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DRMS Comment Objection Intake - DEV 3/30/2025
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DRMS Comment Objection Intake - DEV 3/30/2025
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Last modified
3/30/2025 9:45:01 PM
Creation date
3/30/2025 8:45:23 AM
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Template:
DRMS Permit Index
Permit No
M1977410
IBM Index Class Name
Application Correspondence
Doc Date
3/30/2025
Doc Name
Comment/Objection
From
Tracy Pheneger
To
DRMS
Email Name
JPL
JPL
Media Type
D
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Comment/Objection Narrative* <br /> I am writing to express serious concerns regarding the current application for M1977410 Cross Gold Mine, <br /> which fails to adequately address critical issues related to environmental protection,operational safety,and <br /> regulatory compliance. Below are key deficiencies that must be addressed before approval can be considered: <br /> 1.**Water Pollution Control** <br /> The application does not demonstrate how the mine will control water pollution during operations or in the long <br /> term post-mining.Given the history of water pollution problems in the area,a more detailed analysis of water <br /> quality protection measures is required under state law. <br /> 2.**Inadequate Treatment&Monitoring Systems** <br /> The application does not provide evidence that the proposed or existing treatment and monitoring systems will <br /> sufficiently protect groundwater and surface water during active mining. <br /> 3.**Lack of Detail on Ore Handling** <br /> There is insufficient information regarding plans for mined ore,including processing locations,transportation <br /> methods,and on-site storage.The absence of a clear transportation or storage plan raises significant <br /> operational and environmental concerns. <br /> 4.**Insufficient Hydrological Description** <br /> The application lacks a thorough description of surface hydrology, preventing the public from fully <br /> understanding which drainages and water bodies could be impacted by mining activities. <br /> 5.**Unreviewed Milling Operation Impacts** <br /> While the application references an on-site milling operation, it fails to provide enough detail to assess its <br /> impacts or reclamation requirements. <br /> 6.**Incomplete Financial Assurance for Reclamation** <br /> The reclamation plan must be fully incorporated into the proposed financial assurance(bond)to ensure <br /> complete and adequate reclamation. <br /> 7.**Wildfire Risk Ignored** <br /> Despite being located in the state's highest-risk area for wildfire probability and severity,the application does <br /> not address ignition risks(e.g.,explosives,equipment sparks)or mitigation measures to protect property and <br /> the environment. <br /> 8.**Lack of Emergency Preparedness** <br /> The application does not sufficiently address protections against wildfire,flood,or blackout events, nor does it <br /> clarify emergency response protocols or community notification systems. <br /> **Additional Concerns from Local Stakeholders** <br /> As highlighted in a*Mountain Ear*article,the Town of Nederland has raised important questions, including: <br /> -Emergency response and notification transparency. <br /> -Impacts on wildlife,vulnerable populations,and local air/noise quality. <br /> -Unclear dust mitigation from milling and transport effects on the community. <br /> -Financial accountability and operational oversight. <br /> Given these deficiencies, I urge you to require a revised application that fully addresses these issues before <br /> any approval is granted.The potential risks to water quality, public safety,and the environment demand <br /> thorough scrutiny. <br /> Thank you for your attention to this matter <br /> Sincerely, <br /> Tracy Pheneger <br /> Permitting Action Comment/Objection is Regarding <br /> New Permit Change to Existing Permit <br />
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