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Supervisors will make the final vote in October. The unavoidable reality is... you can’t fix this project. It sits in the middle of a neighborhood that is reliant on private wells for drinking water. There is no viable solution for disposing of the mine waste. And it has an unacceptable energy footprint. This opinion piece by the Community Environmental Advocates Foundation Board of Directors was originally published in The Union. June 23, 2023 On May 11, the Nevada County Planning Commission unanimously voted “No” on the Idaho Maryland Mine project and its flawed Environmental Impact Report (EIR). Even Rise Gold’s last minute ”carrots” to reduce its impacts did not sway the Commission. And now that we have seen Rise’s conspiratorial rant about unfair treatment and indications of a lawsuit as the “stick”, we can expect that they will add more “carrots” before the project goes before the Board of Supervisors for a final vote later this summer. Regardless, the unavoidable reality is, you can’t fix this mine project. It sits in the middle of a neighborhood that is reliant on private wells for drinking water. There is no viable solution for disposing of the mine waste. And it has an unacceptable energy footprint. THE MINE WASTE PROBLEM CAN’T BE FIXED The mine project depends upon being able to dispose of the mine waste (sand tailings and waste rock) by off-site sales as fill materials or construction aggregate. Rise has tried really hard to sell the idea that the mine waste is clean enough to be used without restrictions, but the Water Board stated that the testing results were insufficient to make this determination. At stake is the risk of long term toxic mine waste discharge into our creeks, like we have from past mining projects. The most reliable test data on the potential for this hazardous drainage is from the water that currently flows out of the mine drain, and those tests show high levels of arsenic, manganese, zinc, and iron. So it is unlikely that Rise’s mine waste leachate will be any cleaner. Compounding the problem, the Air Quality Board will require all exported materials to be categorized as “Restricted” due to the potential health hazards from the rock’s asbestos content. There’s no real market for “Restricted” mine waste. Even if some or all of the mine waste tests clean enough to allow off-site sales, the market for aggregates is flooded. The EIR falsely interpreted data indicating that Sacramento would be a viable market, and failed to note that there are abundant supplies of clean aggregate already available nearer there. Furthermore, even if there were a market for the waste, the mine lacks the necessary facilities to produce most forms of construction aggregates. In other words, Rise Gold has no viable solution for disposing of the mine waste. THE THREAT TO LOCAL WELLS CAN’T BE FIXED Numerous experts assert that, because of the fractured rock system around the mine, there is no way to reliably predict the impact on local wells from pumping out the mine water. Even the computer model provided by Rise acknowledges that more data is needed to validate the model’s predictions, yet that model predicts groundwater levels to drop 1-10 feet over a large area. To complicate the problem, Rise’s hydrology documents contained significant errors regarding initial ground water conditions, and no current groundwater data was collected even though at least 3 years of data are needed for a reliable baseline. Thus, the FEIR included no means of accurately determining impacts on individual wells and no mandatory mechanisms for providing remedies. The Nevada Irrigation District has made it clear that if wells are impacted, it may take years to get easements, design and install water mains, and provide service connections to homeowners. This is unacceptable. The more than 300 well owners in the area should be completely protected from damages. GREENHOUSE GAS IMPACTS CAN’T BE FIXED “Net Zero” is the State’s goal for carbon emissions by 2045. Yet, the EIR states that the mine will emit over 9000 tons per year of greenhouse gases. The project completely fails to adequately address the emissions for the 80 year lifespan of proposed operations. The mine’s annual electricity use would be equal to 5,575 homes. This use would completely offset the amount of residential electricity reductions the County wants to achieve in its Energy Action Plan. If we’re serious about the County Energy Action Plan and the climate crisis, the mine is a non-starter. IN CONCLUSION In reaching their decision, the Planning Commission did their homework and professionally considered the evidence over the two day hearing. We hope that the Board of Supervisors will show the same level of professionalism, neither bow to the “sticks” nor be swayed by the “carrots”, and vote no on this deeply flawed project. Community Environmental Advocates Foundation Board of Directors, email info@cea-nc.org

Why did County staff recommending denial of the mine project but approval of the EIR? Only denying the Mine and the EIR will defeat it for good. This opinion piece was originally published in The Union. Community Environmental Advocates Foundation Board: If certified, the Mine EIR will haunt us; Only denying the Mine and the EIR will defeat it for good. May 10, 2023 The Nevada County Planning Department has, for good reason, recommended that the County Planning Commission vote to deny the Idaho Maryland Mine zone change and variance. That may sound a lot like a “No”, but the devil’s in the details. Staff continues to recommend certification of the Final Environmental Impact Report (EIR). Certifying the EIR would be tantamount to leaving an opening to the future approval of a mine at this site. Only denying the Mine and the EIR will defeat it for good. If there is no mine there is absolutely no need for an EIR The county is under no obligation to certify the EIR if the project is denied. Case law is clear on this topic e.g., Las Lomas Land Co., LLC vs City of Los Angeles (2009) Cal.App.4th 83. Why the EIR must not be certified The EIR is totally deficient. It fails to disclose and evaluate the Mine’s significant negative environmental effects, it does not analyze a reasonable range of alternatives to the Mine, and it fails to identify adequate mitigation measures. Here are a few examples: The EIR relies on groundwater data that is over 15 years old as the baseline for determining whether the Mine will have significant impacts on water quality and water supply. It fails to mitigate the Mine’s air quality impacts, even though the EIR acknowledges they will be significant; and similarly, it dismisses significant greenhouse gas emissions and their contribution to climate change. Even if the project is denied, the certified EIR could be relied on in the future to support the approval of yet another mining proposal at this site. Rise Gold, or even a new applicant, could come back in the years ahead with a new mine proposal. However, if the EIR is certified, a new application could use the County’s officially sanctioned EIR to satisfy environmental review requirements, perhaps with minor additions. This would constrain the County’s discretion and leave it vulnerable to a claim that it is required to approve a proposal without the analysis and mitigation necessary to address the significant impacts of a future mining project. If the EIR is certified, the community will be forced to watchdog the county for years to come, waiting for a new mine proposal and the need to fight this battle again. The solution is simple, and the County needs to make it clear: Only denying both the EIR and the Mine will put this project and future ones like it to rest once and for all.

CEA Foundation submitted the following technical, historical, and legal comments to Nevada County in advance of the Vested Rights hearing for the Idaho-Maryland Mine in December 2023. Technical and historical analysis from CEA Foundation Legal analysis from CEA Foundation attorneys, Shute, Mihaly, & Weinberger, October 17, 2023

Read comments prepared by experts, volunteers, and legal minds from CEA Foundation and its MineWatch coalition members about the Final Environmental Impact Report (DEIR) for the proposed reopening of the Idaho-Maryland Mine. CEA FOUNDATION & MIneWatch Coalition CEA Foundation Final EIR Comments April 17, 2023 MineWatch Coalition - 26 Local and State Groups Call for Denial of the Mine Shute, Mihaly, Weinberger Legal Comment Letter & Exhibits FOCUSED COMMENTS ON Major Issues Major CEQA Point / Centennial Site The Final EIR failed to include the cleanup of the Centennial site, the location of the mines historic tailing Water and Wells Comments Well owners are getting the shaft - the claim that groundwater impacts won't be "significant" is not substantiated. Mine Waste Water Impacts Water quality hazards from mine waste were not adequately assessed Review of the Idaho-Maryland Mine DIER Groundwater Model Mine Waste Asbestos Impacts Comments Defects with assessment and mitigation of Air Quality and Asbestos Mine Waste Offsite Sales Comments The mine lacks a viable plan for disposing mine waste. Greenhouse Gas Comments The Final EIR used the wrong standards for Greenhouse Gas Emissions Mine Potential Seismic Hazard Mine Exhaust Moisture Potential Hazard, Aesthetics, and Air Quality Impacts

Special Guest Speaker and Geologist, Rick Humphreys, gives the community a backgrounder on mine waste and its effluents, which are some of the very real consequences of historical and potential future mining in our area. From the MineWatch Community Meeting September 2022. Rick Humphreys, pursued his undergraduate and master’s degrees in geology at Cal State University, San Jose. Rick comes from a mining family and spent most of his career as a scientist with the State Water Resources Control Board where he worked on water assessments of active and historic mines. After retirement, Rick and was a Science and Policy Advisor to The Sierra Fund and worked on TSF's Toxic Mining Initiative. Rick's talk is divided into three parts. The first part is an overview of mines and how they work with some terminology to help think and talk about what actually occurs underground in an operating mine. The second part will focus on mine waste, the different kinds there are and what is unique to each kind of waste. The third part is about mineral oxidization of earthen materials like mine rock and what are the results of these processes. FULL COMMUNITY MEETING PRESENTATION This expanded version of the presentation includes audience questions and answers. 00:00 - Introduction - Moderator, Greg Thrush introduces the session 04:57 – Project Update - CEA Foundation President Ralph Silberstein gives an update on project status. 12:00 – Mines – Rick Humphreys introduces the audience to key mining terminology and shows examples of how mines are typically laid out. 17:34 - Mine Wastes - Rick explains the differences between types of mine wastes, including mill tailings, heap leach waster, waste rock, and overburden. He also talks about the importance of characterizing the wastes and the complexity of sampling and testing in advance of mining and on an ongoing basis. 33:50 - Questions and Answers - Rick and Ralph answer audience questions 51:00 - Acid generation potential of earthen materials - Rick delves into the issues with acid mine drainage, gives an overview of the causes, and provides some discussion of approaches to mitigate the risks. 1:07:50 – Questions and Answers - Rick and Ralph answer audience questions 1:18:20 – Take Action - Greg describes current projects and ways to get involved in the fight against the mine. PDF SLIDES Script Mines Mine Waste Class Acid Generation Mines Underground Mine Terminology These are some terms used to describe underground mine features. Some are self descriptive while others, well, they’re head scratchers. Vein Vug Adit Portal Shaft Stope Drift Breast Incline Decline Winze Hanging wall Footwall Headframe Cage Roof bolt Room and Pillar Bit Blast hole Muck Chute Run-of-mine Underground Mine Schematic #1 The schematic depicts a plane view of a generic underground mine. There should be an air shaft from the upper adit to the mountain top. Ground water draining into the mine working either flows out the portal or is pumped from the sumps. Underground Mine Schematic #2 Appianing, E.J. et al, MOL Report Nine, 2018 The schematic depicts an underground mine in flat terrain. In this case ventilation is provided by compressors and ground water is pumped from the mine. You’ll get a better feeling of the three D nature of the mine workings under Grass Valley when we view the Empire Mine Model tomorrow. Mine Wastes Mill Tailings. Heap leached waste. Waste rock, overburden. Waste rock and mill tailings common at abandoned mines. The second presentation covers the types of mine waste produced by a modern mine, wastes at abandoned mines and dredge spoils. At new mines, waste behavior in its final resting place is unknown. Determining how a mine waste will behave (and what its effluent characteristics are) is the whole point of doing static and kinetic tests. In contrast, mine waste at old mines has had time to “behave” so the point of testing is to determine how it is behaving (is the mine waste or its effluent a problem). For new mines, characterizing mine waste should be a continuous process that begins during exploration and continues as long as mining and processing ores continues. In the end, mine waste produced falls in to three gross categories. All three waste may be found at recent mines, waste rock and mill tailings are common at abandoned mines. Mill tailings Ore ground in a mill to sand size and finer. Characterized chemically and mineralogically. Often contain processing reagents. Discharged to impoundments, lakes, the ocean. Mill tailing are wastes from ores that have been mechanically ground and processed to recover the product of interest. Modern mines have data on tailings they generate. Old gold mine mill tailings frequently contain mercury. Mill tailings often contain elevated levels of metals, metalloids, and constituents such as sulfate. There’s rarely any historical data for old mill tailings. As with waste rock, old mill tailings are essentially an unmonitored kinetic test. Heap leach waste Ore ranges from 13mm to >30cm. Often augmented with cement. Not as well characterized as mill tailings. Leached with cyanide on liners. Closed in-place. Heap leach waste is ore that has been leached with cyanide to recover gold and silver. Heap leaching is a relatively new process (implemented in 1980). In the early days of heap leaching, old mine waste (both mill tailings and waste rock) was “reprocessed”. Waste rock (see overburden) Particle size ranges greatly. Most voluminous waste but poorly characterized. Dumped as close to the mine as possible without (the company hopes) any need for containment. Waste rock does not have enough of the product of interest to warrant “processing” at current market prices. Waste rock can become ore and ore can become waste rock over the course of days depending on the commodity market. Old waste rock dumps are essentially unmonitored kinetic tests. Overburden May be “soil” that is stockpiled for reclamation. May be “non mineralized overburden” that is used for constructing impoundment berms, road beds, etc. May be “mineralized overburden” which is really identical to “mineralized waste rock”. Poorly characterized. As you can see, there’s some ambiguity in terms. Acid-generation mitigation measures for large masses of earthen waste are expensive so there’s incentive to minimize the mass of waste that must be mitigated at the beginning of a new mine. However, it is much more expensive in the long run to mitigate unanticipated masses of problematic wastes. Dredge spoils Organic-rich, often described as “peaty”, iron sulfide rich sediment. Fine grained. Should be characterized before disturbed. 1. The literature of acid generating dredge spoils stresses that such material should be expected when working in estuaries. Mitigation measures stressed avoidance or placing materials under conditions that promote stability (reducing conditions) Pre-mining sample sources Surface grab and trench samples. Exploration drilling samples (chips and core). Metallurgical testing samples (e.g., pre- and post-processing samples for milling). 1. It’s always good to know what materials are being tested and when. Mining sample sources Ore control sampling during mining. Head and tail samples during milling. 1. Sampling and testing should continue through mining. It should not stop when mining begins. Summary Testing programs result in lots of samples. Predictions based on early testing may change if new wastes are identified as mining proceeds. Predictions based on early testing may change if mineral recovery process change during mining. 1. Characterizing the amount and behavior of mine waste should run parallel to characterizing the amount and grade of the ore body. Data quality for both should be comparable. Acid Generation Potential of Earthen Materials We’re going to start with an overview of acid generation. Keep in mind that acid generation has been and still is the subject of research. As such, there are active discussion groups and a steady stream of reports for any of you who might want to pursue this subject in depth. Why do we care? The Bad: Causes serious water quality problems. Causes serious soil fertility problems. Costly to clean up. Clean ups usually require long-term maintenance. USGS Do we all agree these are bad consequences? Does anyone have others we should list? Why do we care? The Good: Enriches metal ore bodies. Produces iron-rich soils which are fertile. Makes cool crystals. Remember, a “natural” process can’t be all bad, right? What earthen materials display the problem? Coal, base metal, and precious metal mine waste. Iron sulfide-rich estuarine marine sediments. Iron sulfide-rich metamorphic rocks (e.g., slates, phyllites). Iron sulfide-rich sedimentary rocks (e.g., pyritic sandstones). Hydrothermally altered rock. Have I missed anything, does anyone have material they would like to add. What is the primary cause? Iron sulfide mineral oxidation catalyzed by bacteria. Iron sulfide minerals responsible: acid volatile sulfide > marcasite > pyrrhotite > pyrite. Other sulfide minerals: copper, nickel, mercury, etc. sulfides do not oxidize readily in air and water to produce acid. However, ferric iron from iron sulfide oxidation will oxidize them to produce mine waters rich in heavy metals, mercury, arsenic, etc. I figured that you all have seen the usual reactions, and that you all know that acid generation is biologically characterized. So I didn’t reproduce them here but they are all included in the background reports on the web site. The reports also contain a lot of “research” reading for those of you whom want to delve into pyrite oxidation in depth. Oxidation Reactions FeS2(s) + (15/4)O2(aq) + (7/2)H2O => Fe(OH)3(s) +2SO42-(aq) + 4H+(aq) {general} FeS2(s) + (7/2)O2(aq) + H2O => Fe+2(aq) +2SO42-(aq) + 2H+(aq) 4Fe+2(aq) +O2(aq) + 4H+(aq) => 4Fe+3 + 2H2O {bacteria catalyzed ferric iron production} FeS2(s) + (14)Fe+3(aq) + (8)H2O => (15)Fe+2(aq) +(2)SO42-(aq) + 16H+(aq) {pyrite oxidation by ferric iron} But I got a lot of requests to depict the reactions after the first class so here they are. By D. Kirk Nordstrom Bet reactions aside, the schematic convey the process much better as, once ARD gets going, all the reactions occur at the same time. Iron sulfides Well crystallized pyrite from Spain that’s similar in form to the example from a road cut near Carson Hill. The Carson Hill example is Cretaceous (>60 million years old) and is oxidizing slowly. On the other hand, the mixed sulfide sample from Iron Mountain mine is older (Devonian) but is oxidizing rapidly. What is the secondary cause? Acid release from iron sulfate salt dissolution. Rapid - Melanterite, rozenite, szomolnokite, romerite, copiapite, etc. Slow - Alunite-jarosite Dry mine waste may contain iron sulfate salts that are an easily released source of stored acid. The Iron sulfate salts on the iron mountain sulfide hydrolyze in water to produce an acidic effluent rich in metals (Fe, Cu). Iron sulfate salts These are more examples from Iron Mountain Mine. More Iron sulfate salts Rhomboclase (H3O)FeIII(SO4)2·3H2O Coquimbite, FeIII2(SO4)3·9H2O These are more examples from Iron Mountain Mine. For those of you who like chemistry, these are the ferrous and ferric iron salts that form in sequence through iron oxidation and dehydration. Natural Buffers Carbonate Minerals provide rapid buffering. - Calcite > dolomite > magnesite > ankerite. Silicate Minerals provide slow buffering (about 7 orders of magnitude slower than carbonates). - Feldspars, olivine Note that these are not biologically catalyzed reaction, and sulfate mineral armoring is not considered. Acid Generation in the field Copiapite-group minerals growing on pyrite, Iron Mountain, CA Iron sulfate salts on a road cut. The same minerals that form in Iron Mountain mine may sometimes be found in iron sulfide bearing outcrops and road cuts. These minerals indicate that acid generation is occurring. These minerals also wash away easily. Summary: All Iron sulfide minerals generate acid “Sooner” or “Later” “Sooner” causes serious water quality problems because a lot of acid is generated over a short time. Natural neutralization or assimilation cannot keep up. “Sooner” results from: low crystallinity, high surface area, impurities (e.g., arsenic in pyrite), lattice defects, strong oxidizing conditions. “Later” causes no or limited to water quality problems because acid is produced over a time span sufficient for neutralization or assimilation by the environment. “Later” results from: high crystallinity, low surface area, high purity, defect-free lattice, reducing conditions. In a general sense, all iron sulfide generates acid. The trick is to find out if the generation rates will result in a low pH effluent, and if mineral oxidation in general will result in effluents that are problematic from a water quality and human health standpoint.

