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Comment/Objection Narrative* <br /> •What is Grand Island Resources LLC(GIR)?There is no website and little internet information regarding this <br /> company. <br /> •What is their portfolio?Do they have a proven track record of mining responsibly anywhere?Is it appropriate <br /> and responsible to give a permit to an unknown company with no visible signs of qualification or experience? <br /> What is the source of their funding? <br /> •Is GIR a bonafide mining company or a contractor company? <br /> •Is GIR connected with or a member of any responsible mining consortiums such as INAP, ICMM, IMWA,or <br /> IRMA?Initiative for Responsible Mining Assurance(IRMA)has set the standard for responsible mining and <br /> mineral processing(October 2023 draft)which is periodically updated.Can GIR demonstrate they follow these <br /> international recommendations? <br /> •For good reasons, leach tests have often been questioned as a predictive guide for acid mine drainage <br /> potential,yet GIR is using leach data to estimate water quality from tailings and waste rock piles.Why isn't GIR <br /> considering additional methods to estimate water quality from mining? <br /> •The mining plan has not identified a site and facilities for the mill and tailings.These aspects are under <br /> development.At many mine sites,the tailings and waste rock are the largest source of contaminants and often <br /> left outside,exposed to weathering and leaching.Why would the mine plan not include the plan for mineral <br /> processing and its containment during mining? Is the tailings disposal not an important part of a"designated <br /> mining operation"if the mill is located on the property?If the mill and tailings will be located in some distant <br /> basin,then this plan should be explicitly stated and may not be needed for this DMO. <br /> •If future ore shows an increase in pyrite or pyrrhotite content such that acid mine drainage is likely released <br /> from tailings or waste rock,what is GIR's plan to contain the contaminating materials? <br /> •In the event of an impoundment or holding pond failure,what backup contingency plans are there to prevent <br /> contamination of Beaver Creek and Barker Reservoir? <br /> •Has the water balance and water quality program(monitoring quality and quantity)been evaluated by an <br /> independent expert to be adequate for the size and scale of the proposed mining expansion,including a flood <br /> event? <br /> •What plans are there to prevent traffic gridlock,dust contamination,and noise from haulage trucks?The extra <br /> burden of these factors would seem to be unacceptable for the limited space in Nederland. <br /> Permitting Action Comment/Objection is Regarding <br /> New Permit • Change to Existing Permit <br /> Permit Number* (?) <br /> Enter a valid permit number <br /> M1977410 <br /> Revision Type and Sequence <br /> 112D(regular DMO permit) <br /> County* <br /> Colorado County where the proposed operation is located <br /> Boulder <br /> Enter one county only <br /> Site Name <br /> Cross Gold Mine <br /> Perm ittee/Operator Name <br /> Grand Island Resources <br /> ADDITIONAL INFORMATION <br /> Are there supporting photos, maps, or documents you wish to upload? <br /> Yes • No <br /> By submitting this form electronically you agree to receive any/all follow up correspondence from the Division of <br /> Reclamation, Mining,and Safety at the email address you have provided. <br />