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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 <br />