Hydrogeologist Dr. June Oberdorfer reviews Rise Gold's published groundwater hydrology report for the Idaho-Maryland Mine. She tells us where the modeling is flawed and makes recommendations for what could be done to follow best practices. When asked whether this report would pass muster as a graduate thesis by one of her students, she was gracious of course, but her answer was a definitive no. Dr. Oberdorfer was interviewed on KVMR evening news on October 25, 2021. Listen to her five minute summary of what you'll hear in the webinar starting at 17:35 in this radio recording. Guest speaker Dr. June Oberdorfer is a Hydrogeologist with a broad range of experience with groundwater resource and contamination issues and a professor at San Jose State University. She has advised public interest groups and acted as an expert witness. Her recent research has focused on the interactions between groundwater and surface water in the coastal zone. This talk was given on October 28, 2021 as Dr, Oberdorfer joined a MineWatch virtual community meeting hosted by CEA Foundation and community partners.

Special Guest Speaker and Respiratory Therapist, Pam Heard takes a detailed look at Rise Gold's reports as they relate to air pollutants that put our lungs at risk, including diesel exhaust, radon, silica, and asbestos. From the MineWatch Community Meeting December 2021. FULL TRANSCRIPT OF PAM'S PRESENTATION Air Concerns: Mining vs. Cancer Risks Slide: Airborne Pollutants November was Lung Cancer Awareness Month. It was also the anniversary of our first discussion about air quality here in Nevada County. Now is the perfect opportunity to talk about exposure to airborne pollutants that will be released during mining processes and how those exposures will impact the health of our community. All of the pollutants you see on this slide have the potential to cause respiratory problems, acute and chronic, from both short and long-term exposures. Rise Gold’s Brunswick site is just a half mile southeast of the city limit – so any pollutants that are released will funnel into the Brunswick Basin and the City of Grass Valley. The question is, which pollutants will be released if the Idaho-Maryland Mine reopens? To try to answer that, I took a deep dive into Rise Gold’s technical reports. Tonight, I will share with you what I found and what the potential health impacts could be. What I found was surprising and concerning, especially as it relates to 4 of these pollutants: diesel emissions, radon, silica, and asbestos. These pollutants will be the focus on my presentation tonight. Slide: Health Risks Before we get into the specifics, I’d like to set the stage for WHY we are so concerned. It’s critical to know that Nevada County already has compromised air quality. The EPA has classified Nevada County to “serious” nonattainment for 8- hour ozone levels. California Air Resources Board, CARB has designated Nevada County as a nonattainment area for the state O3 and PM10 standards. The American Lung Association has given Nevada County an F, a failing grade for air quality due to its high ozone and particle pollution levels. In September of this year, the World Health Organization revised their air quality guidelines for the first time in 15 years in recognition of the harmful effects of air pollution on human health. They lowered limits for PM2.5, PM10, ozone, nitrogen dioxide, sulfur dioxide and carbon monoxide. Nevada County also has a vulnerable population. According to the 2020 census, in NC, nearly a third, 28.6% of our population is 65 years or older, compared to the statewide rate of 14.3%. So, we have an older demographic here. The 2019 Health Assessment for NC revealed that our mortality rate for Chronic Lung Disease is twice that of the statewide rate (69 deaths/100,000 people for the county vs 35 deaths/100,000 for the state). Our Heart Disease Mortality rate is 1.5 times higher than the statewide rate. The bottom line is that we have a vulnerable population with chronic conditions that will be exacerbated by exposure to these pollutants. Slide: Diesel Emissions The first pollutant encountered will be diesel emissions, including both exhaust and particulate matter, or DPM. The impact of these emissions on public health is serious. Approximately 70% of all airborne cancer risk in California is associated with diesel particulate matter. Diesel particulate matter has other public health effects as well. Because it is part of PM2.5, DPM contributes to the same non cancer effects as PM2.5 exposure. These effects include premature death, ER visits and hospitalizations for exacerbated heart and lung disease, asthma and it may affect the immune system increasing the risk of allergies and susceptibility to infectious diseases. Diesel emissions will be constant throughout the life of the project starting with the remedial action on the Centennial site, followed by the construction phase of the Brunswick site, then delivery and placement of engineered fill on the Centennial site, and ongoing operations at Brunswick site. This project will require heavy duty diesel engines for earth moving equipment along with trucks for the delivery and dispersal of materials: bulldozers, graders, compactors, generators, haul trucks, delivery trucks with explosives, water, diesel fuel and cement, fuel storage tanks, explosives, gold concentrate and aggregate removal trucks. Now you should know that, the Rise report states that all diesel equipment “owned” by them would be equipped with Tier 4 Final engines, which is the current emissions standard for new trucks, requiring engine manufacturers to reduce particulate matter and oxides of nitrogen (NOx) by 50-96% as compared to Tier 3 engines. But if you look closely at the plans, you can easily see there are several loopholes. For instance, another section of the report states that “If these engines are not ‘commercially available’, then they will use CARB certified Tier 3 engines with the most effective Diesel Emission Control Strategies available for the engine type. “Commercially available” will take into consideration factors such as critical path timing of construction and geographic proximity of the equipment location to the project site. What isn't covered is the question about what the “Tier” status will be for leased equipment and outside vendors. These trucks will travel the same roads as our residents and school buses. They’ll be bringing explosives, fuel oil and cement to the mine. In other words, there are no guarantees that Tier 4 engines will be used exclusively… Slide: Diesel Exhaust Contributes to Formation of Ozone and Acid Rain These emissions break down into two parts: gases (released through exhaust), and particulate matter. The gas phase contains mostly carbon dioxide, carbon monoxide, nitrogen oxides (NO, NO2), sulfur oxides, and hydrocarbons, including polycyclic aromatic hydrocarbons. Some of these gases react in the atmosphere with UV light to form ozone and acid rain. These pollutants will have devastating effects on both our terrestrial and aquatic environments- which are already stressed from drought and climate change. Slide: Diesel Particulate Composition The emissions also create diesel particulate matter, or DPM, which is also known as soot. Soot is made up of particles such as carbon, organic compounds (including PAHs) and traces of metallic compounds. It contains more than 40 known organic cancer-causing compounds such as benzene and formaldehyde which coat the soot particle. More than 90% of DPM is <1 micron in diameter. Due to its small size, it is inhaled deeply into the lungs where the lung is most susceptible to injury Slide: Particulate Matter Deposition in the Lungs Let’s take a close look at what’s really happening to our lungs. This is a diagram of the respiratory system. It’s like an upside tree starting with the trachea (trunk) which branches into the bronchi, then smaller bronchioles and down to the alveoli. These air sacs are where respiration, or gas exchange, takes place with the bloodstream similar to leaves with the environment. Our bodies take in oxygen and release carbon dioxide through the alveoli while trees respire by taking in carbon dioxide and releasing oxygen to the environment. As you can see, the smaller the particle, the deeper it is able to penetrate into the lungs and cause damage. Slide: Radon Diesel emissions aren’t the only high-level pollutants that affect respiratory health… We also have to consider radon, a radioactive gas that increases the risk of lung cancer. In this section, I’ll explain what it is, then share what I found about it when reviewing Rise Gold’s reports. Slide: Understanding Radon According to WHO, “Radon is a radioactive gas that emanates from rocks and soil and tends to concentrate in enclosed spaces like underground mines and homes” You cannot see it, smell it or taste it. It is generated from the decay of radium. Radium is a decay product of uranium and thorium which are naturally occurring in rocks and soils. Because it is a gas, it moves freely in the air spaces between rocks and in soils. And because it is heavy (7.5 X heavier than air), it accumulates in low places like mines, basements, and the ground floor of homes. Factors that can affect radon levels include local geology, construction materials and how the home was built. Levels can vary from home to home, it’s very unpredictable. What’s the risk? After smoking, radon is the second leading cause of lung cancer in the United States For non-smokers, radon is the leading cause of lung cancer The US EPA estimates that radon causes about 21,000 lung cancer deaths each year. There is a linear relationship between radon and lung cancer: As radon levels increase, the risk of lung cancer increases Slide: California Radon Zones Let’s start by looking at our current radon levels. The national average of radon is 1.3 pCi/L California average is 0.85 pCi/L Now look at Nevada County, our average is 3.1 pCi/L What do these numbers mean? Well, you should know that the EPA action level is 4.0 pCi/L. In other words, you should already be taking action today to lower your exposure. Slide: Nevada County Radon Levels · Now, we’ll look more closely at our County’s levels. · The California Department of Public Health analyzed results of radon tests last updated in 2017. Here in Grass Valley, tests on 315 homes revealed that 66 homes had levels ≥4.0 pCi/L (21% of the total). The highest level recorded was 29.5 pCi/L. · The Idaho Maryland Mine project is located in this same zip code, 95945. Slide: How Radon Enters A Home So just how does radon enter your home? Radon seeps into your home from several sources: fractured bedrock, groundwater, soil and well water. Slide: Questions about Radon · So this is a critical question: How will the reopening of the IMM affect radon levels in Grass Valley and in our homes? How could radon impact our groundwater and wells? Rise Gold did test groundwater from some drains and the New Brunswick shaft for radon and emitting particles, including measurements known as Ra226 and Ra228. All published test results were below the maximum level, measuring under 5pCi/L for both types of radium combined. But in 2006, the state of California adopted new Public Health Goals for Ra226 and Ra228. The new goal for Ra226 is 0.05 pCi/L and the new goal for Ra228 is 0.019 pCi/L. The combined value of 0.069 is below the current detection level [speaker switch – video edited to deliver missing information] but these new goals demonstrate that the state recognizes the health risk for lung cancer from radionuclides exposure. Now looking at the groundwater test results under this criterion, all Ra226 and Ra228 results meet or exceed these PHGs. And here’s another question: What will be the effects on miners and surface workers when this radioactive gas is released during constant dewatering and mine ventilation? [speaker switch] Over the last decade, several studies have concluded that elevated radon concentrations could be a sign of an imminent earthquake. Radon is released from cavities and cracks in the rocks and soil due to “a slight compression of pore volume that causes gas to flow out of the soil”. 1900 pounds of explosives will be detonated every day during mining! Will the continuous explosives use and tunnel excavations lead to increased rock fractures and fissures thereby increasing radon levels in our community? Slide: Recommendations Here are my recommendation on radon… Nevada County should have an action plan that will… 1. Obtain baseline radon level in homes and businesses 2. Maintain ongoing monitoring programs in the mine and all structures in the community 3. Mitigate radon levels as necessary Slide: Toxic Air Contaminants Radon isn’t the only thing from our local geology that may prove hazardous to our health. Silica and asbestos will be released to the environment from all phases of mining: blasting, excavating, skipping, crushing, milling and transporting to various sites. · Both of these materials belong to the category of toxic air contaminants A substance is considered toxic if it has the potential to cause adverse health effects in humans, including increasing the risk of cancer upon exposure, or acute (short-term) and/or chronic (long-term) noncancer effects. A toxic substance released into the air is considered a TAC. To be clear, Rise Gold claims that measures will be taken to reduce the release of these contaminants, but a “reduction” in the release of toxic air contaminants is not the same thing as no release at all. Slide: Rise Gold’s Report This is the only technical report found on the Rise Gold website (www.risegoldcorp.com) for their investors. It’s really a great report, only 179 pages in length, that details the history, gold production and most importantly, the geology of our region. Within it, there are 115 mentions of quartz and over 70 mentions of serpentinite. Why are there so many mentions of these materials? Because that’s where most of the gold is found…in quartz veins along the contact points with serpentinite. These are the buzzwords that excite investors. Rise will be excavating tons of quartz and tons of serpentinite. And you guessed it, these are the rocks that contain silica and asbestos. So, let’s look at quartz first Slide: Silica Exposure Risks Quartz contains Respirable Crystalline Silica (RCS), which is defined as a particle with an aerodynamic diameter size of 4 microns, so it is able to penetrate deep into the lungs. The risks from exposure to crystalline silica are well known: lung cancer, silicosis, emphysema, chronic bronchitis, respiratory failure, premature death. It has been implicated in bladder and kidney disease along with some autoimmune disorders Research indicates that “Freshly ground quartz has been found to be much more cytotoxic than aged quartz because grinding or fracturing quartz particles is thought to break the silicon-oxygen bonds, generating silicon and silicon oxide radicals on the surface of the particles. (Vallyathan et al. 1988,1995: Vallyathan, 1994, Shoemaker et al, 1995)”. Slide: Proportions Matter - Especially in Mining So, just how much silica will we be exposed to? Our geology is igneous in origin with later metamorphosis and alteration. One way to classify igneous rock is according to their silica content: This graphic displays the different categories of igneous rock. All of these rock types are present in our geology. Proportions matter… especially in mining. FELSIC has a silica content greater than 65% by weight such as quartz and plagioclase feldspars FELSIC TO INTERMEDIATE has greater than 20% quartz by volume and between 65-90% plagioclase feldspar such as granodiorite INTERMEDIATE has a silica content between 55-65% by weight such as andesite (52-63%) and diorite MAFIC has a silica content between 45-55% by weight such as gabbro (48%) and diabase ULTRAMAFIC has a silica content less than 45% such as serpentinite What’s most remarkable in Rise Gold’s report is the assumption that 98% of the rock mined will be meta-andesite rock with a silica content of 60%. This percentage was obtained from the geology 101 textbook definition of andesite rock as being between 52-63% silica. Just how accurate is this number? First of all, this is meta-andesite rock not just andesite.…it has undergone metamorphosis becoming altered in composition. In the book, The Gold Quartz Veins of Grass Valley, referenced in the Technical Report of Idaho-Maryland Project Johnston (1940) stated: “The degree of metamorphism may vary in this unit, such that parts of it have been referred to as amphibolite schist, porphyrite, diabase, and quartz porphyrite.” The laboratory that Rise used for all metals analyses, ACZ Laboratories, is certified to perform both silica and silicon dioxide tests yet not a single sample was analyzed for this parameter. Why is this important? To quote Sara Seager, a planetary scientist: “When you are working on such enormous scales, the smallest mistake can be amplified into massive miscalculations” (Sara Seager, planetary scientist/astronomer, The Smallest Lights in the Universe) For example, mining 1000 tons ore/day at 60% silica would yield 600 tons of silica (1,200,000 pounds) But mining 1000 tons ore/day at 65% silica would yield 650 tons of silica- an additional 100,000 pounds (1,300,000 pounds) And this difference would be compounded every day. Slide: Sample Population Metals The thing we need to keep in mind is that Rise selected the sample drill locations, selected the samples to be tested and selected the tests to be performed on those samples. We don’t have the drill logs but let’s look at what information we are given from those drill cores… · From 2017-2019, Rise drilled 19 core samples during their exploratory phase for a total of 67,500 linear feet · Metals analyses were performed on 47 crushed core samples · These 47 samples were selected from just 5 of those cores (26% of the total): I-18-11(1), B-18-02(1), I-18-10(3 200), I-18-12(2, possibly mislabeled) and I-19-13(40) core · The procedure went like this: for every 90-100 feet drilled, a 10 ft sample was obtained for testing. A one gram sample from each 10 ft segment was then analyzed for metals content. The total footage for all segments combined equals 456.5 ft. (0.68% of the 67,500 total drilled) · 40 Samples (85% of the overall total) were selected from a single core, I-19-13 here shown in red. This core began at 167 ft bgs to a final depth of 4774.6 ft (4607.6 ft). · Sampling was consistent from 167 ft to 3227 ft. Then large segments (of 350 to 450 ft) started missing: 365 ft between 3227-3583 depth, another 343.3 ft between 3969.7-4313 depth and lastly 444.9 ft between 4323.0-4767.9 depth (1144.2 ft). · These missing segments add up to over 1100 ft or 25% that is absent from that core. · Why are these segments unaccounted for? Are they quartz or serpentinite? What else are we not being told? Slide: Rise Gold Projections For those who really like to understand how it works, these charts lay it out. · Rise will mine 500 tons of barren rock per day and 1000 tons of ore rock per day. · The rock will be crushed to a 6 inch size in the jaw crusher, then conveyed to the silo. · The ore rock will then be sent to the processing center to be milled in multiple stages, ground down to a small size that will enable them to separate the gold out by gravity flotation. · After removal of the gold, this material is known as “tailings” or sand tailings. 500 tons will be used in cement paste backfill while the remaining 500 tons will be mixed with barren rock to become “engineered fill”. · The pie chart shows the percentage of rock types that will be mined each day…there is no mention of quartz. · The bottom chart shows the breakdown in size for the sand tailings. · The engineering firm, NV5, stated in the Centennial Geotechnical Report that: “We understand that the sand tailings will likely have a gradation similar to the historical gradation presented in the table below, and will typically have a large proportion of quartz.” Hmmm · The quartz sand has been graded according to size and percentage of total for each size. Twelve percent will be less than 44 microns in size. The human eye can only see down to 50 microns, so these particles will be invisible. Just what amount of this 12% is less than 10 microns, of a respirable size, is unknown. · The engineered fill composed of sand tailings and barren rock will be loaded and transported to Centennial site for placement, grading and compaction. · There will be 6 fans in the ore processing facility exhausting 1 gram/second at a flow rate of over 21,000 ft3/min 24 hours per day. · What are these fans exhausting to the environment and in what quantities? Slide: Hours of Operation A close look at this proposed schedule gives us a good sense of the extent of the risk. Mining and ore processing will occur 24 hrs/day for 7 days a week. Hauling of engineered fill will occur 16 hrs/day for 7 days a week · Placement, grading and compaction of the engineered fill will occur 8 hrs/day for 5 days a week. · There will be 50-100 haul truck trips per day with each load weighing 20 tons. (50=3 trips/hr, 100=6 trips/hr) · Since placement, grading and compaction only occurs 8 hrs/day, 5 days a week, there will be significant stockpiles of this material building up before 7 am and after 3:30 pm and throughout the weekends. · Rise maintains that there will be negligible fugitive silica dust because they will sprinkle the material with water twice a day, or cover it with a tarp. We are very concerned about fugitive dust. Are there any protections for our community? Well, there are some regulatory standards for workers exposed to silica · The OSHA, Occupational Safety and Health, regulatory standard for permissible exposure level (PEL) for RCS is 50 ug/m3 TWA over an 8 hour day · The MSHA, Mine Safety and Health Administration, regulatory standard for permissible exposure level (PEL) is 100 ug/m3 TWA over an 8 hour day. This standard was adopted in 1969 and is double the current OSHA standard. · BUT OUR COMMUNITY WILL BE EXPOSED 24 HOURS A DAY, 365 DAYS PER YEAR, forevermore from multiple sources to this toxic air contaminant In 2005, California adopted a “safe limit” for non-occupational exposure. This chronic reference exposure level is 3 ug/m3 for ambient respirable crystalline silica. However, there is no enforcement of this statute and the exposure level falls below the NIOSH 7500 test detection level of 5 ug/m3. (In other words, the accepted method for sampling and testing is not sensitive enough to reach the state limit of 3 ug/m3) Note: A chronic reference exposure level is a concentration, at or below which no adverse health effects are anticipated in the general human population from long-term (up to a lifetime) exposure. OEHHA, 2000 Slide: Asbestos And still the community has yet another TAC to be concerned about …asbestos According to the World Health Organization, “No level of asbestos exposure is safe. Excess rates of cancer are found at all asbestos fiber concentrations. ” WHO Exposure is linked to several diseases: cancer of the lung, larynx, and ovaries and mesothelioma (cancer of the pleura and peritoneal linings). Exposure is also responsible for asbestosis, COPD, and pleural effusions. It generally has the worst effects when a person is exposed to an intense concentration of it or they are exposed on a regular basis over a long period of time. Chrysotile, serpentine asbestos, is the type found in IMM An asbestos fiber is defined as a particle longer than or equal to 5 microns with a length to width ratio of greater than or equal to 3:1 Thus, the fibers are invisible, readily airborne and inhaled deep into the lungs. Slide: Mining Will Occur Along Faults Associated with Serpentinite · Here is a geologic map from the Hydrology report · The black dotted line represents the mineral rights boundary with different rock types denoted by color · The purple area is serpentinite, which can contain asbestos · The red dotted lines trace the Morehouse, Idaho and 6-3 faults through the serpentinite deposit. Slide: Rise Gold’s Asbestos Sampling Locations Again in this map, the gray area represents the mineral rights boundary with serpentinite traced in purple. Green is porphyrite (meta-andesite), orange is diorite, coral is granodiorite with meta-sedimentary deposits shown in blue Slide: Inconsistencies Raise Questions And here is an expanded view of the previous map showing the drill core locations where asbestos sampling was done… · 42 samples were analyzed: 2 blanks, 2 tailings from Centennial site and 40 core samples · Core samples were from 6 different cores out of 19 total: 9 samples from I-18-11, 1 from I-18-12? (labeled I-19-12 on map), 9 from I-19-13, 7 from I-19-13A, 8 from I-19-14, and 4 from I-19-14A · Asbestos was encountered in serpentinite at final drill depth for 3 cores I-18-11, I-19-13, I-19-13A where drilling stopped. So, the thickness and width of the serpentinite layers are unknown. · Two distinct methods of analysis with different sample prep, instrumentation, magnification and counting methods were used. Forty samples were analyzed by Polarizing Light Microscopy while the remaining two samples were analyzed by transmission electron microscopy. The results by TEM were 3.1% for one sample and 2.0% for another. PLM had two detections at 0.75% and 2.5%. · Overall, asbestos was detected in four samples. For quality control, duplicate analyses were performed: this is when you analyze two samples from the same location. The results were <0.25% PLM(Y962847) and 2.0% TEM (Y962981) e.g. TEM used a magnification of 15,000X vs PLM at 50-1000X, usually 400X. Higher resolving power enables TEM microscopists to distinguish and identify finer particle and fibers not seen with the use of PLM The differences between these sample duplicate results could be due to different analysis methods, lack of sample homogeneity (one sample was received as pulp) or both. Regardless, there is a very big difference between no detection of fibers and 2.0% by weight results. Slide: No Guidelines for Specimin Collection - Stats Not Representatitive In fact… Regarding asbestos sampling, the California Geologic Survey states: “Because no exact guidelines exist for determining the number of specimens that should be collected, any statistics that are computed using the quantitative results from analysis of these specimens cannot be interpreted to be “representative” of the entire NOA population. Guidelines for Geologic Investigation of Naturally Occurring Asbestos in California, California Geologic Survey For example, suppose the analytical results for three samples are 0%, 5% and 10% asbestos. The mean, or average, of these three values is 5%, but the variability is considerable. Simply reporting the average value, 5%, says nothing about this variability. It is not correct to say that the average NOA concentration for the entire site is 5% because it is not known, nor can it be known, that the three specimens are representative of the entire population.” Rise did use a “weighted” average for the 12 serpentinite samples used for asbestos weight % determination. Four of those samples, 25% of the total, contained asbestos ranging from 0.75-3.1% by weight. The core lengths ranged from 3.6” to 13”, with over half of the samples at <5” length. Based on 12 samples, Rise calculated the content of asbestos as 1.08% by weight and the asbestos emissions are based on the 1% of serpentinite to be mined each day. Is this an accurate percentage based on the limited sampling done, testing limitations and the asbestos variability in serpentinite deposits? Slide: So much Serpentinite in the Mining Area Here is a closer look at some of the deposits that are proposed or targeted sites for mining… · The diagram on the left is “The Rose Garden”. According to the Technical Report on the Idaho-Maryland Project this deposit “is hosted solely in serpentinite. Serpentinite within the Idaho fault zone, east towards the 6-3 Fault and west of the 3 Vein may host mineralization similar to the Rose Garden.” · On the right is a view of the Idaho #3 Vein System. You can trace the gold vein along the serpentinite contact, here in purple Slide: More Serpentinite And here are portions of the Idaho #1 and #2 Veins adjacent to the Morehouse fault… again with the gold vein tracing alongside the serpentinite contact Rise states that only 1% of daily mined material will be serpentinite. However, as you can see from the previous Rise Gold maps, gold mineralization has a strong association with serpentinite Rise plans for the additional serpentinite material (besides the content taken to the Centennial site) to be placed in a separate compartment of the concrete silo. It will also be used to backfill stopes (empty tunnels). Rise claims that 90% of asbestos fibers will be captured by filters on the ventilation system, water curtains, or other methods. The remaining 10% will be exhausted to the ambient environment. For reference, the main ventilation fan exhausts to the ambient environment at 200,000 ft3/minute from a height of 165 ft. In the Health Risk Assessment section of the Air Quality Report is the following statement: “The average asbestos content of the total ore is of primary concern, rather than the speculative potential of blasting particularly asbestos rich rock, since asbestos does not have established acute noncancer effects (OEHHA).” In other words, Rise will not have to account for fibers released during blasting of asbestos rich rock simply because there are no immediate proven cancer health effects from acute exposure…what a nice loophole This statement may be true for the miners but there will be safeguards in place to limit their exposure: respirators, PPE, working a short shift and being monitored to ensure they don’t exceed Permissible Exposure Levels according to regulations. At the end of their shift, they will decontaminate themselves and go home. Rise claims that by protecting their employees, they will….by default …be protecting the community. But there is a fatal flaw to their logic in this argument. The primary way that Rise will protect their workers is by ventilating the mine. But ventilating the mine to the ambient air is the primary way our community will be contaminated with asbestos. Once these fibers are in the environment, they persist forever and the community exposure will be every minute of every day. Just where can we expect these fibers to go once airborne? Slide: Particles Travel Easily - Grass Valley is at Risk We’re almost done now, but before we conclude, let’s consider how far these toxic contaminants might travel in the air. We know that both respirable crystalline silica and asbestos emissions are microscopic, less than 5 microns in size. But any particles less than 10 microns can be inhaled into the lungs · Here are some charts based on Stoke’s Law showing particle distances travelled according to wind speed and particle size. · Keep in mind that the Brunswick site is <2 miles from downtown Grass Valley · The average hourly wind speed in Grass Valley is 5.7 mph WeatherSpark · Here is one last statement from the Air Quality Report: “Based on the PM10 emissions estimated and the lab sample results, emissions of asbestos, silica, and heavy metals were estimated for purposes of this HRA (Health Risk Assessment).” · The consultant is using estimations of estimates to predict the future health of our community. It may take 10-20 years for diseases to appear from radon, silica and asbestos exposure. But the effects will be devastating. · A bigger question is…. How will we monitor these airborne pollutants? PM10 studies will only indicate quantity, they will not distinguish the amounts of the individual components AND… Nevada County is already in nonattainment status for PM10. · The fugitive dust mitigation plans are not adequate to prevent the release of airborne microscopic silica and asbestos into our environment. Slide: ALL THE GOLD IN THE WORDS CAN’T BUY GOOD HEALTH: Diesel, radon, silica and asbestos…OH MY! Rise has said that each of these pollutants will have a “less than significant effect on our community. They maintain that they will be able to mitigate or diminish the effects with strategies such as using Tier 4 diesel engines, filters on the mine ventilation fan, and wetting down the “dust”. How can spewing pollutants from thousands of gallons of diesel fuel daily, trucking rock and sand tailings laden with asbestos and silica around town 16 hours per day, building two sites with this material, plus the daily operations of the mine for 80 years have a “less than significant effect” on our community? I am concerned that the rise operation will constitute a public health and an environmental health crisis. All the gold in the world can’t buy good health. Please join with CEA to Stop the Idaho Maryland Mine!

