Year Review(September 2022)suggests that the only Superfund work remaining in the area is monitoring the effectiveness of diversion ditches upgradient of the Mikado, RAM and Pyrenees waste rock piles and implementing land use restrictions to protect engineered remedies and reduce exposure to contaminants that remain in place.Water quality in the Arkansas River is good and,as mentioned above,supports a gold medal fishery. We should also consider the issue of environmental justice, particularly concerning the Lake Fork Trailer Park. Residents of this predominantly Hispanic community reside near the proposed CJK Mill project.We must consider the disproportionate burden that such industrial activity would place on already marginalized populations. The transportation of waste rock from the historic mining district and water from the Parkville Water District through our community poses additional concerns. Increased truck traffic not only exacerbates noise and safety issues, but also disrupts the tranquility of our surroundings.The proposed industrial activity in the historic mining district, including crossing the popular Mineral Belt Trail,threatens to impede recreational opportunities and diminishes the quality of life for our residents and visitors alike. There is also a potential impact on heritage tourism. Leadville's rich history as a pivotal mining district in the western United States attracts visitors from across the country who seek to experience our unique heritage firsthand.The resurgence of industrial mining activity jeopardizes the preservation of our cultural identity and undermines the efforts to promote sustainable tourism in our community.