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Comment/Objection Narrative* <br /> After observing eleven(11)individual exceedances of the National Pollutant Discharge Elimination System <br /> (NPDES)aquatic life water quality standards during the 2021 monitoring period,GIR installed a$200,000+ <br /> post-filtration, polishing media water treatment system to augment the historic water treatment provided by the <br /> three legacy settling ponds Tom Hendricks had been using. <br /> The good news is that there were only 11 exceedances of the 20 bi-monthly tests conducted during the relevant <br /> time frame—eleven of the more than 400 data points tested.The even better news is that the very stringent <br /> aquatic life standards that were exceeded 11 out of 400 times tested never violated National Primary Drinking <br /> Water Regulations(NPDWR)(see NPDWR-related table,attached)even at our point source, an 8"diameter <br /> pipe(see attached photos)4 miles above Nederland. <br /> The Colorado Division of Reclamation, Mining and Safety(DRMS)actually issued a press release on February <br /> 22,2022,to make it clear that,after reviewing the available water quality data, DRMS"found no evidence <br /> indicating groundwater discharges from the mine led to degradation of surface and groundwater resources." <br /> Our new water treatment system has prevented aquatic life standard exceedances since its installation and GIR <br /> has made plans to relocate it below the discharge pipe to allow a gravity fed treatment approach that will not <br /> even be subject to power outages in the future. <br /> In fact, had GIR not been there to respond to the Idaho Tunnel failure beneath Caribou Road with$4,000,000 <br /> and nearly 20,000 man-hours to restore the road, it might still not be passable for all those who enjoy recreating <br /> near the historic Caribou townsite. GIR's resources and corporate responsibility is proven by our actions, not <br /> just our words. <br /> Finally,with respect to the proposed new mine"expansion,"the boundaries of the existing 110 permit(10 acres) <br /> needed to be redrawn to permit GIR to begin processing and removing the mine tailings scattered throughout <br /> the Caribou and Cross mine area.The plans which are still under review by DRMS will require sequential <br /> processing of 5-1 0-acre sites around the legacy mine tailings,followed by reclamation in accordance with State <br /> requirements. <br /> Construction of an onsite mill to process the tailings and ore will permit the number of truck trips to be reduced <br /> substantially(by up to 20 times what would be required to process the ore off-site).The non-grade ore and <br /> waste rock can then be used to fill tunnels and shafts in the mine,safely closing them,and as road base—a <br /> continuing road-grading challenge in the Nederland area. <br /> With respect to certain statements made in the guest opinion,we would like to provide these additional <br /> comments: <br /> -As noted above,our exceedances of the very stringent aquatic life standards(11 times in 400 parameter tests) <br /> still remained compliant with federal drinking water standards,so characterizing them as"high levels of heavy <br /> metals discharged into Coon Track Creek"was probably not accurate.The unregulated Boulder County-owned <br /> Cardinal Mill discharges from and through its failed tailings ponds should be of greater concern. <br /> -Barker Reservoir is a rarely used source for the City of Boulder's drinking water supply,which primarily comes <br /> to the Betasso Water Treatment Plant in the Lakewood Pipeline from the North Boulder Creek watershed.Our <br /> 8"diameter pipe,4.5 miles northwest of Barker Reservoir(now effectively filtered through our state-of-the art <br /> system), is not a threat to well water, Barker Reservoir or the City of Boulder's drinking water supply. <br /> -The proposed onsite processing mill will not use toxic chemicals and an onsite mill will greatly reduce off-site <br /> truck trips. <br /> -Much of the waste rock removed from the ore concentrate will be redeployed onsite to fill tunnels and shafts, <br /> or as road base on roads in the near vicinity. <br /> -GIR has committed their resources and expertise to fulfill the traditions established by our former President, <br /> Tom Hendricks,to manage the Caribou and Cross mines in a manner that supports the community of <br /> Nederland and protects our neighbors from off-site impacts,while setting an industry-leading standard for <br /> environmentally responsible,sustainable and economically resilient hard-rock mining operations in the high <br /> alpine environment. <br /> Permitting Action Comment/Objection is Regarding <br /> New Permit Change to Existing Permit <br />