Watch CEA Foundation and coalition partners as they present a virtual community meeting for people interested in stopping the proposed Idaho-Maryland Mine in Grass Valley, CA. Guest speaker, respiratory therapist Pam Heard, does a special presentation on air quality concerns. You can skip to the topics that interest you the most by jumping to the start time for each section. Overall impacts of the mine (7:08) Anticipated timeline for the review process (21:55) Air quality impacts featuring Respiratory Therapist Pam Heard (31:00) Live questions (43:45) CEA had experts online to answer questions throughout. Together, we can STOP THE MINE!

Watch CEA Foundation and coalition partners as they present a virtual community meeting for people interested in stopping the proposed Idaho-Maryland Mine. Guest speaker, respiratory therapist Pam Heard, does a special presentation on air quality concerns. In this session, you'll learn about: - What's next in the approval process - Why our community can't afford to make air quality worse - Recommended talking points CEA had experts online to answer questions throughout. Together, we can STOP THE MINE!

Watch CEA Foundation and coalition partners hosting a virtual community meeting to share news on the proposed Idaho-Maryland Mine. Meeting focus: Impact on Private Wells Special guest speakers: Sol Henson, San Juan Ridge Taxpayers Association, and Gary Pierazzi, East Bennett Road Resident. Agenda - The potential impact and risk to neighborhood wells from the Idaho-Maryland Mine - Siskon Gold Corporation's mine on the San Juan Ridge that was forced to shut down in the 1990s and lessons that can be applied today - A new Campaign website and outreach tools - Q&A

