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<br /> CPW and other relevant entities.
<br /> Regarding Reclamation Plans.The plans provided are insufficient for exploring the full range of potential
<br /> detrimental impacts to the environment and the public.Admittedly,the aquifer referred to in the application that
<br /> would potentially be impacted,"has a refill rate of 1-500 years,"which is a difficult variable to swallow. Mining
<br /> requirements include that the applicant must thoroughly understand the waters they may impact,and return the
<br /> land to a natural state after activity ceases.The application also states the reclamation plan is for within 5
<br /> years,then purports that it will only take 3 years.This is because the plans are very basic.They claim no need
<br /> for remediation of any site,simply grade,cover with topsoil,and plant.This is perhaps sufficient rehabilitation of
<br /> land for a road,rock pile,or other areas, but this does not feel sufficient for closing up mineshafts.
<br /> The vegetation plans are lacking in biodiversity.The plan states the operator will purchase a bulk grass seed
<br /> mix,and add in some yarrow.This is a good start to a vegetation plan, but is not by any means sufficient to
<br /> reclaim almost 10 acres(or more if activities occur on the 200+acres requested).
<br /> Surface water diversion methods are to be left in place to deteriorate, including buried water lines that
<br /> discharge from the mine.This does not seem sufficient to restore the land to a natural state.
<br /> Rock shifts and moves over time, meaning closed entryways can re-open,as well as new cracks can open in
<br /> areas expected to be contained.The paste backfill method mentioned could be a huge risk to groundwater if
<br /> rock were to shift and dislodge any toxic material into nearby water sources.
<br /> Regarding this"pilot project"operation. Furthermore,A GIR representative stated,when referencing a new ore
<br /> processing facility,a septic system,and a road to connect the two mines"that the mines were to be GIR's"pilot
<br /> project,"to serve as a template for their future business operations."(The Mountain Ear."Status of the Caribou
<br /> and Cross Mines."February 22,2024)If any approval were to occur,it should be only under strict and frequent
<br /> monitoring for impacts to the environment.
<br /> They are currently testing the efficacy of their wastewater treatment method.The plan mentions"periodic"
<br /> testing of water and wastewater,yet it is unclear how often it will occur.Testing should occur whenever there is
<br /> an out-of-ordinary incident,and at least weekly if not more frequently to ensure any hazards are identified and
<br /> remediated as quickly as possible. If they cannot guarantee reasonably clean water discharge,operations
<br /> should not be allowed to continue. Further,testing should occur on multiple places on the property to ensure
<br /> that no other contamination is occurring,such as oil leaking from parked equipment or ore storage containers.
<br /> The rock currently on-site is non-acidic, however it does not seem the plan includes any methods for further
<br /> monitoring/testing of ore to determine it's acidic nature.Given the long-standing history of the environmental
<br /> hazards produced by stoping in other areas of Colorado,operations should not be allowed to continue without
<br /> stringent monitoring efforts to ensure any and all water coming from mine activity(including but not limited to
<br /> waste piles,settling tanks,container facilities,sheds and buildings, parking lots,water flowing from mineshafts)
<br /> is reasonably clean.
<br /> They are currently testing their paste backfill method,which seems to be crucial to some of their reclamation
<br /> plans to stabilize and fill underground cavities. If they cannot guarantee their reclamation and backfill efforts are
<br /> sufficient,they should not be allowed to continue mining activity.
<br /> They give no clear explanation for the reason for the expansion of permit activity and"affected land,"and
<br /> purport future constructed capabilities as part of the plan,without any detailed plans for such facilities(the mill
<br /> and wastewater facilities). If such facilities are so crucial to the mining plan,these should be included in the
<br /> application. If the applicant cannot acquire the funding to put up a sufficient bond for mining without these
<br /> facilities,these should be included in application.
<br /> Before the application is further considered, I request:
<br /> The applicant obtain a new letter from the EPA and Army Corp of Engineers assessing the expanded area and
<br /> re-assuring no further permits or approvals from their offices are necessary,given that the permit area has
<br /> significantly expanded to include Caribou Creek and its wetland watershed.(Letter provided in application is
<br /> dated 2021)
<br /> Subsequent to a hearing on this application,open another public comment period to ensure a robust and
<br /> transparent communication with the public.
<br /> A public notice be posted to all homes/homeowners with well water along Caribou Rd between the mine
<br /> discharge and Barker Reservoir of the application.
<br /> The public be made aware of a more specific map detailing mining, milling, road,and other activities.
<br /> The public be made aware of any potential impacts to recreational access on CR505 and it's connected trails.
<br /> The applicant be made to publish a statement that outlines the significant changes to their operations in the
<br /> local news outlets.The public notice printed did not include any information about the expanded acreage nor
<br /> the inclusion of a mill.
<br /> The applicant's Reclamation plan should be revised to include alternative shaft stabilization methods(that don't
<br /> include pumping waste slurry into the ground),soil remediation and especially clean-up of the ponds,and a 20-
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