DRMS Comment Objection Intake - DEV 3/31/2025 (24)

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Comment/Objection Narrative* Boulder County Nature Association(BCNA)strongly objects to the referenced permit application submitted by Grand Island Resources(GIR)to significantly expand"designated"mining operations. Even if strict permit conditions are developed,funded,applied,and enforced,the proposed mining and processing operations will cause numerous and significant adverse environmental and public health impacts to the greater Nederland area and potentially as far downstream as the City of Boulder. Impacts would include: -Acid mine drainage of toxic and radioactive materials affecting terrestrial and aquatic habitats and species, and surface and ground drinking water supplies. -Air pollution and noise from operations and material transportation, including toxic chemicals and dust. -Significant habitat destruction and ecosystem degradation, including tree removal,species extirpation,soil degradation,erosion,and stream sedimentation. -Public safety associated with significant increases in vehicle traffic(trucks and cars). -Accelerated wear and tear on public roadways. -Impacts on public lands, including Boulder County lands and associated recreational uses. -Damage to area cultural resources. -Economic impacts associated with the above-listed impacts. If the permit application is approved,hopefully extensive permit conditions will be developed and enforced to mitigate adverse impacts.Some key conditions are listed below. -Require the applicant to demonstrate(1)the ability to sustain compliance with water quality standards at current activity levels before permitting a 20-fold expansion,and(2)the ability of the upgraded water treatment system to effectively treat water from a greatly expanded operation of over 200 acres. Rigorously assess the likely impact of the proposed expansion of existing tunnels and the creation of new tunnels upon ground and well water. -To ensure the quality of downstream water complies with all applicable standards protecting humans,fish and wildlife, put a rigorous and frequent water quality monitoring system in place for 100+years.Also, if the applicant is to remove up to 40,000 cubic yards of waste rock for 50 years,then measures to prevent acid mine drainage, including testing of waste and host rock,are appropriate. -Ensure the environmental protection plan addresses adjacent areas as well as points downstream;specifies which minerals and chemicals will be present in the ponds and at what anticipated concentrations;and explains how current birds,and aquatic and terrestrial species will be protected.Additionally,the applicant plans to re- route surface water flows uphill of the operation around the disturbance area. Require the applicant to explain how Coon Track Creek,its associated wetlands,and the surrounding ecosystem will be impacted by this re- routing and how they will mitigate the associated impacts. -Require the maximum permissible financial warranty to cover the risk of bankruptcy and all potential environmental damage so local municipalities and downstream water users are buffered from potential clean-up and water replacement costs to the maximum extent permissible by law. -Require the applicant explain how explosives will be stored and used so the fire danger is reduced to the greatest extent possible.Then consult with experts, including the US Forest Service,about the adequacy of these measures. Require the applicant explain how explosives will be stored and used so the fire danger is reduced to the greatest extent possible.Then consult with experts, including the US Forest Service,about the adequacy of these measures. Require the applicant to minimize all construction-related impacts,including traffic disruption, noise,dust and erosion/sedimentation. Require the applicant to monitor air quality and noise during all construction and operational hours,and comply with all applicable air quality,dust and noise standards and local requirements. Require the applicant to develop a comprehensive traffic management plan to maximize public safety and minimize noise during construction and operation, including any night-time work.Also, require applicant to resurface any degraded roadways. Require applicant to work with the adjacent public and private landowners, including CPW and BCPOS,to understand and address their concerns. Remedy could include compensation for damages.The effort should include the identification and protection of all cultural resources that could be impacted. Require the applicant to work with local city and county agencies,and businesses,to identify and minimize any associated economic impacts,such as reduced business activity due to construction and operational traffic, temporary and permanent loss of recreational opportunities and related revenue,and loss of timber revenue. Thank you for your consideration of the BCNA comments.