Special Guest Speaker and Respiratory Therapist, Pam Heard takes a detailed look at Rise Gold's reports as they relate to air pollutants that put our lungs at risk, including diesel exhaust, radon, silica, and asbestos. This virtual community meeting was hosted by CEA Foundation and community partners on December 16, 2021. 6:15 Project Update The meeting begins with CEA Foundation president Ralph Silberstein giving a progress report on the effort to oppose the mine. He provides an update on the Centennial project, tells us the Nevada County Supervisors approved the costs and consultant selection for an Economic Study, and tells us the Draft Environmental Impact Report is now guesstimated for arrival in late January 2022. 11:25 Air Concerns: Mining vs Cancer Risk Respiratory Therapist, Pam Heard talks about the dangers of diesel exhaust, radon, silica, and asbestos, educates us on how each of them play a role in the rocks and geology in our area, and reviews the assumptions and inconsistencies found in Rise Gold's reports. See the full transcript below. 53:45 - Questions and Answers. Part 1 1:09:45 - Questions and Answers. Part 2 Pam Heard answers a number of questions from the audience. 1:04:30 - Take Action CEA Foundations' Christy Hubbard and Laurie Oberholzer talk about what the community can do to take action, including letter writing, sharing on social media, canvassing in the new year, and making a tax-deductible donation in 2021. FULL TRANSCRIPT OF PAM HEARD'S PRESENTATION Air Concerns: Mining vs. Cancer Risks Slide: Airborne Pollutants November was Lung Cancer Awareness Month. It was also the anniversary of our first discussion about air quality here in Nevada County. Now is the perfect opportunity to talk about exposure to airborne pollutants that will be released during mining processes and how those exposures will impact the health of our community. All of the pollutants you see on this slide have the potential to cause respiratory problems, acute and chronic, from both short and long-term exposures. Rise Gold’s Brunswick site is just a half mile southeast of the city limit – so any pollutants that are released will funnel into the Brunswick Basin and the City of Grass Valley. The question is, which pollutants will be released if the Idaho-Maryland Mine reopens? To try to answer that, I took a deep dive into Rise Gold’s technical reports. Tonight, I will share with you what I found and what the potential health impacts could be. What I found was surprising and concerning, especially as it relates to 4 of these pollutants: diesel emissions, radon, silica, and asbestos. These pollutants will be the focus on my presentation tonight. Slide: Health Risks Before we get into the specifics, I’d like to set the stage for WHY we are so concerned. It’s critical to know that Nevada County already has compromised air quality. The EPA has classified Nevada County to “serious” nonattainment for 8- hour ozone levels. California Air Resources Board, CARB has designated Nevada County as a nonattainment area for the state O3 and PM10 standards. The American Lung Association has given Nevada County an F, a failing grade for air quality due to its high ozone and particle pollution levels. In September of this year, the World Health Organization revised their air quality guidelines for the first time in 15 years in recognition of the harmful effects of air pollution on human health. They lowered limits for PM2.5, PM10, ozone, nitrogen dioxide, sulfur dioxide and carbon monoxide. Nevada County also has a vulnerable population. According to the 2020 census, in NC, nearly a third, 28.6% of our population is 65 years or older, compared to the statewide rate of 14.3%. So, we have an older demographic here. The 2019 Health Assessment for NC revealed that our mortality rate for Chronic Lung Disease is twice that of the statewide rate (69 deaths/100,000 people for the county vs 35 deaths/100,000 for the state). Our Heart Disease Mortality rate is 1.5 times higher than the statewide rate. The bottom line is that we have a vulnerable population with chronic conditions that will be exacerbated by exposure to these pollutants. Slide: Diesel Emissions The first pollutant encountered will be diesel emissions, including both exhaust and particulate matter, or DPM. The impact of these emissions on public health is serious. Approximately 70% of all airborne cancer risk in California is associated with diesel particulate matter. Diesel particulate matter has other public health effects as well. Because it is part of PM2.5, DPM contributes to the same non cancer effects as PM2.5 exposure. These effects include premature death, ER visits and hospitalizations for exacerbated heart and lung disease, asthma and it may affect the immune system increasing the risk of allergies and susceptibility to infectious diseases. Diesel emissions will be constant throughout the life of the project starting with the remedial action on the Centennial site, followed by the construction phase of the Brunswick site, then delivery and placement of engineered fill on the Centennial site, and ongoing operations at Brunswick site. This project will require heavy duty diesel engines for earth moving equipment along with trucks for the delivery and dispersal of materials: bulldozers, graders, compactors, generators, haul trucks, delivery trucks with explosives, water, diesel fuel and cement, fuel storage tanks, explosives, gold concentrate and aggregate removal trucks. Now you should know that, the Rise report states that all diesel equipment “owned” by them would be equipped with Tier 4 Final engines, which is the current emissions standard for new trucks, requiring engine manufacturers to reduce particulate matter and oxides of nitrogen (NOx) by 50-96% as compared to Tier 3 engines. But if you look closely at the plans, you can easily see there are several loopholes. For instance, another section of the report states that “If these engines are not ‘commercially available’, then they will use CARB certified Tier 3 engines with the most effective Diesel Emission Control Strategies available for the engine type. “Commercially available” will take into consideration factors such as critical path timing of construction and geographic proximity of the equipment location to the project site. What isn't covered is the question about what the “Tier” status will be for leased equipment and outside vendors. These trucks will travel the same roads as our residents and school buses. They’ll be bringing explosives, fuel oil and cement to the mine. In other words, there are no guarantees that Tier 4 engines will be used exclusively… Slide: Diesel Exhaust Contributes to Formation of Ozone and Acid Rain These emissions break down into two parts: gases (released through exhaust), and particulate matter. The gas phase contains mostly carbon dioxide, carbon monoxide, nitrogen oxides (NO, NO2), sulfur oxides, and hydrocarbons, including polycyclic aromatic hydrocarbons. Some of these gases react in the atmosphere with UV light to form ozone and acid rain. These pollutants will have devastating effects on both our terrestrial and aquatic environments- which are already stressed from drought and climate change. Slide: Diesel Particulate Composition The emissions also create diesel particulate matter, or DPM, which is also known as soot. Soot is made up of particles such as carbon, organic compounds (including PAHs) and traces of metallic compounds. It contains more than 40 known organic cancer-causing compounds such as benzene and formaldehyde which coat the soot particle. More than 90% of DPM is <1 micron in diameter. Due to its small size, it is inhaled deeply into the lungs where the lung is most susceptible to injury Slide: Particulate Matter Deposition in the Lungs Let’s take a close look at what’s really happening to our lungs. This is a diagram of the respiratory system. It’s like an upside tree starting with the trachea (trunk) which branches into the bronchi, then smaller bronchioles and down to the alveoli. These air sacs are where respiration, or gas exchange, takes place with the bloodstream similar to leaves with the environment. Our bodies take in oxygen and release carbon dioxide through the alveoli while trees respire by taking in carbon dioxide and releasing oxygen to the environment. As you can see, the smaller the particle, the deeper it is able to penetrate into the lungs and cause damage. Slide: Radon Diesel emissions aren’t the only high-level pollutants that affect respiratory health… We also have to consider radon, a radioactive gas that increases the risk of lung cancer. In this section, I’ll explain what it is, then share what I found about it when reviewing Rise Gold’s reports. Slide: Understanding Radon According to WHO, “Radon is a radioactive gas that emanates from rocks and soil and tends to concentrate in enclosed spaces like underground mines and homes”. You cannot see it, smell it or taste it. It is generated from the decay of radium. Radium is a decay product of uranium and thorium which are naturally occurring in rocks and soils. Because it is a gas, it moves freely in the air spaces between rocks and in soils. And because it is heavy (7.5 X heavier than air), it accumulates in low places like mines, basements, and the ground floor of homes. Factors that can affect radon levels include local geology, construction materials and how the home was built. Levels can vary from home to home, it’s very unpredictable. What’s the risk? After smoking, radon is the second leading cause of lung cancer in the United States For non-smokers, radon is the leading cause of lung cancer The US EPA estimates that radon causes about 21,000 lung cancer deaths each year. There is a linear relationship between radon and lung cancer: As radon levels increase, the risk of lung cancer increases Slide: California Radon Zones Let’s start by looking at our current radon levels. The national average of radon is 1.3 pCi/L California average is 0.85 pCi/L Now look at Nevada County, our average is 3.1 pCi/L What do these numbers mean? Well, you should know that the EPA action level is 4.0 pCi/L. In other words, you should already be taking action today to lower your exposure. Slide: Nevada County Radon Levels · Now, we’ll look more closely at our County’s levels. · The California Department of Public Health analyzed results of radon tests last updated in 2017. Here in Grass Valley, tests on 315 homes revealed that 66 homes had levels ≥4.0 pCi/L (21% of the total). The highest level recorded was 29.5 pCi/L. · The Idaho Maryland Mine project is located in this same zip code, 95945. Slide: How Radon Enters A Home So just how does radon enter your home? Radon seeps into your home from several sources: fractured bedrock, groundwater, soil and well water. Slide: Questions about Radon · So this is a critical question: How will the reopening of the IMM affect radon levels in Grass Valley and in our homes? How could radon impact our groundwater and wells? Rise Gold did test groundwater from some drains and the New Brunswick shaft for radon and emitting particles, including measurements known as Ra226 and Ra228. All published test results were below the maximum level, measuring under 5pCi/L for both types of radium combined. But in 2006, the state of California adopted new Public Health Goals for Ra226 and Ra228. The new goal for Ra226 is 0.05 pCi/L and the new goal for Ra228 is 0.019 pCi/L. The combined value of 0.069 is below the current detection level [speaker switch – video edited to deliver missing information] but these new goals demonstrate that the state recognizes the health risk for lung cancer from radionuclides exposure. Now looking at the groundwater test results under this criterion, all Ra226 and Ra228 results meet or exceed these PHGs. And here’s another question: What will be the effects on miners and surface workers when this radioactive gas is released during constant dewatering and mine ventilation? [speaker switch] Over the last decade, several studies have concluded that elevated radon concentrations could be a sign of an imminent earthquake. Radon is released from cavities and cracks in the rocks and soil due to “a slight compression of pore volume that causes gas to flow out of the soil”. 1900 pounds of explosives will be detonated every day during mining! Will the continuous explosives use and tunnel excavations lead to increased rock fractures and fissures thereby increasing radon levels in our community? Slide: Recommendations Here are my recommendation on radon… Nevada County should have an action plan that will… 1. Obtain baseline radon level in homes and businesses 2. Maintain ongoing monitoring programs in the mine and all structures in the community 3. Mitigate radon levels as necessary Slide: Toxic Air Contaminants Radon isn’t the only thing from our local geology that may prove hazardous to our health. Silica and asbestos will be released to the environment from all phases of mining: blasting, excavating, skipping, crushing, milling and transporting to various sites. · Both of these materials belong to the category of toxic air contaminants A substance is considered toxic if it has the potential to cause adverse health effects in humans, including increasing the risk of cancer upon exposure, or acute (short-term) and/or chronic (long-term) noncancer effects. A toxic substance released into the air is considered a TAC. To be clear, Rise Gold claims that measures will be taken to reduce the release of these contaminants, but a “reduction” in the release of toxic air contaminants is not the same thing as no release at all. Slide: Rise Gold’s Report This is the only technical report found on the Rise Gold website (www.risegoldcorp.com) for their investors. It’s really a great report, only 179 pages in length, that details the history, gold production and most importantly, the geology of our region. Within it, there are 115 mentions of quartz and over 70 mentions of serpentinite. Why are there so many mentions of these materials? Because that’s where most of the gold is found…in quartz veins along the contact points with serpentinite. These are the buzzwords that excite investors. Rise will be excavating tons of quartz and tons of serpentinite. And you guessed it, these are the rocks that contain silica and asbestos. So, let’s look at quartz first Slide: Silica Exposure Risks Quartz contains Respirable Crystalline Silica (RCS), which is defined as a particle with an aerodynamic diameter size of 4 microns, so it is able to penetrate deep into the lungs. The risks from exposure to crystalline silica are well known: lung cancer, silicosis, emphysema, chronic bronchitis, respiratory failure, premature death. It has been implicated in bladder and kidney disease along with some autoimmune disorders Research indicates that “Freshly ground quartz has been found to be much more cytotoxic than aged quartz because grinding or fracturing quartz particles is thought to break the silicon-oxygen bonds, generating silicon and silicon oxide radicals on the surface of the particles. (Vallyathan et al. 1988,1995: Vallyathan, 1994, Shoemaker et al, 1995)”. Slide: Proportions Matter - Especially in Mining So, just how much silica will we be exposed to? Our geology is igneous in origin with later metamorphosis and alteration. One way to classify igneous rock is according to their silica content: This graphic displays the different categories of igneous rock. All of these rock types are present in our geology. Proportions matter… especially in mining. FELSIC has a silica content greater than 65% by weight such as quartz and plagioclase feldspars FELSIC TO INTERMEDIATE has greater than 20% quartz by volume and between 65-90% plagioclase feldspar such as granodiorite INTERMEDIATE has a silica content between 55-65% by weight such as andesite (52-63%) and diorite MAFIC has a silica content between 45-55% by weight such as gabbro (48%) and diabase ULTRAMAFIC has a silica content less than 45% such as serpentinite What’s most remarkable in Rise Gold’s report is the assumption that 98% of the rock mined will be meta-andesite rock with a silica content of 60%. This percentage was obtained from the geology 101 textbook definition of andesite rock as being between 52-63% silica. Just how accurate is this number? First of all, this is meta-andesite rock not just andesite.…it has undergone metamorphosis becoming altered in composition. In the book, The Gold Quartz Veins of Grass Valley, referenced in the Technical Report of Idaho-Maryland Project Johnston (1940) stated: “The degree of metamorphism may vary in this unit, such that parts of it have been referred to as amphibolite schist, porphyrite, diabase, and quartz porphyrite.” The laboratory that Rise used for all metals analyses, ACZ Laboratories, is certified to perform both silica and silicon dioxide tests yet not a single sample was analyzed for this parameter. Why is this important? To quote Sara Seager, a planetary scientist: “When you are working on such enormous scales, the smallest mistake can be amplified into massive miscalculations” (Sara Seager, planetary scientist/astronomer, The Smallest Lights in the Universe) For example, mining 1000 tons ore/day at 60% silica would yield 600 tons of silica (1,200,000 pounds) But mining 1000 tons ore/day at 65% silica would yield 650 tons of silica- an additional 100,000 pounds (1,300,000 pounds) And this difference would be compounded every day. Slide: Sample Population Metals The thing we need to keep in mind is that Rise selected the sample drill locations, selected the samples to be tested and selected the tests to be performed on those samples. We don’t have the drill logs but let’s look at what information we are given from those drill cores… · From 2017-2019, Rise drilled 19 core samples during their exploratory phase for a total of 67,500 linear feet · Metals analyses were performed on 47 crushed core samples · These 47 samples were selected from just 5 of those cores (26% of the total): I-18-11(1), B-18-02(1), I-18-10(3 200), I-18-12(2, possibly mislabeled) and I-19-13(40) core · The procedure went like this: for every 90-100 feet drilled, a 10 ft sample was obtained for testing. A one gram sample from each 10 ft segment was then analyzed for metals content. The total footage for all segments combined equals 456.5 ft. (0.68% of the 67,500 total drilled) · 40 Samples (85% of the overall total) were selected from a single core, I-19-13 here shown in red. This core began at 167 ft bgs to a final depth of 4774.6 ft (4607.6 ft). · Sampling was consistent from 167 ft to 3227 ft. Then large segments (of 350 to 450 ft) started missing: 365 ft between 3227-3583 depth, another 343.3 ft between 3969.7-4313 depth and lastly 444.9 ft between 4323.0-4767.9 depth (1144.2 ft). · These missing segments add up to over 1100 ft or 25% that is absent from that core. · Why are these segments unaccounted for? Are they quartz or serpentinite? What else are we not being told? Slide: Rise Gold Projections For those who really like to understand how it works, these charts lay it out. · Rise will mine 500 tons of barren rock per day and 1000 tons of ore rock per day. · The rock will be crushed to a 6 inch size in the jaw crusher, then conveyed to the silo. · The ore rock will then be sent to the processing center to be milled in multiple stages, ground down to a small size that will enable them to separate the gold out by gravity flotation. · After removal of the gold, this material is known as “tailings” or sand tailings. 500 tons will be used in cement paste backfill while the remaining 500 tons will be mixed with barren rock to become “engineered fill”. · The pie chart shows the percentage of rock types that will be mined each day…there is no mention of quartz. · The bottom chart shows the breakdown in size for the sand tailings. · The engineering firm, NV5, stated in the Centennial Geotechnical Report that: “We understand that the sand tailings will likely have a gradation similar to the historical gradation presented in the table below, and will typically have a large proportion of quartz.” Hmmm · The quartz sand has been graded according to size and percentage of total for each size. Twelve percent will be less than 44 microns in size. The human eye can only see down to 50 microns, so these particles will be invisible. Just what amount of this 12% is less than 10 microns, of a respirable size, is unknown. · The engineered fill composed of sand tailings and barren rock will be loaded and transported to Centennial site for placement, grading and compaction. · There will be 6 fans in the ore processing facility exhausting 1 gram/second at a flow rate of over 21,000 ft3/min 24 hours per day. · What are these fans exhausting to the environment and in what quantities? Slide: Hours of Operation A close look at this proposed schedule gives us a good sense of the extent of the risk. Mining and ore processing will occur 24 hrs/day for 7 days a week. Hauling of engineered fill will occur 16 hrs/day for 7 days a week · Placement, grading and compaction of the engineered fill will occur 8 hrs/day for 5 days a week. · There will be 50-100 haul truck trips per day with each load weighing 20 tons. (50=3 trips/hr, 100=6 trips/hr) · Since placement, grading and compaction only occurs 8 hrs/day, 5 days a week, there will be significant stockpiles of this material building up before 7 am and after 3:30 pm and throughout the weekends. · Rise maintains that there will be negligible fugitive silica dust because they will sprinkle the material with water twice a day, or cover it with a tarp. We are very concerned about fugitive dust. Are there any protections for our community? Well, there are some regulatory standards for workers exposed to silica · The OSHA, Occupational Safety and Health, regulatory standard for permissible exposure level (PEL) for RCS is 50 ug/m3 TWA over an 8 hour day · The MSHA, Mine Safety and Health Administration, regulatory standard for permissible exposure level (PEL) is 100 ug/m3 TWA over an 8 hour day. This standard was adopted in 1969 and is double the current OSHA standard. · BUT OUR COMMUNITY WILL BE EXPOSED 24 HOURS A DAY, 365 DAYS PER YEAR, forevermore from multiple sources to this toxic air contaminant In 2005, California adopted a “safe limit” for non-occupational exposure. This chronic reference exposure level is 3 ug/m3 for ambient respirable crystalline silica. However, there is no enforcement of this statute and the exposure level falls below the NIOSH 7500 test detection level of 5 ug/m3. (In other words, the accepted method for sampling and testing is not sensitive enough to reach the state limit of 3 ug/m3) Note: A chronic reference exposure level is a concentration, at or below which no adverse health effects are anticipated in the general human population from long-term (up to a lifetime) exposure. OEHHA, 2000 Slide: Asbestos And still the community has yet another TAC to be concerned about …asbestos According to the World Health Organization, “No level of asbestos exposure is safe. Excess rates of cancer are found at all asbestos fiber concentrations. ” WHO Exposure is linked to several diseases: cancer of the lung, larynx, and ovaries and mesothelioma (cancer of the pleura and peritoneal linings). Exposure is also responsible for asbestosis, COPD, and pleural effusions. It generally has the worst effects when a person is exposed to an intense concentration of it or they are exposed on a regular basis over a long period of time. Chrysotile, serpentine asbestos, is the type found in IMM An asbestos fiber is defined as a particle longer than or equal to 5 microns with a length to width ratio of greater than or equal to 3:1 Thus, the fibers are invisible, readily airborne and inhaled deep into the lungs. Slide: Mining Will Occur Along Faults Associated with Serpentinite · Here is a geologic map from the Hydrology report · The black dotted line represents the mineral rights boundary with different rock types denoted by color · The purple area is serpentinite, which can contain asbestos · The red dotted lines trace the Morehouse, Idaho and 6-3 faults through the serpentinite deposit. Slide: Rise Gold’s Asbestos Sampling Locations Again in this map, the gray area represents the mineral rights boundary with serpentinite traced in purple. Green is porphyrite (meta-andesite), orange is diorite, coral is granodiorite with meta-sedimentary deposits shown in blue Slide: Inconsistencies Raise Questions And here is an expanded view of the previous map showing the drill core locations where asbestos sampling was done… · 42 samples were analyzed: 2 blanks, 2 tailings from Centennial site and 40 core samples · Core samples were from 6 different cores out of 19 total: 9 samples from I-18-11, 1 from I-18-12? (labeled I-19-12 on map), 9 from I-19-13, 7 from I-19-13A, 8 from I-19-14, and 4 from I-19-14A · Asbestos was encountered in serpentinite at final drill depth for 3 cores I-18-11, I-19-13, I-19-13A where drilling stopped. So, the thickness and width of the serpentinite layers are unknown. · Two distinct methods of analysis with different sample prep, instrumentation, magnification and counting methods were used. Forty samples were analyzed by Polarizing Light Microscopy while the remaining two samples were analyzed by transmission electron microscopy. The results by TEM were 3.1% for one sample and 2.0% for another. PLM had two detections at 0.75% and 2.5%. · Overall, asbestos was detected in four samples. For quality control, duplicate analyses were performed: this is when you analyze two samples from the same location. The results were <0.25% PLM(Y962847) and 2.0% TEM (Y962981) e.g. TEM used a magnification of 15,000X vs PLM at 50-1000X, usually 400X. Higher resolving power enables TEM microscopists to distinguish and identify finer particle and fibers not seen with the use of PLM The differences between these sample duplicate results could be due to different analysis methods, lack of sample homogeneity (one sample was received as pulp) or both. Regardless, there is a very big difference between no detection of fibers and 2.0% by weight results. Slide: No Guidelines for Specimin Collection - Stats Not Representatitive In fact… Regarding asbestos sampling, the California Geologic Survey states: “Because no exact guidelines exist for determining the number of specimens that should be collected, any statistics that are computed using the quantitative results from analysis of these specimens cannot be interpreted to be “representative” of the entire NOA population. Guidelines for Geologic Investigation of Naturally Occurring Asbestos in California, California Geologic Survey For example, suppose the analytical results for three samples are 0%, 5% and 10% asbestos. The mean, or average, of these three values is 5%, but the variability is considerable. Simply reporting the average value, 5%, says nothing about this variability. It is not correct to say that the average NOA concentration for the entire site is 5% because it is not known, nor can it be known, that the three specimens are representative of the entire population.” Rise did use a “weighted” average for the 12 serpentinite samples used for asbestos weight % determination. Four of those samples, 25% of the total, contained asbestos ranging from 0.75-3.1% by weight. The core lengths ranged from 3.6” to 13”, with over half of the samples at <5” length. Based on 12 samples, Rise calculated the content of asbestos as 1.08% by weight and the asbestos emissions are based on the 1% of serpentinite to be mined each day. Is this an accurate percentage based on the limited sampling done, testing limitations and the asbestos variability in serpentinite deposits? Slide: So much Serpentinite in the Mining Area Here is a closer look at some of the deposits that are proposed or targeted sites for mining… · The diagram on the left is “The Rose Garden”. According to the Technical Report on the Idaho-Maryland Project this deposit “is hosted solely in serpentinite. Serpentinite within the Idaho fault zone, east towards the 6-3 Fault and west of the 3 Vein may host mineralization similar to the Rose Garden.” · On the right is a view of the Idaho #3 Vein System. You can trace the gold vein along the serpentinite contact, here in purple Slide: More Serpentinite And here are portions of the Idaho #1 and #2 Veins adjacent to the Morehouse fault… again with the gold vein tracing alongside the serpentinite contact Rise states that only 1% of daily mined material will be serpentinite. However, as you can see from the previous Rise Gold maps, gold mineralization has a strong association with serpentinite Rise plans for the additional serpentinite material (besides the content taken to the Centennial site) to be placed in a separate compartment of the concrete silo. It will also be used to backfill stopes (empty tunnels). Rise claims that 90% of asbestos fibers will be captured by filters on the ventilation system, water curtains, or other methods. The remaining 10% will be exhausted to the ambient environment. For reference, the main ventilation fan exhausts to the ambient environment at 200,000 ft3/minute from a height of 165 ft. In the Health Risk Assessment section of the Air Quality Report is the following statement: “The average asbestos content of the total ore is of primary concern, rather than the speculative potential of blasting particularly asbestos rich rock, since asbestos does not have established acute noncancer effects (OEHHA).” In other words, Rise will not have to account for fibers released during blasting of asbestos rich rock simply because there are no immediate proven cancer health effects from acute exposure…what a nice loophole This statement may be true for the miners but there will be safeguards in place to limit their exposure: respirators, PPE, working a short shift and being monitored to ensure they don’t exceed Permissible Exposure Levels according to regulations. At the end of their shift, they will decontaminate themselves and go home. Rise claims that by protecting their employees, they will….by default …be protecting the community. But there is a fatal flaw to their logic in this argument. The primary way that Rise will protect their workers is by ventilating the mine. But ventilating the mine to the ambient air is the primary way our community will be contaminated with asbestos. Once these fibers are in the environment, they persist forever and the community exposure will be every minute of every day. Just where can we expect these fibers to go once airborne? Slide: Particles Travel Easily - Grass Valley is at Risk We’re almost done now, but before we conclude, let’s consider how far these toxic contaminants might travel in the air. We know that both respirable crystalline silica and asbestos emissions are microscopic, less than 5 microns in size. But any particles less than 10 microns can be inhaled into the lungs · Here are some charts based on Stoke’s Law showing particle distances travelled according to wind speed and particle size. · Keep in mind that the Brunswick site is <2 miles from downtown Grass Valley · The average hourly wind speed in Grass Valley is 5.7 mph WeatherSpark · Here is one last statement from the Air Quality Report: “Based on the PM10 emissions estimated and the lab sample results, emissions of asbestos, silica, and heavy metals were estimated for purposes of this HRA (Health Risk Assessment).” · The consultant is using estimations of estimates to predict the future health of our community. It may take 10-20 years for diseases to appear from radon, silica and asbestos exposure. But the effects will be devastating. · A bigger question is…. How will we monitor these airborne pollutants? PM10 studies will only indicate quantity, they will not distinguish the amounts of the individual components AND… Nevada County is already in nonattainment status for PM10. · The fugitive dust mitigation plans are not adequate to prevent the release of airborne microscopic silica and asbestos into our environment. Slide: ALL THE GOLD IN THE WORDS CAN’T BUY GOOD HEALTH: Diesel, radon, silica and asbestos…OH MY! Rise has said that each of these pollutants will have a “less than significant effect on our community. They maintain that they will be able to mitigate or diminish the effects with strategies such as using Tier 4 diesel engines, filters on the mine ventilation fan, and wetting down the “dust”. How can spewing pollutants from thousands of gallons of diesel fuel daily, trucking rock and sand tailings laden with asbestos and silica around town 16 hours per day, building two sites with this material, plus the daily operations of the mine for 80 years have a “less than significant effect” on our community? I am concerned that the rise operation will constitute a public health and an environmental health crisis. All the gold in the world can’t buy good health. Please join with CEA to Stop the Idaho Maryland Mine!

