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Comment Collection - DEIR - CEA Foundation - March 2022

Read comments prepared by experts, volunteers, and legal minds from CEA Foundation and its MineWatch coalition members about the Draft Environmental Impact Report (DEIR) for the proposed reopening of the Idaho-Maryland Mine.

“This DEIR is riddled with errors, omissions, and legal flaws”, said Ralph Silberstein, President of CEA Foundation. “We’ll see many more impacts listed as significant and unavoidable before this is done." Read the press release.

 

CEA FOUNDATION & MIneWatch Coalition

MineWatch Coalition - Summary Letter 18 page subset of the CEA Foundation comment letter, signed by coalition members.

CEA Foundation - Full Comments

CONSULTANT LETTERS

Center for Science in Public Participation (CSP) - by Dave Chambers

Legal Comments from Shute, Mihaly & Weinberger

Baseline Environmental Consulting Report Covers hazards, hydrology, air quality, and greenhouse gas emissions

Salter Report Noise

LOCAL Agency Comments

Read local agency comments, (City of Grass Valley, Nevada Irrigation District, Northern Sierra Air Quality Management District, Central Valley Regional Water Quality Control Board)


Files referenced with CEA FOUNDATION comments

Review of the Idaho-Maryland Mine DEIR Groundwater Model Examines the data and analysis used to create the model

Review of the ITASCA Groundwater Model Identifies multiple assumptions that understate the extent of groundwater drop

Mine Exhaust Moisture Provides facts about saturated air coming out of the mine and the potential cloud plume

Faulting Hazards Identifies potential seismic hazards from mining activities adjacent to and through fault lines

Health Risk Assessment Critique

Sampling Procedures Critique Identifies the very few samples used to characterize mine waste, etc.

Sample Quality Control Review Details the failure to process specific tests correctly, making much of the data unreliable

ASUR Plan Analysis Examines the issues with the asbestos mitigations and the air quality hazard

ADDITIONAL MINEWATCH COALITION COMMENTS

Wells Coalition



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