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Comment/Objection Narrative* <br /> As a Colorado native I appreciate the rich mining history of the area.As a former Utah Division of Oil, Gas and <br /> Mining abandoned mine reclamation specialist and active mine permit team member, I understand both the <br /> potential devastation that can occur from mining and that advances have been made in mining extraction and <br /> reclamation techniques over the decades.With both of these perspectives and as a current resident of Boulder <br /> County,downstream of the Cross-Caribou mine site, I am concerned that expansion of the mine operations, <br /> which only begins with conversion of the existing permit,could have significant impacts. <br /> While I am not familiar with DRMS's permit structure, I am concerned about: <br /> —Impacts to area wildlife,their habitat,and to recreation use of the area due to land disturbance, noise,traffic, <br /> and dust during both construction and operation of an expanded mine and mill. GIR minimizes the potential <br /> impacts from the proposed amendment in which they request a 20 fold increase in the permit area.While no <br /> new disturbances are currently planned for this additional acreage, neither does GIR discuss potential future <br /> impacts nor the cost and issues of reclaiming disturbance of this expanded area that would result from the <br /> intended expansion from their current operation to a commercial mine and mill. <br /> —Impacts to water quality, based on occurrence of past violations and indications of inadequate infrastructure <br /> (e.g., needs to bypass frozen ponds)coupled with GIR's apparent lack of a full understanding of the area <br /> hydrogeology.While the plan suggests". . .the lack of any acid rock drainage potential."(page G-7),the DRMS <br /> has apparently determined that conversion to a DMO 112D permit is necessary for continued operation"due to <br /> the potential for mineralized materials to generate acidic water."(Conversion Application, Introduction). <br /> Furthermore,GIR"intends to conduct a comprehensive Hydrogeologic Study of the Mining Complex"that is <br /> considered" . . .critical and essential for near future and long-term operations and water quantity and quality <br /> management."GIR has, however,made zero percent progress on that study. (GIR's Quarterly Report for the <br /> 2024 4th Quarter,page 9). How can the permit conversion plan be adequate if it is not based on data and <br /> analysis from a comprehensive understanding of the area hydrogeology?Furthermore,despite the importance <br /> of protecting water quality, GIR apparently plans no water quality monitoring after closure and reclamation of <br /> the site. (Reclamation Plan at E-11 and Reclamation Cost Estimate, Exhibit L,at 367). <br /> GIR's ability to both protect water quality and to address emergencies that might occur at either the current or <br /> an expanded operation is also questionable because of their apparent inadequate staffing and financial <br /> resources to perform activities planned for the site.As recently as their 2024 Fourth Quarter Report,GIR states: <br /> "Activities planned for Third Quarter of 2024,were not performed by GIR due to staffing and financial <br /> constraints;the planned activities for the Fourth Quarter of 2024 remain unchanged from the First Quarter 2024 <br /> . . ."(GIR's Quarterly Report for the 2024 4th Quarter, page 13). Expanding development of the site on a <br /> shoestring budget and with a bond seeming to cover only the current disturbance,would risk significant <br /> negative impacts on the area environment and to both local and downstream communities. <br /> Permitting Action Comment/Objection is Regarding <br /> New Permit • Change to Existing Permit <br /> Permit Number* (?) <br /> Enter a valid permit number <br /> M1977410 <br /> Revision Type and Sequence <br /> 112D <br /> County <br /> Colorado County where the proposed operation is located <br /> Boulder <br /> Enter one county only <br /> Site Name <br /> Cross Gold Mine <br /> Perm ittee/Operator Name <br /> Grand Island Resources <br /> ADDITIONAL INFORMATION <br />