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inclusion of the milling activity,which could impact air quality,water quality,and soil quality.
<br /> However, no such plans are provided here,and applicant is vague about any impacts that
<br /> operation could have on the surrounding environment,especially if any endangered species,such
<br /> as cutthroat trout,are found in Coon Track Creek. Milling activity could lead to even greater
<br /> environmental concerns than the mine operations,with even more chemicals or other hazards
<br /> 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
<br /> include an environmental assessment,completed by a professional third party,and should
<br /> include recommendations from CPW and other relevant entities.
<br /> Regarding Reclamation Plans.The plans provided are insufficient for exploring the full
<br /> range of potential detrimental impacts to the environment and the public.Admittedly,the aquifer
<br /> referred to in the application that would potentially be impacted,"has a refill rate of 1-500 years,"
<br /> which is a difficult variable to swallow. Mining requirements include that the applicant must
<br /> thoroughly understand the waters they may impact,and return the land to a natural state after
<br /> activity ceases.The application also states the reclamation plan is for within 5 years,then
<br /> purports that it will only take 3 years.This is because the plans are very basic.They claim no
<br /> need for remediation of any site,simply grade,cover with topsoil,and plant.This is perhaps
<br /> sufficient rehabilitation of land for a road, rock pile,or other areas, but this does not feel
<br /> sufficient for closing up mineshafts.
<br /> •The vegetation plans are lacking in biodiversity.The plan states the operator will
<br /> purchase a bulk grass seed mix,and add in some yarrow.This is a good start to a
<br /> vegetation plan, but is not by any means sufficient to reclaim almost 10 acres(or more if
<br /> activities occur on the 200+acres requested).
<br /> • Surface water diversion methods are to be left in place to deteriorate, including buried
<br /> water lines that discharge from the mine.This does not seem sufficient to restore the land
<br /> to a natural state.
<br /> • Rock shifts and moves overtime,meaning closed entryways can re-open,as well as new
<br /> cracks can open in areas expected to be contained.The paste backfill method mentioned
<br /> could be a huge risk to groundwater if rock were to shift and dislodge any toxic material
<br /> into nearby water sources.
<br /> Regarding this"pilot project"operation. Furthermore,A GIR representative stated,when
<br /> referencing a new ore processing facility,a septic system,and a road to connect the two mines
<br /> "that the mines were to be GIR's"pilot project,"to serve as a template for their future business
<br /> operations."(The Mountain Ear."Status of the Caribou and Cross Mines."February 22,2024)If
<br /> any approval were to occur, it should be only under strict and frequent monitoring for impacts to
<br /> the environment.
<br /> •They are currently testing the efficacy of their wastewater treatment method.The plan
<br /> mentions"periodic"testing of water and wastewater,yet it is unclear how often it will
<br /> occur.Testing should occur whenever there is an out-of-ordinary incident,and at least
<br /> weekly if not more frequently to ensure any hazards are identified and remediated as
<br /> quickly as possible. If they cannot guarantee reasonably clean water discharge,
<br /> operations should not be allowed to continue. Further,testing should occur on multiple
<br /> places on the property to ensure that no other contamination is occurring,such as oil
<br /> 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
<br /> methods for further monitoring/testing of ore to determine it's acidic nature. Given the
<br /> long-standing history of the environmental hazards produced by stoping in other areas of
<br /> Colorado,operations should not be allowed to continue without stringent monitoring
<br /> 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
<br /> flowing from mineshafts)is reasonably clean.
<br /> •They are currently testing their paste backfill method,which seems to be crucial to some
<br /> of their reclamation plans to stabilize and fill underground cavities. If they cannot
<br /> guarantee their reclamation and backfill efforts are sufficient,they should not be allowed
<br /> to continue mining activity.
<br /> •They give no clear explanation for the reason for the expansion of permit activity and
<br /> "affected land,"and purport future constructed capabilities as part of the plan,without
<br /> any detailed plans for such facilities(the mill and wastewater facilities). If such facilities
<br /> are so crucial to the mining plan,these should be included in the application. If the
<br /> applicant cannot acquire the funding to put up a sufficient bond for mining without these
<br /> facilities,these should be included in application.
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