DRMS Comment Objection Intake - DEV 4/2/2025 (40)

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close due to insufficient profits. • GIR's management practices seem questionable,and their safety and emergency planning is lacking in detail.This can pose risks to the health and safety of their workers. Regarding Environmental&Public Health Concerns Generally. Coon Track Creek,Caribou Creek (which is included in the permit,yet claimed to not be at risk of any ill effect),and the surrounding watershed are multi-use recreation areas that draw activity throughout the year.The application mentions no impact to this area that is included in their application.These areas feed into the water supply for the City of Boulder, but also into habitats,soils and backyards before accumulating in Barker Reservoir.The main mine site is 2.7 miles,as the crow flies,from Nederland Elementary School. Between the mine and Nederland are several dozens of homes, watered by natural wells and springs.This proposal and large expansion of activity leaves many questions left unanswered,and could have significant detrimental impacts on the health of the environment and it's inhabitants within the entire watershed downstream of the activity. • It is unclear on which areas of land different activities will take place,since the application available to the public does not include the maps for Exhibit C. If GIR is allowed to prospect,or does prospect due to lack of oversight manpower,in the 200+ acre area requested in the application,there is potential for significant detrimental impacts to not just Coon Track Creek,but also Caribou Creek and it's watershed. •The application does not mention conflicts with recreational activity. Increasing mine traffic and an increased permit boundary may lead to conflict with recreators and the natural environment.This is a narrow mountain road that requires 4x4 access,and there have been a number of accidents and rollovers due to the steep grade and narrow width that make two-way traffic difficult at times. •The application does not mention any conflicts with wildlife. It does not mention the potential for large spills to affect wildlife,and further does not give consideration for other factors such as explosive activity and how it disturbs wildlife,increased truck traffic and construction noise pollution that will disturb wildlife, nor how they handle wildlife interactions with GIR employees/contractors. It is unclear if the fencing surrounding the mine site is adequate to protect wildlife from entering the area. Regarding the style of mining proposed.Stoping can forever alter the landscape, including but not limited to,erosion,sinkholes,soil contamination,and groundwater contamination. •The method can cause land subsidence,leading to structural damage in nearby areas. •The method requires large amounts of water,potentially depleting local water resources. •The method can lead to long-term contamination by waste materials if not properly managed,affecting the watershed and natural inhabitants for decades or more. •The method also poses health risks to workers,including exposure to hazardous substances and physical injuries.The Idaho tunnel collapse in 2019 is a testament to how quickly and unexpectedly disaster can occur at the Caribou and Cross Mine site. •While the application does mention elk, moose and other wildlife in the area, it is an incomprehensive list sourced from government data, not actual observation and not from any environmental assessment),and it does not mention any provisions regarding calving season or other life cycle events.The application states they will not seek CPW recommendations,though it is highly encouraged. •The application only specifies one potential hazard to surface water,which is the discharge permit regulated by CDPHE.The applicant claims there is no risk of acid drainage from waste rock. It is rare for mining activity to not produce runoff,and to not affect other waters than the discharge flow.Thus, it feels incomplete. •The environmental protection plan does not outline specific measures for protection (especially in regards to potential impacts on endangered species like the wolverine, Canada lynx or Colorado cutthroat trout)such as habitat restoration, buffer zones for operations,and long-term monitoring. I have personally witnessed both Canada lynx and wolverine in the area of Caribou Road and FSR 505. Not evaluating these factors before approving the permit risks irreversible harm to local biodiversity. •The application mentions a paste backfill method for mine clean-up. In other areas,these encapsulated pockets of mine waste have leached into groundwater over time. Many homes are on well water within 3 miles of the mine, but the application does not mention a potential impact to these groundwater sources.The application states there has not been any site-specific study of the aquifer that feeds the area. 1 +h..f..11 +_+hr..—+i.. k-A...i...I.1 nr.i. -mn..n.nn..f+hi.