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Comment/Objection Narrative* <br /> As a Boulder resident and PhD in toxicology with a professional background in environmental health, I am <br /> deeply concerned about the inadequacies and omissions in this application.The potential human and <br /> ecological risks posed by the proposed mining operation are significant,and this application fails to meet basic <br /> standards of transparency,accountability,and environmental protection. <br /> Water Quality Risks <br /> The application fails to demonstrate how water pollution will be prevented and controlled during both active <br /> mining and post-closure phases. Given Colorado's legacy of water contamination from mining operations, it is <br /> alarming that the proposal does not include a detailed water management plan. Under state law,a thorough <br /> analysis is required to ensure future water quality protection—and that standard has not been met here. <br /> The current treatment and monitoring plans, both as they stand and as proposed,do not convincingly <br /> demonstrate that surface and groundwater will be adequately protected.As a toxicologist, I find the lack of <br /> specificity regarding the handling of potentially hazardous runoff unacceptable. <br /> Ore Processing and Transport <br /> There is also an alarming lack of clarity on how and where ore will be processed, how it will be transported,and <br /> how it will be stored on site.This is a critical oversight,as ore handling and transportation are major sources of <br /> environmental and community disruption—including the potential release of dust and heavy metals. <br /> Incomplete Environmental Impact Assessment <br /> The application lacks a sufficient description of surface hydrology, making it impossible to fully assess which <br /> watersheds and aquatic ecosystems may be affected.This omission is particularly concerning given the <br /> interconnected nature of Boulder County's water systems. <br /> The proposed on-site milling operation is mentioned but not adequately described,especially regarding its <br /> environmental impact or the reclamation measures that would be necessary post-operation. <br /> Inadequate Reclamation Financial Planning <br /> The proposed financial assurance(bond)for reclamation does not clearly account for the full scope of <br /> environmental repair that may be necessary.Without incorporating all aspects of the reclamation plan,this bond <br /> falls short of ensuring financial accountability. <br /> Wildfire and Disaster Preparedness <br /> The application completely overlooks the risk of wildfire ignition, despite the proposed mine's location in one of <br /> the highest wildfire risk zones in the state. Furthermore, it fails to address protections against flooding, blackout <br /> events,or other disaster scenarios—conditions that are increasingly likely due to climate change. <br /> Community Concerns Echoed by Local Leaders <br /> I echo the Town of Nederland's concerns, including those outlined by Town Administrator Jonathan Cain and <br /> Mayor Pro Tern Nichole Sterling.The application is silent on emergency response planning, noise and air <br /> pollution controls,wildlife impacts,effects on vulnerable populations,and overall technical and financial <br /> oversight. <br /> Given the scope and potential risk of this project,this application must be rejected until GIR can provide <br /> comprehensive,evidence-based plans to protect public health,the environment, and our local 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 /> County* <br /> Colorado County where the proposed operation is located <br /> Boulder <br /> Enter one county only <br />