Hundreds of people signed up to hear coalition experts talk about the Draft Environmental Impact Report (DEIR) in our January webinar. If you’re a writer (technical and non-technical) interested in commenting on the DEIR or an activist who wants to speak up, watch the recorded presentation below to get the full story or download the PDF for a quick overview. 08:15 – 83 Negative Impacts. Oh My! - An overview of what’s in the report by the numbers. 18:00 – DEIR Explainer – A tutorial on the DEIR, what it does and doesn’t do, and how it relates to decision making 29:00 – Our Take on the DEIR – CEA Foundation President, Ralph Silberstein shares a preliminary view of concerns about the science and mitigations described in the DEIR. 41:30 – How to Write a Comment Letter 49:05 – Questions and Answers 1:14:40 – Volunteer Opportunities PDF SLIDES Key RESOURCES Mentioned in this presentation Comment on the Draft Environmental Impact Report (DEIR) MineWatch DEIR information page https://www.minewatchnc.org/post/take-action-draft-environmental-impact-report County information page www.mynevadacounty.com/3195/Idaho-Maryland-Mine---Rise-Grass-Valley How to write DEIR comments https://www.MineWatchNC.org/post/how-to-write-deir-comments Sign up to be a DEIR commenter https://minewatch.ivolunteer.com/commentwriter Share the link to this webinar with others https://www.minewatchnc.org/post/deir-explainer-minewatch-january-meeting Volunteer for a variety of tasks to help stop the mine https://minewatch.ivolunteer.com/ Sign the petition (now closed) Donate (to help fund expert DEIR reviewers) https://www.paypal.com/donate/?hosted_button_id=TVNUXWDH2UBNG TRANSCRIPT of questions and answers during the session NOTE: Some questions were answered live or not included in the transcript below. We're working on adding those answers. You'll find them in red below. what specific truck route does Rise Gold propose for removing mine waste products? first 5 years, to centennial site via Whispering Pines. Then later trucking out or area Regardless of the outcome of this mine project, should we not be drafting up a petition to get a ballot measure to enact an ordinance to not allow any further hard rock mining in Nevada County? good point. This is complicated because of state and federal laws, but we want to pursue it How certain is CEA about the Mine being opened? When I talk to the general public most of the people think the Mine will not go through and be opened? It seems serious to me especially with all the hoops the county/city is making Rise jump through. we are addressing this tonight. With all the identified negative impacts, not the least of which is Rise Gold only having $400,000 of the needed $10 million to start taking out gold, why has the County not rejected this mine project? They're not in a position to do that yet. Mining approvals are subject to a regulated process, which includes the Environmental Impact Report we're talking about there. The County is obligated to consider it. Great slides. Can we post them to NextDoor, Facebook etc.? I found when posting to NextDoor that people really appreciate DATA and not OPINIONS. That is a wonderful idea -- thank you What did Rise Gold do to other communities by mining in them? What is their record for environmental damage? Rise Gold itself has never opened a mine or made a profit in 15 years. However, their CEO, Ben Mossman was CEO at the Yellow Giant Mine in BC Canada where they polluted tribal waters, went bankrupt, and let Canadians with a bill to pay. You can learn more at https://www.minewatchnc.org/shouldnt-trust-rise-gold Great simplification of the impacts. Thank you Martin. Thx, glad you caught it! thank you. glad there are so many You’re welcome. thank you Would panelists be willing to make presentations available to attendees for later reference in writing letters? Definitely. we will have this available on our website. We've also created a "how to" in writing comment letters. Thank you! Martin. I was not able to screenshot that screen showing that out of 85 concerns, 85 made it in. That is powerful. Could you share that with me? I want to show people our actions did something. "Glad you liked it. And thank you for contributing to the first round!!! We will definitely be sharing. (see the link above). For Mr. Webb - Reading the DEIR I see no mention of using solar energy anywhere on the project. I read some weasel words about Rise being an industry and is not required to pursue solar energy options. Can we challenge this in view of the large energy use by the project? It's worth challenging on the merits of the proposed project blowing up our county's Energy Action Plan, which the BOS approved UNAMIMOUSLY right before Covid in 2019. Instead of reducing our community's energy use, it would double it. Does the BOS feel all the work on the EAP they approved was useless and disposable? There aren't any requirements to install solar, so it's something to lean into the BOS on. In an era of drought water quality is most important as well as quantity for the people in town, farms and fire fighting and recreation. is there a provision for exceptional climate conditions? Yes - The DEIR should analyze potential impacts considering likely impacts from climate change in both the Air Quality Section and the Hydrology Section. Those would be great comments to include in a comment letter. The cover of the DEIR indicates there are 10 ((x) volumes and that what we're being shown is only Volume 1. Where are the other 9 and what is in them? Take a look at the Table of Contents on pages 2-11 of the report PDF. The DEIR itself is Volume I. The other volumes 2-10 contain the reports and background that the DEIR utilized for the analysis. All the documents can be found on the County website at [the link above] We recommend that people start by reviewing the Executive Summary and Project Summary and then look at the specific impact(s) they are interested in, those are contained in Chapter 4. Shouldn't a mitigation measure also be verifiable and sustainable? Mitigation measures must be fully enforceable through permit conditions, agreements or other legally binding instruments. So yes- need they should be entirely verifiable and enforceable. This would be a great thing to include in a comment letter if you see a mitigation measure that does seem enforceable, verifiable, or sustainable. How can we get Grass Valley or Nevada County to purchase the property and close mining possibilities FOREVER??? What a GREAT idea! Is the letter to be sent to Matt Kelly? If the letter is not specific to a particular situation and not highly technical, will the county or supervisors not take it seriously? I sent a lengthy email to all the supervisors expressing my reasons for opposing the mine but did not get technical. It is landing on deaf ears or blind eyes if a person does not bone up enough to feel comfortable being technical. Is the EIR data the only thing the county will consider? Not at all. Both technical and non-technical comments are valuable in influencing decision makers. Thank you for doing what you've already done. General letters to the supervisors are read and valued. For some parts of the process, like commenting on the DEIR, it pays to be very specific, but if you're not comfortable commenting on the science, then take a close look at the proposed mitigations and see if they make common sense. For instance, ask your self whether a mitigation is clear and precise enough for the County to hold Rise Gold accountable? If not. Make a comment and tell them exactly which line you're commenting on. DEIR addresses loss of wells page 1. NID will take care of this- is this a done deal? Let’s say the mine owners pay for NID infrastructure and then the homeowners pay the water bill. to be answered - stay tuned Have we reached out to metro news outlets? Yes and we continue to reach out. Is it accurate that Rise Gold states that if the Centennial Site is not approved that they have plenty of space on the Brunswick site for waste rock? And they will truck it out and sell it? If so, how significant is the Centennial site to the project? to be answered - stay tuned After the EIR is submitted, what happens before the BOS votes The next steps are as follows: DEIR released (January 4th), Planning Commission hearing February 23rd, Public comment deadline is April 4th. An Economic Report may be released in the Spring The Planning Commission will hold hearings and make a recommendation to the Board of Supervisors before the Supervisors vote. Who authored the DEIR? Raney Planning Associates I assume we can submit more than one letter? Yes "The red flag you mentioned was what jumped out to me. The DSTR is not out, yet the dEIR refers to the remediation that will be described in the report. It's like a shell game Under biological resources this caught my attention (among others) ON the Brunswick site there is a large freshwater marsh. These are possibly jurisdictional wetlands due to proximity to Wolf Creek; if so they must be delineated and permitted by USACE Under Federal Clean Water Act Section 404. The dEIR says "The applicant shall implement the mitigation measures identified in the Aquatic Resources Management Plans for the Centennial Industrial Site and Brunswick Area, pursuant to Mitigation Measure"" Where are the Aquatic Resources Management Plans; are they in the dEIR or the nonexistent DSTR?" Exactly! Great point! It’s virtually impossible to tell exactly what the biological impacts will be because they’re assuming Centennial will be cleaned up, but they have not clarified the design of that cleanup. It’s unclear exactly how many wetlands will be impacted by this project as a result, which makes the analysis inadequate. FYI - you should feel free to reach out to Matt Kelly to ask for copies of any reports that are referenced in the DEIR. They are required to provide copies of these reports if they are not available on the website. Is it appropriate to write more than one letter on different topics? Yes. Focus first on the Planning Commission and then the BOS. You can write to each member. In addition to the MANY environmental concerns, the finances of the company seem really important. But are they not a factor for this stage? You're right! The financial strength of any company trying to take on such a massive project is definitely a factor, but it is NOT explored in the Environmental Impact Report. We are confident the Supervisors will be looking at this information, plus the data from the economic impact report, before making their final decision. According to an Opinion Piece by Randall Newsome (Randall J. Newsome: Thar’s gold in those promises? | TheUnion.com) Rise Gold has $400,000 in the bank and is on the brink of insolvency. I have written to Matt Kelly and the BoS about a matter that concerns me. I calculated 13,000 added monthly trips using numbers from page 883 and 884 of the DEIR. The matter is traffic safety from the added trips. We have twisting two lane roads with blind and semi blind turns. Plus roads that feed into access roads to the mine ie Bennett, Hwy 174 and Brunswick creating a situation of crossing traffic to merge. In September there was a fatal head on accident on Brunswick. Please speak out on the added traffic safety issues created. these are the basis of some good comments. What is FEIR? Final Environmental Impact Report. Is there a zoom meeting that I could get involved in with the team? I was on one before but didn’t know the details for any further meetings. I have a bunch of people that want to help and I also have some really good ideas that we can implement to help the cause send an email saying this to MineConcerns@cea-nc.org to connect better on this. thanks. If a person has comments in more than one area, is it better to submit them separately or put them all in a single letter? A single letter is fine. You can create a section for each impact that you are focusing on. Regarding the rezone required prior to approval; isn't that it's own Yes- you’re right. It is a separate approval process. The Board of Supervisors will need to approve this, and there will be another hearing at which you can speak directly about the project. isn't the rezone hearing it's own process? And after that, IF this is approved and goes through, leaving vast environmental damage; is there a way to hold the county legally liable for their decision based on profits vs. actual outcome? to be answered - stay tuned Who should letter be sent to other than the supervisors? I would like to share my letter with someone to determine if it is significant enough. We have a resource online with the address to send to the planning department. They are the ones focusing on the DEIR. https://www.minewatchnc.org/post/how-to-write-deir-comments. In addition, you can copy supervisors and any other government representatives that matter to you, like city, NID, or others. I commented on all the situations involved or as many as I could remember. I do live on top of the Brunswick Mine. Thank you! "Regarding the 100’ setback: As a multi- generational local landowner I know the logging EIR requires such set back at waterway. Since the mining company requires an 80 year lease on the land and can sell the lease if they quit/fail mining, would they then be able to sell to loggers who would no longer need a setback to waterways? Good question. The new owners would need to obtain a use permit to authorize different uses on the property like logging. Can we submit them electronically? yes. Read the how to comment guide here. https://www.MineWatchNC.org/post/how-to-write-deir-comments Can you comment on the number of folks that you might know of who see the mine as a positive addition to our county? (Other than the owner and investors..?) LoL. Rise Gold would like everyone to believe that it's a majority (if you believe their press), but that was based on a push poll that was widely-criticized in numerous op-eds in The Union. Our experience when we go out into the community and talk with people is that the vast majority are against the mine. Does copy the DTSC on our letters helpful? Or the Waterboard? Yes, if you are writing on one of their subject areas. how can I find the DEIR’s responses to the scoping comments I sent in || live answered If we have two topics of concern, should we write one letter addressing both topics, or two separate letters each addressing one topic? || All one letter is perfectly fine. Just be sure to clarify your remarks so they know which comments apply to which sections of the report. Can a DEIR letter response that was submitted during the Emperor Gold DEIR be submitted for this project (Rise)? I am referring to groundwater and domestic wells. yes. If they are relevant. (I suspect you are thinking about previous docs on hydrology. :-) During a meeting of the Planning Commission today, it appeared to me that the Commissioners are not technically "oriented". When a project was voted on , the Commissioners relied on the recommendations by Planning Dept. Staff. this is fairly typical. We would like to see more engagement into the details of projects. Is there strength in having numerous persons signing a comment letter that numerous people worked on? Not necessarily. If you worked on it collaboratively though, it is fine to put all names on it. Do what feels right to you. The exception would be if you want to write a response on behalf of an existing group such as a coalition or association. This how to guide can help. https://www.minewatchnc.org/post/how-to-write-deir-comments Are we doing something about the possible endangered flannel bush plant species that will be detrimentally affected? this is a huge issue. the CNPS is working with us to address this. thanks. How does the newly required Financial Impacts Report play into the current deadlines for public comment? The Economic Impact report is running on its own schedule and we don't have details from the County on that yet, but we do know that the intent is to have it done in the same timeframe as the Final Environmental Impact Report (FEIR) so that Supervisors have the data from both reports before making decisions. Did the DIER consider the new housing be built off Brunswick? to be answered - stay tuned After the EIR is submitted, what happens before the BOS votes to be answered - stay tuned I believe that County Staff should be communicated with as much as possible. They will also be the source of most input to the Supervisors, especially in public hearings. At this point, only the Staff and Rise Mine will make Presentations (PowerPoint) at the hearings. We get a few minutes each to talk. Good suggestions. When is the county economic impact report expected to be completed? Roughly the same time as the final environmental report - the idea is to have both of them available to make final decisions. They haven't provided a precise date. Because CEQA approval comes through the CA Department of Fish and Wildlife, would it be effective to start sending letters of opposition, or requests for further explanation of mitigation for environmental concerns, to the CDFW as well? The CEQA approval comes through the County. The CDFW relies on the CEQA document as a Responsible Agency and will have to issue separate permits for the project. Yes- it’s great to send your concerns to CDFW as well so they consider this as part of their permitting process. Our well isn’t identified as one that would get NID replacement service, but we’re only 1/2 mile from the mine and the mineral rights under us belong to the Idaho Maryland mine. I don’t see how the DEIR addresses the potential for catastrophic dewatering outside the 300 identified impacted wells. Am I missing something? You're not missing anything. This is a significant concern for many homeowners and a coalition of well owners that is forming. You can learn more at https://www.cea-nc.org/concerned-well-owners-sign-up-form/ "can the BoS make a decision Before the economic impact report is completed?" Good question. The ENVIRONMENTAL impact report is REQUIRED before they make a decision. The specifications on the ECONOMIC impact report clearly indicated that they intend to finish it in time for the release of the Final DEIR, so we're confident it will be part of the information considered before a decision Unfortunately, I have to log out. Thank you all very much for all your hard work. I look forward to working in solidarity with you all to address the issues in the DEIR and beyond. Thank you for all you do! I know this sounds obvious, but what are the logistics for submitting letters? Mail only? Electronically? Email? Email or mail is fine. Check out the how to guide https://www.minewatchnc.org/post/how-to-write-deir-comments Regarding Rise Mine finances, as a public company they can issue more stock. I heard that they were planning, and close to, a secondary offering of 2.5 million shares at approx. 50 cents per share. This would be a significant war chest. They could generate another $1.2 millon through the OTC stock market. They could do this multiple times. I wrote the public comment for Banner Mtn. Homeowners association in 2009. Yes, the focus was on domestic well vulnerability. Thanks! If you or other folks from Banner Mtn will be commenting on this round, please encourage them to let us know. https://minewatch.ivolunteer.com/commentwriter Can people outside of Nevada County comment on this? Yes Please feel free to share the documentary “Rise Beyond Gold” on social media: https://vimeo.com/480024102 GREAT idea. GREAT video. A lot of people haven't seen this one yet!!!! Been crossing my fingers for an endangered animal. My husband has a background in Haz waste mgmt, chemistry, biology and more. How can he best help? Who should he offer his expertise to? That's great! Please ask him to help with comments. If he goes to https://minewatch/ivolunteer.com , and identify his interest. We can try to match him up with others doing that work. Notice Of Availability link: chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/viewer.html?pdfurl=https%3A%2F%2Fwww.mynevadacounty.com%2FDocumentCenter%2FView%2F41581%2FIdaho-Maryland-Mine-Draft-EIR-NOA&clen=44775 to protect. Idaho.MMEIR@co.nevada.ca.us is the email Jillian referred to. Thank you! Nevada County Notice of Availability of the DEIR: https://www.mynevadacounty.com/CivicAlerts.aspx?AID=4505 Outstanding job all of you! Thanks! Thank you all for a very professional and well organized meeting! Thank you! Do we know the approximate timing for the final BOS vote? It is anticipated later in 2022. Thanks so much everyone! Thank you for all the information!

