Comment/Objection Narrative*
<br /> To:Colorado Mined Land Reclamation Board1313 Sherman Street, Room 215Denver,CO 80203
<br /> Subject:Objection to Cross Gold Mine DMO Permit Application(Permit No. M-1977-410)
<br /> Dear Members of the Mined Land Reclamation Board,
<br /> I am writing to formally object to the approval of Grand Island Resources LLC's(GIR)application for the
<br /> Caribou-Cross Gold Mine(Permit No. M-1977-410).The proposed expansion raises serious concerns
<br /> regarding environmental protection, public health, regulatory compliance,and the adequacy of reclamation
<br /> efforts.Given these concerns, I urge the Board to reject the application or impose significantly stricter oversight
<br /> and conditions.
<br /> Environmental and Public Health Risks
<br /> The proposed activities would impact Coon Track Creek, Caribou Creek,and the surrounding watershed,which
<br /> feed into Barker Reservoir,a critical water supply for the City of Boulder and local residents.The permit
<br /> includes areas near well-water-dependent homes and Nederland Elementary School,yet it lacks sufficient
<br /> assessment of groundwater contamination risks.Additionally,the mine is situated in a heavily used recreational
<br /> area,and the application does not address potential conflicts with outdoor activities.
<br /> The mining method proposed—stoping—poses long-term risks, including land subsidence,erosion,and
<br /> groundwater contamination.The company claims there is no risk of acid drainage,yet it has not provided site-
<br /> specific studies to verify this.The potential for toxic runoff, habitat destruction,and water depletion requires far
<br /> more scrutiny before any approval is granted.
<br /> Company Compliance,Transparency,and Bond Sufficiency
<br /> GIR has a record of regulatory violations,demonstrating a lack of accountability.The company's environmental
<br /> impact plan is vague and does not adequately address wildlife disturbances, hazardous spills,or mitigation
<br /> strategies for noise and pollution.The proposal also lacks transparency regarding where specific mining
<br /> activities will take place, particularly given the absence of Exhibit C maps in the public application.
<br /> The bond proposed appears inadequate to cover full reclamation costs,especially considering long-term water
<br /> treatment needs. Many mining operations underestimate costs, leading to taxpayer-funded cleanups.GIR must
<br /> provide a more comprehensive financial assurance plan to cover worst-case environmental scenarios.
<br /> Inadequate Reclamation and Long-Term Monitoring
<br /> The reclamation plan provided is oversimplified and does not adequately restore the land to a natural state.The
<br /> proposed method—grading,topsoil cover,and grass seeding—is insufficient for mine closure, particularly
<br /> regarding shaft stabilization and long-term groundwater protection.Additionally,the use of paste backfill raises
<br /> concerns,as similar methods have led to groundwater contamination elsewhere.
<br /> Surface water diversion systems and buried water lines are set to be left in place,with no clear long-term
<br /> maintenance plan. Given that rock shifts unpredictably, new fissures could form,creating pathways for toxic
<br /> materials to enter the watershed.A thorough,site-specific hydrological study is necessary before any
<br /> expansion is approved.
<br /> Lack of Clarity on Future Expansion and Processing Facilities
<br /> GIR representatives have referred to this project as a"pilot"for future operations,yet the application lacks
<br /> details on planned infrastructure, including a mill and wastewater treatment facility.These operations could
<br /> significantly increase risks to air,water,and soil quality.Any proposal for a mill should be subject to a separate
<br /> application with full public notice and comment.
<br /> Requests for Further Review and Public Engagement
<br /> Before any further consideration of this permit,the following must be required:
<br /> •A new environmental impact and hydrology study assessing risks to the aquifer and watershed.
<br /> •A revised reclamation plan with detailed measures for mine closure, long-term water quality monitoring,and
<br /> alternative stabilization methods.
<br /> Stronger third-party oversight of wastewater discharge, hazardous material storage,and wildlife impact
<br /> mitigation.
<br /> A revised and publicly available map clearly defining the areas of proposed mining, road expansion,and
<br /> processing activities.
<br /> A new letter from the EPA and Army Corps of Engineers reassessing the project's expanded footprint and
<br /> confirming whether additional permits are required.
<br /> A second public comment period to ensure transparency and allow for community input on the expanded
<br /> project scope.
<br /> Given the lack of transparency, potential for significant environmental harm,and GIR's inadequate planning, I
<br /> strongly urge the Board to deny this permit to protect the health of our water, land,and community.
<br /> Permitting Action Comment/Objection is Regarding
<br /> 9 New Permit Change to Existing Permit
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