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Regarding Environmental&Public Health Concerns Generally. Coon Track Creek,Caribou Creek(which is
<br /> included in the permit,yet claimed to not be at risk of any ill effect),and the surrounding watershed are multi-
<br /> use recreation areas that draw activity throughout the year.The application mentions no impact to this area that
<br /> is included in their application.These areas feed into the water supply for the City of Boulder, but also into
<br /> habitats,soils and backyards before accumulating in Barker Reservoir.The main mine site is 2.7 miles,as the
<br /> crow flies,from Nederland Elementary School. Between the mine and Nederland are several dozens of homes,
<br /> watered by natural wells and springs.This proposal and large expansion of activity leaves many questions left
<br /> unanswered,and could have significant detrimental impacts on the health of the environment and it's
<br /> inhabitants within the entire watershed downstream of the activity.
<br /> It is unclear on which areas of land different activities will take place,since the application available to the public
<br /> does not include the maps for Exhibit C. If GIR is allowed to prospect,or does prospect due to lack of oversight
<br /> manpower,in the 200+acre area requested in the application,there is potential for significant detrimental
<br /> impacts to not just Coon Track Creek,but also Caribou Creek and it's watershed.
<br /> The application does not mention conflicts with recreational activity. Increasing mine traffic and an increased
<br /> permit boundary may lead to conflict with recreators and the natural environment.This is a narrow mountain
<br /> road that requires 4x4 access,and there have been a number of accidents and rollovers due to the steep grade
<br /> and narrow width that make two-way traffic difficult at times.
<br /> The application does not mention any conflicts with wildlife. It does not mention the potential for large spills to
<br /> affect wildlife,and further does not give consideration for other factors such as explosive activity and how it
<br /> disturbs wildlife, increased truck traffic and construction noise pollution that will disturb wildlife, nor how they
<br /> handle wildlife interactions with GIR employees/contractors. It is unclear if the fencing surrounding the mine site
<br /> is adequate to protect wildlife from entering the area.
<br /> Regarding the style of mining proposed.Stoping can forever alter the landscape, including but not limited to,
<br /> erosion,sinkholes,soil contamination,and groundwater contamination.
<br /> The method can cause land subsidence,leading to structural damage in nearby areas.
<br /> The method requires large amounts of water, potentially depleting local water resources.
<br /> The method can lead to long-term contamination by waste materials if not properly managed,affecting the
<br /> watershed and natural inhabitants for decades or more.
<br /> The method also poses health risks to workers, including exposure to hazardous substances and physical
<br /> injuries.The Idaho tunnel collapse in 2019 is a testament to how quickly and unexpectedly disaster can occur at
<br /> the Caribou and Cross Mine site.
<br /> While the application does mention elk, moose and other wildlife in the area, it is an incomprehensive list
<br /> sourced from government data,not actual observation and not from any environmental assessment,and it does
<br /> not mention any provisions regarding calving season or other life cycle events.The application states they will
<br /> not seek CPW recommendations,though it is highly encouraged.
<br /> The application only specifies one potential hazard to surface water,which is the discharge permit regulated by
<br /> CDPHE.The applicant claims there is no risk of acid drainage from waste rock. It is rare for mining activity to
<br /> not produce runoff,and to not affect other waters than the discharge flow.Thus,it feels incomplete.
<br /> The environmental protection plan does not outline specific measures for protection(especially in regards to
<br /> potential impacts on endangered species like the wolverine, Canada lynx or Colorado cutthroat trout)such as
<br /> habitat restoration, buffer zones for operations,and long-term monitoring. I have personally witnessed both
<br /> Canada lynx and wolverine in the area of Caribou Road and FSR 505. Not evaluating these factors before
<br /> approving the permit risks irreversible harm to local biodiversity.
<br /> The application mentions a paste backfill method for mine clean-up. In other areas,these encapsulated pockets
<br /> of mine waste have leached into groundwater over time. Many homes are on well water within 3 miles of the
<br /> mine, but the application does not mention a potential impact to these groundwater sources.The application
<br /> states there has not been any site-specific study of the aquifer that feeds the area.
<br /> Understanding the full impact to the watershed would necessitate a mapping of the proposed underground and
<br /> surface activity. Even then, rocks can shift and crack in surprising ways,as evidenced by the rock work in
<br /> Boulder Canyon several years ago, in which much more of the rock fractured than anticipated by the
<br /> professional demolition company working on Hwy 119. In many areas where mines have filled cavities with a
<br /> waste slurry,the cavities open up as fissures form in shifting rock,and toxic waste leaches into water sources.
<br /> Regarding the mill proposed.The application states the activity will necessitate the inclusion of the milling
<br /> activity,which could impact air quality,water quality,and soil quality. However, no such plans are provided here,
<br /> and the application is vague about any impacts that operation could have on the surrounding environment,
<br /> especially if any endangered species,such as cutthroat trout,are found in Coon Track Creek. Milling activity
<br /> could lead to even greater environmental concerns than the mine operations,with even more chemicals or
<br /> other hazards present on site.When an application for this mill is received by the Division, I would ask that a
<br /> public notice and public comment period be opened.The application for a mill should also include an
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