Three major, significant and unresolved impacts of the mine. The MineWatch June Community Meeting brought together three of the most significant learnings from the Draft Environmental Impact Report (DEIR) comment period that ended in April 2022. Watch the recorded presentation below to get the full story. Download the PDF for a quick overview. Or, read the script below to find specific information. 01:55 – Project Update - CEA Foundation President Ralph Silberstein gives an update on project status. 8:17 – Wells & Groundwater – CEA volunteer, Mike Shea, reviews what the DEIR said about wells and groundwater, then summarizes the flaws found by experts at Baseline Environmental Consulting 19:34 – Mine Waste Disposal and risks to air & water – CEA volunteer, Greg Thrush, explains how the the byproducts of mining are a critical concern for the quality of air and water in our area. 36:11 – Greenhouse Gas Emissions – The host of KVMR's Climate Report radio show, Martin Webb tells us how the DEIR yardstick is outdated and key emissions are missing, which leads to dangerous conclusions. 50:40 – Questions and Answers 1:18:09 – Take Action PDF SLIDES Script for Project Update Planning Commission Meeting Good evening. I’m just going to do a quick report on recent events. In case you missed it, this picture is from the March 24 Planning Commission meeting for the Idaho-Maryland Mine Draft Environmental Impact Report or DEIR. We counted 482 people who showed up, and only one person of the 100 speakers spoke in favor of the mine. Of note, we were well received. The Planning Commission was very impressed with how civil and on topic everyone was and thanked us. "NO IMPACTS" The Draft EIR comment period officially ended on April 4, but to me it seems like April 1 was more appropriate because Rise Gold continued to claim that the project basically had “No Impacts”. I kept imagining "April Fools, Investors! The project has numerous additional significant impacts that the DEIR missed." Nevada County Planner Matt Kelley said it looks like there were over 1000 comments . We submitted a letter on behalf of our coalition of 20 organizations, CEA submitted extensive Legal comments as well as addition general comments, and we had a number of comments from experts. The Draft EIR needs to be recirculated County has ot yet made a determination on recirculation. And reportedly they are still processing the comments. Under CA law, a Draft EIR must be recirculated if (1) there is significant information that was not included initially, or (2) the Draft EIR is so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment are precluded. This Draft EIR fails on both points. What Draft EIR Recirculation Means A number of additional studies will have to be done, the impacts will need to be adequately identified, and appropriate mitigations detailed in a new Draft EIR. It starts with gathering adequate data. For example: The Centennial Cleanup Project current conditions (baseline) needs to be detailed, and impacts from the cleanup assessed. Well monitoring to get a groundwater baseline has to be done BEFORE the project is started as part of the Draft EIR Extensive mine rock testing is needed to evaluate the potential toxic hazards There needs to be a realistic construction schedule instead of the ridiculous 1 year listed. It will be more like 7 years before any gold could be produced. Many other items need additional information THEN a revised Draft EIR needs to be published, and then we’d have a repeat of the public comment period and hearings. Centennial Cleanup status For those of you who are just learning about the mine, What is the Centennial project? Not to be confused with the Centennial Dam, the historic IM Mine site on Idaho-Maryland Road and Centennial Drive is covered with old mine waste that is toxic and needs to be cleaned up. Rise Gold plans to dump more tailings on the site, so they need to clean up the 44 acres of mine waste first. This is being done under the supervision of the Dept of Toxic Substances Control, or DTSC. The DTSC is a separate agency, and the cleanup plan (Remedial Action Plan, or RAP) is not even approved, but the Mine Draft EIR pretends that it is already done. The Final Remedial Action Plan and response to public comments is now expected late this month with a proposed Final RAP, and final approval of that would follow at some later date. Our view: The cleanup and all of it’s impacts must be included in the Draft EIR. The DEIR should describe the current conditions of the site and assess all of the impacts of the cleanup and the mine together instead of breaking the mine project into pieces and thereby disguising the true impacts. Economic Study Status Nevada County contracted to have an independent Economic Study done on the proposed mine’s economic impact. The consultant is apparently waiting for some evaluation of the Draft EIR comments due to the high possibility that the project description will change. Our take: The study will likely be less favorable to the Mine than the study provided by Rise Gold, which has a number of defects. Script for Wells & Groundwater My section of the presentation will focus on the mine's potential impacts on groundwater and wells. - First a little background - Numerical Model Rise hired two firms to look at the effects the mine will have on hydrology – EMKO Environmental, Inc. and Itasco, Denver Inc. (Eye tas ka) Itasca developed a 3-D numerical groundwater flow model of the Mine and the surrounding area. Using this numerical model and other analytical methods, historical data was used to simulate and evaluate the effects of mine dewatering on domestic wells above the underground mine works. - Modeling And based on their simulations and evaluations, the firms made estimates, predictions, and assumptions on how the mine will affect wells. According to the Idaho Maryland Well Mitigation Plan that accompanied the draft EIR: “All potentially impacted wells are located in the E. Bennett Road area. Domestic water wells outside this area will not be impacted.” - What me worry And, as you may have heard, Rise says it will provide NID hookups for up to 30 properties using well water along East Bennett Rd. So it sounds like Rise has everything covered. What can possibly go wrong? We have consulted with other experts, ones that weren't paid to prepare reports for Rise Gold. And here is what our experts found: Flawed Groundwater Model – Fracture patterns The Draft EIR does not accurately evaluate the project’s impacts on wells because it relies on a flawed groundwater model. There are several reasons for this. Let’s take a look at them: Baseline Environmental Consulting, a consulting firm hired by CEA's attorneys, points out that accurate prediction of groundwater behavior in fractured bedrock using groundwater models rarely occur because there are different, unknowable, fracture patterns in the bedrock. Flawed Groundwater Model – Baseline groundwater The DEIR acknowledges that baseline groundwater levels have not been established and wants to defer the collection of additional data to the future using a Groundwater Monitoring Plan. But by then it would be too late because the mine would already be approved and dewatering will have started. And this Groundwater Monitoring Plan seeks to establish pre‐dewatering baseline levels but not until after dewatering begins. Do you get how crazy that is? Flawed Groundwater Model – wide enough area Also, the DEIR states that “drawdowns of the water table are generally within the mineral rights boundary” but provides no explanation as to how it determined that water table drawdowns would be limited to the area within the Rise mineral rights boundary. According to Baseline Environmental, since the area surrounding the Project site contains a fractured bedrock system it is possible for water table drawdowns to extend beyond the mineral rights boundary. Flawed Groundwater Model – data limited and not current Rather than using current data, the groundwater model was calibrated based on historical pumping rates and a single water level measurement from 64 years ago. Data used about the private wells was old and limited to just a few years. Flawed Groundwater Model – new mine features Also, the groundwater model did not include the proposed access shaft Rise wants to put in or other proposed mine features, all of which would contribute to the downward transmission of ground water. Flawed Groundwater Model - faults Plus, there are three major faults and numerous minor faults in the mineral rights area. These impact the transmission of water and introduce a high level of uncertainty in the accuracy of a model which assumes the geology is uniform. Flawed Groundwater Model end These are all elements that are critical for constructing a reliable groundwater model. And, before the impacts of the mine dewatering can be accurately identified, a reliable ground water model is needed. It is our position that the groundwater model is seriously deficient with respect to data reliability, initial conditions, and modeling assumptions, and does not accurately depict the projects impacts. Significant to who And here’s another thing, the DEIR holds that a well isn’t considered significantly impacted unless there is a 10 percent reduction of water. Nowhere in the DEIR is it explained how this arbitrary 10 percent reduction figure was chosen, nor is it justified. What about low volume wells that barely supply enough water now? Any reduction may be too much for them. Keep in mind Rise has made no plans to provide water to well owners other than those on East Bennet. Monitoring Wells As I previously mentioned, the Groundwater monitoring plan acknowledges that more groundwater level data is needed to assess the potential impacts of the project to groundwater levels. The DEIR and associated Groundwater Monitoring Plan does not propose to monitor water levels in the actual domestic wells that may be affected by the project, but proposes to install 15 monitoring wells. No explanation has been given on how it was decided 15 wells would adequately represent the hundreds of other wells in the area, nor was information provided on how they arrived at the locations of the monitoring wells. This shows the locations of the monitoring wells, represented by a red dot with crosshairs, with the mineral rights boundary shown by a double doted line. I think you can see that there are large areas within the mineral rights area that do not have a monitoring well, nor are there any monitoring wells outside of the mineral rights boundary. Do these 15 wells make you feel comfortable that your well won’t go dry? The bottom line is that the DEIR incorrectly concludes that the impacts to wells are less than significant and any possible impact is fully mitigated. We disagree. –Protection for Well Owners This leads us to what we believe what needs to be done to insure well owners are protected from any impact the mine could have on their wells. • Completion of a detailed water supply well inventory for all wells within the Mineral Rights Boundary, plus a substantial buffer zone; This would include the details about each potentially affected well such as the construction design, type and use of the well (e.g., domestic, irrigation, industrial, etc.); water demand; recharge rates; and seasonal variations in water levels; and • Development of a plan for each well to ensure that an immediate alternate water supply can be provided should a well be impacted. This plan must ensure alternate water supplies will be provided throughout the 80‐yearlife of the mine and beyond. The question is, will the county protect its residents by requiring Rise to pay whatever is necessary to ensure well owners are not without water. Things do go wrong I'd like to end with two examples of how models and simulations can go wrong. First, you no doubt are already aware of what happened when an underground gold mine was opened in San Juan Ridge. After a bedrock fault was encountered the water flowing into the mine greatly increased. A dewatering well was drilled to capture this excess water, but when the water was pumped out of the well it caused “significant water level declines in water supply wells north of the mine.” What I want to point out is, before the mine was approved a groundwater study was also done, and if you read it, you will see the same words used in the EMKO and Itasco studies – Modeling, Simulation, Predicted, Estimated, Assumed. And the prediction was, that dewatering would have a minimal impact on neighboring wells. So as you can see, models are not perfect. The second example concerns the Stillwell aggregate mine operated by Cemex in Lemon Cove, California. Without getting into the specifics of the problems faced by well owners, a water consulting firm hired to review the data and previous groundwater evaluations was able to demonstrate numerous contradictions and inconsistencies within the Hydrological report previously prepared by EMKO. That name sound familiar? The problems in Lemon Cove further illustrate the issues that arise in hydrologic studies. The bottom line here, is that reopening a mine under the feet of an established residential and business area is a huge risk. History tells us that things do go wrong. The analysis and proposed mitigations presented in the DEIR are wildly inadequate and completely fail to address the significant disruption and financial consequences that would befall local residents and businesses when things fail. Resources https://www.cea-nc.org/the-idaho-maryland-mine/idaho-maryland-mine-deir-comments-by-cea-foundation/ Script for Mine waste and the impact on water and air quality 1. Introduce topic of mine waste a. Hardrock mining creates large amounts of mine waste. Mine waste includes the barren rock excavated in search of the mineralized ore rock and the tailings that are created as the ore rock is processed to extract gold. b. The Draft Environmental Report (DEIR) describes three ways to deal with the mine waste. 1) Dump it on a suitable disposal site, 2) sell the waste rock as a product (which has to meet certain standards before it can be sold to assure that it is not a source of contamination), or 3) return the material back into the mine. I’m going to focus on surface disposal because it bears upon the impacts to water and air quality in our area. c. Of the 1500 tons of rock excavated each day, 500 tons are returned back into the mine as backfill and the rest ends up somewhere on the surface. d. That “somewhere” happens to be near the residential neighborhoods that border the New Brunswick Mine site and the Centennial Site that adjoins the industrial / business park area off Whispering Pines Drive near downtown Grass Valley. 2. Mine Waste Storage a. Under the current mine proposal, each day 500 tons of barren rock and 1000 tons of mineralized ore rock are excavated and crushed underground to a size of about 6 inches. b. The freshly broken rock is brought to the surface. The mineralized ore is processed which results in fine sand tailings, and rest is 6 inched-sized, unprocessed barren waste rock. 3. Water quality impacts a. It’s easy to think of rocks as unchanging, but they are actually composed of mineral elements that interact with what’s around them. Mine waste piles are actually dynamic physical and chemical systems. b. Surface disposal exposes waste rock to conditions different than what exist underground. Weathering, the exposure to water and oxygen, causes waste rock to undergo changes that leach metals into the fluids flowing through it. Depending on the chemical composition of the rock, these effluents can be hazardous. c. Arsenic, Iron and Manganese are three principal minerals of concern because they are abundant and naturally occurring elements in our region. All are readily leachable metals. If not properly managed, hazardous substances contaminate public waterways, get deposited on land where they dry and can become airborne. Water and dust are the primary exposure pathways to humans and other animals. d. The State’s Central Regional Water Quality Board is tasked with assuring that discharges into public waters do not exceed established standards. Under Title 27 of the California Codes and Regulations, effluent water quality data are used to classify mining waste in order to determine whether containment will be required, based on that data. Containment means making sure that toxic substances don’t get into public waterways. 4. What does the DEIR say about mine waste? a. The short answer is practically nothing, beyond where to put the stuff. According to the DEIR, there are no significant concerns about mine waste that would be produced by the mine’s operations. b. Rise Gold collected drill core samples and hired a consulting firm to analyze the samples and characterize the geochemistry of the waste rock. The analyses concluded that the mine’s tailings would not generate acid. Acid Rock Drainage is one common environmental hazard that accelerates heavy metal leachates. This is all that the DEIR says about effluents coming from mine waste. c. Waste rock and mill tailings that produce near neutral to alkaline pH effluents with elements such as arsenic are not mentioned at all. This is a significant omission given that both the historic Idaho-Maryland mine and the neighboring Empire mine contain documented high levels of arsenic in the mine waste piles produced by prior mining activities in this area. d. A paper published in 2014 about arsenic associated with historical gold mining in the Sierra Nevada foothills found that waste piles at the Empire Mine Historical State Park contain high levels of arsenic. [Explain figures] i) This map of Empire Mine State Historic Park shows the locations of mining features. Waste-rock piles are shown in light green. It shows data points for arsenic concentrations on trails prior to remediation determined by field X-ray fluorescence. ii) This table presents the levels of heavy metals found in the various waste rock piles in the park. The final two columns titled “Total Metals Exceeding Criteria” and “As Exposure Point Concentration” show which elements exceeded CA Health Screening levels in each waste pile and levels of arsenic concentrations at each place. For reference, natural concentrations of arsenic in soil typically range from 0.1 to 40 mg/kg. 5. Air quality impacts a. In terms of air quality, in addition to the above mentioned metals, silica and asbestos are substances of concern in mine-waste because they are released when rocks are crushed, transported and disposed of. b. Silica is essentially pulverized crystalline silica or quartz. The size of the airborne silica particles determines the amount of risk. Larger particles, such as beach sand, are not as great a concern because they are too large to inhale. Smaller particles can be inhaled deep into the lungs where they cause health impacts like silicosis. c. Serpentine rock often co-exists with gold bearing quartz and it does exist within the mineral boundary area of the proposed mine. Serpentine rock commonly contains asbestos. The crushing, hauling and deposal of waste rock liberates the materials within it – including asbestos. This possibility is acknowledged and discussed in the DEIR. 6. Review some of the expert comments to the DEIR related to mine waste a. The DEIR does not contain any data that would serve as a basis for classifying waste rock or mill tailings. Given what is known about historic waste rock and mill tailings contamination from past mines in the area and its potential to generate poor quality effluent that threatens water quality, the DEIR is negligent not to address this. b. The sampling that was submitted for analysis appears to be selective and, given the DEIR’s lack of documentation about how the samples were chosen, it is not possible to determine if this sample is representative of the ore body that would be mined. Rise Gold completed 19 drill exploration drill core holes, totaling 67,500 linear feet, from 2017-2019. From this drill core, Benchmark Resources collected six drill core samples that it used to characterize the geochemistry of the waste rock. The geochemical predictions for approximately 96% of the waste rock to be produced comes from one 10-foot interval of drill core, and one 1-foot sample. The sampling is inadequate at best and possibly deceptive. 7. What does the DEIR say about mitigating asbestos and silica? a. The DEIR makes no mention of silica, most likely because it is so pervasive, but it does talk about asbestos. b. The Asbestos Management Plan would ensure that average mined material and engineered fill contains less than 0.01% asbestos. Testing the asbestos content, however, does not control the amount of asbestos in the actual material mined. To control the average amount of asbestos in output materials (and to avoid significant impacts related to asbestos exposure) you have to test and potentially stockpile asbestos-rich material to mix it down to an acceptable level with other mine waste. Currently, the DEIR does not include any evidence that asbestos levels will not exceed this threshold. c. The testing process can require up to two weeks before the results are known, yet the Project calls for daily mining activity to continue during this time. The DEIR does not address how this would happen given that daily mined material might have to be stockpiled while awaiting the test results. Otherwise, the mine waste could get trucked out and dumped with knowing what levels of asbestos it contained. d. Incidentally, Rise Gold’s business plan counts on eventually selling and trucking mine waste as a construction material. The ability to do this is also regulated by the State and thus would have to conform to the same contamination standards as local surface storage. 8. Conclusion a. As I’ve briefly outlined, the DEIR has serious omissions related to mine waste. b. While mining technology advances in terms of its efficiency and has made improvements by abandoning some dangerous processes like the use of mercury, the byproducts of mining are not different than they were 150 years ago and the environmental impacts of mine waste remain the same as well. Operating a mine again in our area would re-start many of the same issues that the initial exploitation of the gold rush introduced. c. Over the past 15 years, about one million dollars in EPA Brownfields funding has been allocated for our area just to help figure out how to remedy the contamination resulting from past mining activities. Mine waste is a significant environmental issue that still needs to be addressed in our area and re-opening a mine would simply contribute to the complicated legacy problem of mine waste contamination. d. The DEIR is supposed to describe what are the environmental impacts of opening a mine and how those impacts will be addressed should the mine application be approved. The DEIR clearly fails to do this with regards to mine waste. e. Mine proponents talk about the benefits and the wealth created by mining gold but are mute about the social and environmental burdens that our community bears to in order allow them to achieve their objectives. f. It is not within the DEIR’s scope to assess the social costs borne by our community to host an industrial mining operation, but they are real. So it is up to us to make sure that the issues are understood and communicated to the County’s decision makers. This concludes my presentation. Thank you for your time and attention. Resources Arsenic Associated with Historical Gold Mining in the Sierra Nevada Foothills: Case Study and Field Trip Guide for Empire Mine State Historic Park, California https://www.researchgate.net/publication/266672219_Arsenic_Associated_with_Historical_Gold_Mining_in_the_Sierra_Nevada_Foothills_Case_Study_and_Field_Trip_Guide_for_Empire_Mine_State_Historic_Park_California Arsenic species in weathering mine tailings and biogenic solids at the Lava Cap Mine Superfund Site, Nevada City, CA https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3037876/ Script for Greenhouse Gas Emissions: DEIR yardstick is outdated, key emissions are missing, leading to dangerous conclusions PART 1: BAD GHG YARDSTICK The DEIR must choose a GHG yardstick Question: At what level do GHG emissions break into “significant” territory, requiring mitigation by CEQA? A level of acceptable unmitigated GHG emissions is set Project stays below that annual limit = GHG pollution is ignored by DEIR and considered “Less Than Significant” Project goes above that limit = GHG mitigations must be taken that lower the GHG, and increase the project costs DEIR uses the wrong GHG yardstick, for the wrong place, at the wrong time Some CA Counties & AQMD’s came up with arbitrary 10,000 metric tons/year of “CO2 equivalent” = no worries 10,000 “MT of CO2e” = ~22 million pounds of CO2 That’s shredding a 6-million-pound solid block of carbon/yr This number was arbitrary and does not represent the best climate science and GHG goals DEIR uses the wrong GHG yardstick, for the wrong place, at the wrong time Some CA Counties & AQMD’s came up with arbitrary 10,000 metric tons/year of “CO2 equivalent” Our County & our AQMD (Northern Sierra) have never set any numerical GHG limits to use for this analysis We are a different county/region than SoCal, the Bay Area, Sacramento Metropolitan area, and Placer County This was lifted from SoCal AQMD, Bay Area AQMD, Sacramento Area AQMD, Placer Co DEIR uses the wrong GHG yardstick, for the wrong place, at the wrong time 2015 = International Paris Climate Accord set new global GHG reduction goals 2016 = CA SB32 updated state GHG reduction goals, triggering statewide review 2017 = CA Air Resources Board Scoping Plan says “Achieving no net additional increase in GHG emissions, resulting in no contribution to GHG impacts, is an appropriate overall objective for new development.” Old limits that don’t apply here, in a time of urgent GHG reductions, allow emissions to spoil our environment unchecked. Four chronological parts for GHG analysis: Year 1: “Construction & Dewatering” = 3,444 MT/yr … Limit set at 1,100/yr 5 Yrs: “Mining/Dumping @Centennial” = 7,222 MT/yr … Limit set at 10,000/yr 6 Yrs: “Mining/Dumping @Brunswick” = 7,000 MT/yr … Limit set at 10,000/yr 70 Yrs: “Mining/Dumping @Elsewhere” = 9,041 MT/yr … Limit set at 10,000/yr The DEIR abandons all efforts to mitigate, eliminate, or offset 1.5B lbs of CO2 emissions for the entire 80 years of operation. DEIR MITIGATION GOAL: ONLY OFFSET 2,344 METRIC TONS 1 YEAR, ALLOW 7,000-9,000 METRIC TONS FOR 80+ YRS (approves of releasing >1.5 billion pounds of CO2 = burning ~800,000,000 pounds of coal, according to EPA) PART 2: GHG EMISSIONS OMISSIONS Ignore GHG emissions from Centennial cleanup…but donate its GHG benefits: 5 Yrs: Mining/Dumping @Centennial = 7,222 MT/yr … Limit set at 10,000/yr 70 Yrs: Mining/Dumping @Elsewhere = 9,041 MT/yr … Limit set at 10,000/yr Centennial toxic cleanup is not part of “existing starting environmental conditions.” The GHG section wasn’t supposed to assume a cleanup was done. It does anyway. This allows the mine’s environmental report to capture GHG benefits of a cleanup that may never happen, while ignoring all negative impacts of that same cleanup. The DEIR must either fully ignore, or fully include, GHG impacts of the Centennial toxic cleanup as part of the mine report. Ignores GHG emissions from using cement Cement Paste Backfill use is constant = DEIR says 468 cement truck trips/yr Based on payload size of trucks = 3,884 MT of CO2e released every year to produce the cement…not included anywhere in DEIR GHG analysis This number would blow GHG emissions past the 10,000 limit used in the DEIR, for the entire 80 years of operation, triggering necessary mitigations Per CEQA, the DEIR can’t include the project’s GHG emissions from cement production as part of the mine’s analysis, but the impact will happen, regardless Ignore GHG emissions from ore processing After some initial on-site ore processing, gold concentrate is shipped away because refining is a chemically intensive process w/ environmental issues The gold-to-be-refined could be transported to Nevada, other US states, or even overseas for refining The GHG emissions from this final transportation step (especially if via ship), as well as GHG released during the final gold refining process, are ignored Final decisions should take into account the project’s GHG emissions from off-site ore transportation/ refinement regardless of the DEIR analysis. KEY TAKEAWAY: MINE’S GHG EMISSIONS Outdated limits (set too high) Multiple GHG sources ignored = * OVERALLOW & UNDERCOUNT GHG * climatemartin@gmail.com

Mine waste and its effluents are one the very real consequences of historical and potential future mining in our area. This meeting is designed to give you a better working knowledge of the topic so you can talk to people clearly and accurately about the potential impacts that mines have in our area. This session's featured speaker is Rick Humphreys, who pursued his undergraduate and master’s degrees in geology at Cal State University, San Jose. Rick comes from a mining family and spent most of his career as a scientist with the State Water Resources Control Board where he worked on water assessments of active and historic mines. After retirement, Rick and was a Science and Policy Advisor to The Sierra Fund and worked on TSF's Toxic Mining Initiative. Rick's talk is divided into three parts. The first part is an overview of mines, how they work with some terminology to help think and talk about what actually occurs underground in an operating mine. The second part will focus on mine waste, the different kinds there are and what is unique to each kind of waste. The third part is about mineral oxidization of earthen materials like mine rock and what are the results of these processes. 00:00 - Introduction - Moderator, Greg Thrush introduces the session 04:57 – Project Update - CEA Foundation President Ralph Silberstein gives an update on project status. 12:00 – Mines – Rick Humphreys introduces the audience to key mining terminology and shows examples of how mines are typically laid out. 17:34 - Mine Wastes - Rick explains the differences between types of mine wastes, including mill tailings, heap leach waster, waste rock, and overburden. He also talks about the importance of characterizing the wastes and the complexity of sampling and testing in advance of mining and on an ongoing basis. 33:50 - Questions and Answers - Rick and Ralph answer audience questions 51:00 - Acid generation potential of earthen materials - Rick delves into the issues with acid mine drainage, gives an overview of the causes, and provides some discussion of approaches to mitigate the risks. 1:07:50 – Questions and Answers - Rick and Ralph answer audience questions 1:18:20 – Take Action - Greg describes current projects and ways to get involved in the fight against the mine. PDF SLIDES MINING 101 PRESENTATION ONLY This reduced version of the presentation contains only Rick Humphreys' talk. Rick Humphrey's Script - Mining 101 Mines Mine Waste Class Acid Generation Mines Underground Mine Terminology These are some terms used to describe underground mine features. Some are self descriptive while others, well, they’re head scratchers. Vein Vug Adit Portal Shaft Stope Drift Breast Incline Decline Winze Hanging wall Footwall Headframe Cage Roof bolt Room and Pillar Bit Blast hole Muck Chute Run-of-mine Underground Mine Schematic #1 The schematic depicts a plane view of a generic underground mine. There should be an air shaft from the upper adit to the mountain top. Ground water draining into the mine working either flows out the portal or is pumped from the sumps. Underground Mine Schematic #2 Appianing, E.J. et al, MOL Report Nine, 2018 The schematic depicts an underground mine in flat terrain. In this case ventilation is provided by compressors and ground water is pumped from the mine. You’ll get a better feeling of the three D nature of the mine workings under Grass Valley when we view the Empire Mine Model tomorrow. Mine Wastes Mill Tailings. Heap leached waste. Waste rock, overburden. Waste rock and mill tailings common at abandoned mines. The second presentation covers the types of mine waste produced by a modern mine, wastes at abandoned mines and dredge spoils. At new mines, waste behavior in its final resting place is unknown. Determining how a mine waste will behave (and what its effluent characteristics are) is the whole point of doing static and kinetic tests. In contrast, mine waste at old mines has had time to “behave” so the point of testing is to determine how it is behaving (is the mine waste or its effluent a problem). For new mines, characterizing mine waste should be a continuous process that begins during exploration and continues as long as mining and processing ores continues. In the end, mine waste produced falls in to three gross categories. All three waste may be found at recent mines, waste rock and mill tailings are common at abandoned mines. Mill tailings Ore ground in a mill to sand size and finer. Characterized chemically and mineralogically. Often contain processing reagents. Discharged to impoundments, lakes, the ocean. Mill tailing are wastes from ores that have been mechanically ground and processed to recover the product of interest. Modern mines have data on tailings they generate. Old gold mine mill tailings frequently contain mercury. Mill tailings often contain elevated levels of metals, metalloids, and constituents such as sulfate. There’s rarely any historical data for old mill tailings. As with waste rock, old mill tailings are essentially an unmonitored kinetic test. Heap leach waste Ore ranges from 13mm to >30cm. Often augmented with cement. Not as well characterized as mill tailings. Leached with cyanide on liners. Closed in-place. Heap leach waste is ore that has been leached with cyanide to recover gold and silver. Heap leaching is a relatively new process (implemented in 1980). In the early days of heap leaching, old mine waste (both mill tailings and waste rock) was “reprocessed”. Waste rock (see overburden) Particle size ranges greatly. Most voluminous waste but poorly characterized. Dumped as close to the mine as possible without (the company hopes) any need for containment. Waste rock does not have enough of the product of interest to warrant “processing” at current market prices. Waste rock can become ore and ore can become waste rock over the course of days depending on the commodity market. Old waste rock dumps are essentially unmonitored kinetic tests. Overburden May be “soil” that is stockpiled for reclamation. May be “non mineralized overburden” that is used for constructing impoundment berms, road beds, etc. May be “mineralized overburden” which is really identical to “mineralized waste rock”. Poorly characterized. As you can see, there’s some ambiguity in terms. Acid-generation mitigation measures for large masses of earthen waste are expensive so there’s incentive to minimize the mass of waste that must be mitigated at the beginning of a new mine. However, it is much more expensive in the long run to mitigate unanticipated masses of problematic wastes. Dredge spoils Organic-rich, often described as “peaty”, iron sulfide rich sediment. Fine grained. Should be characterized before disturbed. 1. The literature of acid generating dredge spoils stresses that such material should be expected when working in estuaries. Mitigation measures stressed avoidance or placing materials under conditions that promote stability (reducing conditions) Pre-mining sample sources Surface grab and trench samples. Exploration drilling samples (chips and core). Metallurgical testing samples (e.g., pre- and post-processing samples for milling). 1. It’s always good to know what materials are being tested and when. Mining sample sources Ore control sampling during mining. Head and tail samples during milling. 1. Sampling and testing should continue through mining. It should not stop when mining begins. Summary Testing programs result in lots of samples. Predictions based on early testing may change if new wastes are identified as mining proceeds. Predictions based on early testing may change if mineral recovery process change during mining. 1. Characterizing the amount and behavior of mine waste should run parallel to characterizing the amount and grade of the ore body. Data quality for both should be comparable. Acid Generation Potential of Earthen Materials We’re going to start with an overview of acid generation. Keep in mind that acid generation has been and still is the subject of research. As such, there are active discussion groups and a steady stream of reports for any of you who might want to pursue this subject in depth. Why do we care? The Bad: Causes serious water quality problems. Causes serious soil fertility problems. Costly to clean up. Clean ups usually require long-term maintenance. USGS Do we all agree these are bad consequences? Does anyone have others we should list? Why do we care? The Good: Enriches metal ore bodies. Produces iron-rich soils which are fertile. Makes cool crystals. Remember, a “natural” process can’t be all bad, right? What earthen materials display the problem? Coal, base metal, and precious metal mine waste. Iron sulfide-rich estuarine marine sediments. Iron sulfide-rich metamorphic rocks (e.g., slates, phyllites). Iron sulfide-rich sedimentary rocks (e.g., pyritic sandstones). Hydrothermally altered rock. Have I missed anything, does anyone have material they would like to add. What is the primary cause? Iron sulfide mineral oxidation catalyzed by bacteria. Iron sulfide minerals responsible: acid volatile sulfide > marcasite > pyrrhotite > pyrite. Other sulfide minerals: copper, nickel, mercury, etc. sulfides do not oxidize readily in air and water to produce acid. However, ferric iron from iron sulfide oxidation will oxidize them to produce mine waters rich in heavy metals, mercury, arsenic, etc. I figured that you all have seen the usual reactions, and that you all know that acid generation is biologically characterized. So I didn’t reproduce them here but they are all included in the background reports on the web site. The reports also contain a lot of “research” reading for those of you whom want to delve into pyrite oxidation in depth. Oxidation Reactions FeS2(s) + (15/4)O2(aq) + (7/2)H2O => Fe(OH)3(s) +2SO42-(aq) + 4H+(aq) {general} FeS2(s) + (7/2)O2(aq) + H2O => Fe+2(aq) +2SO42-(aq) + 2H+(aq) 4Fe+2(aq) +O2(aq) + 4H+(aq) => 4Fe+3 + 2H2O {bacteria catalyzed ferric iron production} FeS2(s) + (14)Fe+3(aq) + (8)H2O => (15)Fe+2(aq) +(2)SO42-(aq) + 16H+(aq) {pyrite oxidation by ferric iron} But I got a lot of requests to depict the reactions after the first class so here they are. By D. Kirk Nordstrom Bet reactions aside, the schematic convey the process much better as, once ARD gets going, all the reactions occur at the same time. Iron sulfides Well crystallized pyrite from Spain that’s similar in form to the example from a road cut near Carson Hill. The Carson Hill example is Cretaceous (>60 million years old) and is oxidizing slowly. On the other hand, the mixed sulfide sample from Iron Mountain mine is older (Devonian) but is oxidizing rapidly. What is the secondary cause? Acid release from iron sulfate salt dissolution. Rapid - Melanterite, rozenite, szomolnokite, romerite, copiapite, etc. Slow - Alunite-jarosite Dry mine waste may contain iron sulfate salts that are an easily released source of stored acid. The Iron sulfate salts on the iron mountain sulfide hydrolyze in water to produce an acidic effluent rich in metals (Fe, Cu). Iron sulfate salts These are more examples from Iron Mountain Mine. More Iron sulfate salts Rhomboclase (H3O)FeIII(SO4)2·3H2O Coquimbite, FeIII2(SO4)3·9H2O These are more examples from Iron Mountain Mine. For those of you who like chemistry, these are the ferrous and ferric iron salts that form in sequence through iron oxidation and dehydration. Natural Buffers Carbonate Minerals provide rapid buffering. - Calcite > dolomite > magnesite > ankerite. Silicate Minerals provide slow buffering (about 7 orders of magnitude slower than carbonates). - Feldspars, olivine Note that these are not biologically catalyzed reaction, and sulfate mineral armoring is not considered. Acid Generation in the field Copiapite-group minerals growing on pyrite, Iron Mountain, CA Iron sulfate salts on a road cut. The same minerals that form in Iron Mountain mine may sometimes be found in iron sulfide bearing outcrops and road cuts. These minerals indicate that acid generation is occurring. These minerals also wash away easily. Summary: All Iron sulfide minerals generate acid “Sooner” or “Later” “Sooner” causes serious water quality problems because a lot of acid is generated over a short time. Natural neutralization or assimilation cannot keep up. “Sooner” results from: low crystallinity, high surface area, impurities (e.g., arsenic in pyrite), lattice defects, strong oxidizing conditions. “Later” causes no or limited to water quality problems because acid is produced over a time span sufficient for neutralization or assimilation by the environment. “Later” results from: high crystallinity, low surface area, high purity, defect-free lattice, reducing conditions. In a general sense, all iron sulfide generates acid. The trick is to find out if the generation rates will result in a low pH effluent, and if mineral oxidation in general will result in effluents that are problematic from a water quality and human health standpoint.

Over 5,500 signatures From Nevada County residents and others were collected online and in person by an army of volunteers... showing extensive opposition to the mine. For Immediate Release: July 12, 2022 Contacts: Traci Sheehan Community Environmental Advocates Foundation traci@cea-nc.org Community Submits Petition Signatures Opposing Gold Mine Grass Valley, CA – July 12, 2022 – Today, MineWatch Nevada County, a coalition effort spearheaded by the Community Environmental Advocates Foundation (CEA Foundation), announced that it has joined together with businesses, homeowners, conservationists, and others to obtain over 5,500 petition signatures and 1500 comments to showcase the community's opposition to reopening the Idaho-Maryland Mine. Signatures were collected in person and online through grassroots efforts such as information tables in front of local businesses and sharing via website and social media. The petitions were presented to the Nevada County Board of Supervisors during their regular board meeting on Tuesday. RISE Gold Corp., a company headquartered in Canada, has proposed re-opening the mine in Grass Valley – an urbanized historic mining town. The long-shuttered mine sits just outside of the downtown, and a residential neighborhood has developed around the abandoned site. “Despite Rise Gold’s claims to the contrary, these petitions add to the growing mountain of evidence that the people of Nevada County are overwhelming rejecting the mine”, stated Ralph Silberstein, CEA Foundation Board President. “Over a hundred volunteers helped collect these signatures. Many told me their job was easier than expected because it was extremely rare to meet anyone in favor of the mine.” Further evidence of anti-mine activism abounds. “No-mine” opinion pieces in the local Union newspaper outnumber “pro-mine” pieces 160 to 8. MineWatch social media groups are over 2,500 members strong. And almost 500 people attended the planning commission meeting in March to review comments on the Draft Environmental Impact Report for the mine – at 9am on a Thursday morning. Of the 101 who took tickets to speak, only one spoke in support of the mine. Over 1500 of the people who signed online also wrote personalized messages to Nevada County Supervisors. The full collection was delivered today along with the petition signatures. Here are just a few samples. "As a physician and Nevada County resident for 10 years, I am opposed to this mine [and] I urge you to oppose the mine. Please don’t vote to destroy the peace, quiet, and beauty of our delightful town. This is the best place I have ever lived and worked. If this mine opens, I will move, and you’ll have one less doctor here." “A hundred years ago a mine was appropriate. Now we are dependent on tourism and attracting people to a clean and quiet place. The mine site is surrounded by 1-5 acre parcels, [with hundreds of them] on a well. Approval of a mine in this situation opens the county up to a financial disaster.” “As a water policy specialist, I know the impacts of mining and the value of water in this climate change vulnerable region. Water is more precious than gold, and with its terrible track record Rise Gold should not be allowed to come anywhere near our watersheds which could easily be further degraded and depleted by this mine.” "As a renter, property owner, and leader of a soil health/agriculture non-profit, all in Nevada County, I strongly object to the proposal to reopen the Idaho-Maryland Mine. I’m very concerned about the impacts on water quality and underground water sources, including the impacts that polluted wells would have on our surrounding farms and food supply. I urge the Board of Supervisors to protect our community, our environment, and our economy and reject the proposed mine." Of the over 5500 people who signed the petition, over 85% were Nevada County residents. Another 5% were from neighboring counties such as Placer, Yuba, and Sacramento. 6% were tourists or visitors. For more information about the potential re-opening of the Idaho-Maryland Mine visit: www.MineWatchNC.org *** About CEA Foundation: Community Environmental Advocates Foundation (CEA Foundation) performs research, education, and advocacy to promote responsible land use and environmental protection policies in Nevada County. CEA Foundation is the sponsor of MineWatch, a campaign that brings together a coalition of nonprofit organizations, residents, and businesses opposed to the mine. www.cea-nc.org/

The MineWatch Community Meeting in September was a rare in-person event. View the recording below or download the PDF below for a quick overview. Opening - Shafted - Filmmakers Lou Douros and Larry Huntington introduce a new chapter in their series of short films about the mine project. 01:11 – Rise Gold News – CEA Foundation volunteer, John Vaughan talks about the outcomes of Rise Gold CEO Ben Mossman's trial in Canada and the company's appointment of a new CEO. 06:23 – Project Update / Vested Rights - CEA Foundation President Ralph Silberstein gives an update on project status and in-depth overview of Rise Gold's petition for vested rights. 21:15 – What's the Risk? – CEA Foundation volunteer and Wells Coalition organizer, Christy Hubbard, talks about what's at risk if vested rights are granted. 28:25 – Questions and Answers 41:40 – Never Again – CEA Foundation volunteer and Wells Coalition organizer, Gary Pierazzi, talks about the cost to the community of fighting efforts to reopen the mine and calls for a future action to protect homeowners from future battles. 47:50 – Take Action - CEA Foundation organizer Traci Sheehan helps attendees understand how to take action in the coming months. Note: Shafted is a GoFundMe project. Learn more. Note: CEA Foundation's legal team is preparing a response to Rise Gold's vested rights petition. Please considering making a donation to help. PDF SLIDES

View the Fox News report on the outcome of Rise Gold's attempt to claim vested rights to reopen the Idaho Maryland Mine. View the video here. Nevada County Leaders Vote For Mine to Remain Closed

Interested in learning about the latest developments in the fight against the mine? Rereading recent newsletters is a great way to catch up.

Download a PDF to see a collection of over 265 letters to the editor and almost 100 articles published during the fight against the mine. What a journey it has been! Rise Gold first submitted the application to re-open the Idaho-Maryland Mine in Grass Valley 2019. Initially, few knew about it. But as word spread, the community started weighing in by submitting letters and opinion pieces to the local newspaper, The Union. By 2024, opposition to the mine united our community like no other topic in recent decades. Conservatives and liberals alike weighed in against the mine. It seems that air, water, and quality of life are bipartisan topics! In the PDF file below, we've collected over 265 letters and opinion pieces that were submitted to The Union Newspaper from the beginning of the fight against the Idaho-Maryland Mine through February 1. 93% of them are against the mine (248 vs 19). There are also almost 100 newspaper articles from The Union, YubaNet, and others of note. Thank you to EVERYONE in the community who contributed. What an amazing community we have! Download the collection

APPROVAL / DENIAL PROCESS TIMELINE The California Environmental Quality Act (CEQA) requires the Nevada County to produce an independently written Environmental Impact Report (EIR) to inform the decision-making process about whether or not to re-open the Idaho-Maryland Mine. The approval process for the mine is regulated by CEQA, making the whole effort a marathon, not a sprint. Nevada County's detailed project timeline chart can be found here. https://www.mynevadacounty.com/3195/Idaho-Maryland-Mine---Rise-Grass-Valley UNDERSTANDING THE CALIFORNIA ENVIRONMENTAL QUALITY ACT Listen to retired Capital Planner, Paul Schwartz, explain the timeline, process, and decision points for the Draft Environmental Impact Report (DEIR). The County is required to produce an environmental report per the California Environmental Quality Act (CEQA). ​

This is it! The FINAL hearing on Rise Gold’s application to re-open the Idaho-Maryland Mine. After a long four-year run-up, the Nevada County Board of Supervisors will finally get to vote on the fate of the mine. This is the most important and final step in the decision process. LATE BREAKING NEWS The County is offering FREE bus/shuttle service to the hearing (see below) Hearing hours have been extended to 7pm on Thursday night to give the public more time to comment! You can pick up tickets to speak as early as 8am! Help us show Supervisors this community’s fierce opposition to the mine. Let's FILL the chambers (and overflow rooms) - AND deliver the same level of outstanding comments to Supervisors as we did with Planning Commissioners last May. This is our last chance to tell Commissioners to Just Say No to the project... AND the seriously flawed Environmental Impact Report! Only denying the mine AND not certifying the EIR will defeat it for good! Thursday, Feb 15 is the most critical day. → Pick up your 'no mine' attendance sticker at the MineWatch booth. → Join us for a group picture during the lunch break. Thursday, Feb 15, 2024 | 9:00am – 7:00pm (EXTENDED HOURS) Friday, February 15, 2024 | 9:00 – 5:00pm (or until its done) 950 Maidu Ave, Nevada City, CA 95959, USA Here’s a rough idea of how the schedule will go. 8:00 am Thursday Feb 15 – This is the earliest you can pick up a comment number if you want to speak, but you can pick up a number any time before comments are finished. 9:00 am– Most of the morning will be taken with presentations & supervisors questions. Public comment will begin after that. Lunch break – The exact time will be decided by the Supervisor chairperson. Join us for a giant group photo shortly after they declare lunch. Be flexible if you can. Sometimes they break before noon. Sometimes after. Afternoon to 7:00 pm / likely continuing to Friday Feb 16 Public comment continues. Note: it is possible public comment will be done by Thursday evening. If you want to comment, Thursday is your safest bet. Once all speakers have been heard, the supervisors will discuss and take a final vote. Spoken comments needed: 3 minute comments are encouraged on all related topics, e.g., environmental, economic, cultural, trust. If you made a public comment at last May’s Planning Commission hearing, consider refreshing it and presenting it again. Supervisors may (or may not) have heard your comments back then. And even if they did, let’s give them a refresher course. If you would like to make a spoken comment, your best bet is to show up Thursday morning and get a number (that number is your assigned spot). 8:30am on Thursday is the earliest you can pick up a comment number if you want to speak, but you can pick up a number any time before comments are finished. Your speaking time will likely be Thursday afternoon or early evening (which might involve a return trip for you). It is possible comments will continue to Friday morning, but we can't be certain. I depends up on how many speakers there are (and how many are actually there when their number is called). We will track speaker numbers and post them on Facebook (only) so you can keep track of when your number is likely to come up. We recommend you practice your speech in advance to make sure it fits within 3 minutes. The County's microphone will turn off automatically when your time is up. Know before you go: Carpool or take the bus if you can. The County expects overflow conditions in the Rood Center parking lot. If you can, take the bus or carpool with others. Route 1 ervice is FREE. See details below. Plan for lunch. Java Johns County Cafe in Rood Center is open for business. Or... pack your own lunch. Join us for lunch and a group photo on Feb 15 -- We will gather everyone and share the moment with a giant group photo. In addition to the Board Chambers, there will be overflow rooms for folks to sit inside. Outdoor seating will also available (weather allowing). Our goal is to have everyone seen and heard by the Supervisors. Read the County's public notice about the event to learn more about the rules of engagement. The County will be live streaming the meeting for those who can't attend in person (note that online attendance isn't counted, so if you can make it in person - it would be gratefully appreciated) https://www.youtube.com/@CountyofNevadaCA/streams More things you can do to help make a HUGE impact: Invite family and friends to attend the meeting. Share social media posts about the meeting on Facebook, Instagram, or Nextdoor. Write a letter to editor in the Union newspaper in the weeks before the hearing. Have questions? Email mineconcerns@cea-nc.org Why take the bus? It's fast - check out the timetable below. 25 minutes from Tinloy Center to Rood Center. It makes a bunch of convenient stops where you can park -- Grass Valley City Hall, Fowler Center, and Nevada City SPD to name a few. It runs on the hour- buses leave from Tinloy Center The Bus is FREE February 15 and 16! Route 1 | Nevada County, CA (nevadacountyca.gov) Route 1 departs Tinloy Transit Center, Grass Valley, at the top of the hour starting at 7 a.m. and will arrive at the Nevada County Rood Center approximately 25 minutes later; for example, an 8 a.m. departure from Tinloy Transit Center arrives at the Nevada County Rood Center at 8:25 a.m.

Local resident, John Vaughan takes issue with a Union columnist's February 6 opinion piece about the Mine. George Boardman: Supervisors’ decision on reopening of the mine is just the beginning of the end. This opinion piece was published in The Union. In response to George Boardman’s February 6th column, it appears George is generalizing a bit too much without actually doing his homework. If he had done that, Mr. Boardman might find that: The EIR lists significant and unavoidable impacts…to noise, traffic, and aesthetics. The EIR ignores dozens of expert opinions that question a long list of EIR conclusions and proposed mitigations. The supposed benefits shown in the Economic Report are based completely on data provided by Rise. Large parts of the data provided by Rise for the Economic Report do not stand up to even mild scrutiny. The Economic Report’s inability to find conclusive evidence of negative impact on real estate values was the result of ignoring their own survey of licensed local realtors and instead relying on a non-standard analysis of three mines that bear zero resemblance to our community or situation. The EIR conveniently forgot to include 2019 findings, provided to Rise by the EPA, whose test results show mine drain outflows into Wolf Creek with high levels of Arsenic, Barium, Chromium, Cobalt, Copper, Lead, Manganese, Nickel, and Zinc…happening every day, right now…with no cleanup plan from Rise. The jobs Rise brags about represent less than 0.6% of the County’s current employment, are 5-10 years away, and independent experts estimate that 58% (not 32%) of Rise’s workforce would be commuters from outside the county. The new CEO is a part-time consultant with lots of experience in Mergers & Acquisitions at Mining companies but no apparent experience in day-to-day operations…which means that Mr. Mossman, convicted in Canada on 13 counts of dumping toxic waste into the environment, will likely oversee day-to-day operations. The proposed well mitigations and well monitoring plan is a joke, based on old science with no financial plan to cover costs and protect homeowners, leaving people with no permanent water supply if anything goes wrong during the 80-year permit. I could go on and on but maybe Mr. Boardman understands my point by now…Economic Reports and data provided by Rise are designed to sell a story, just like any other advertisement you see. Maybe those advertisements should be taken with a grain of salt. Then, Mr. Boardman attacks the people who oppose the mine. Yes, oh my! Some of the opponents, including me, are retired. Does that also make Mr. Boardman, who certainly looks old enough to be retired, less valuable and his opinions less useful? Does being retired actually mean someone does not understand business and the need for jobs? Mr. Boardman might consider that a person’s long experience leads them to say, “We agree, that good paying jobs are needed…but what is the real cost and risk associated with this proposal?” But I guess Mr. Boardman believes if you are retired you are not allowed to comment on jobs and economic growth. Maybe, just maybe, Mr. Boardman should consider that the people opposed to the Mine include all age groups, many of whom have done their homework and clearly understand the high risks and low rewards, and actually care about the future of this community. I agree with Mr. Boardman that Nevada County needs expansion and new business. It happens that the property Rise owns is already zoned for a Business & Industrial Park which could easily support hi-tech or any other “clean” business without the many risks associated with the Mine. I’ll also note that relying on “old standbys” is a very common business practice while waiting for the next opportunity that makes sense. Re-opening the Idaho-Maryland Mine on an 80-year permit vs. the catastrophic environmental impact and multi-multi-million cost of cleaning up any issues is not worth the risk and makes absolutely no sense. I even agree that attracting new businesses to our County is a challenge, but Mr. Boardman’s implication that nothing is being done is misinformed. The County is making strong progress on removing some of the critical infrastructure barriers of the past, including better high-speed internet access and the availability of more workforce housing. And finally, I completely disagree with Mr. Boardman’s innuendo that various people have a better idea for how to actually run government, despite their glaring lack of experience or any specifics about how they would accomplish cutting County salaries and expenses. Good luck with keeping the excellent workforce Nevada County already has if major cost cutting is your only plan. For more information, see the Minewatch site at www.minewatchnc.org or attend the Board of Supervisors hearing on February 15th and February 16th. John Vaughan, Grass Valley Retired, 56-year resident of Nevada County

During the comment period for the Draft Environmental Impact Report, Rise Gold submitted 1,600 reply cards and form letters as “comments” that simply declared support for the mine without following County guidelines to focus comments only on the adequacy of the report. This included over 500 duplicates and multiple spoofed names. In late June, they used those numbers to create a press release claiming that the majority of residents support the mine. By contrast, MineWatch opposition leaders delivered over 5,500 petition signatures and 1,500 personalized opposition comments on July 12th, 2022. The Union covered it lightly in Panning for support over mine; Rise Gold and advocates spar over level of opposition, but three opinion pieces published on July 20th tell the rest of the story in all its ugly detail. They are included below in their entirety. Scroll past the picture for easy reading. Christy Hubbard: Rise Gold resorts to stuffing the ballot box July 19, 2022 Originally published in The Union Let’s face it, we’re all growing deeply weary of Rise Gold’s misrepresentations when it comes to talking about the proposed reopening of the Idaho-Maryland Mine. Last year, there was the widely criticized, heavily manipulated survey that concluded the majority of residents support the mine. (Read Op-eds in The Union #1, #2, #3 #4). Early this year, their glossy mailer proclaimed that the mine was going to be “green” while happily ignoring the huge energy use and greenhouse gas emissions they’ll be generating. Even more alarming were their assertions that “The county has determined” that the project is safe … trying to fool people into believing that a draft environmental report was the final word on the subject. Recently, they hit a new low with their press release claiming the majority of the comments on the environmental report “supported” the mine. Come again? Are they serious? I distinctly remember sitting in the Planning Commission meeting and being told that this was not the forum for “for” or “against” comments, but that we should focus our comments on the adequacy of the draft report itself. But no. Rise Gold needed a press sound byte so badly, they decided to submit 1,600 reply cards and form letters that simply declared support for the mine. This is akin to stuffing a ballot box because people on the other side of the fight weren’t even using the environmental report comments to cast votes. As it turns out, over 500 of them were duplicates, making the real count more like 1,100. Then adding insult to injury, some of the listings seemed to be spoofed because they included several names of known MineWatch activists who oppose the mine and deny ever authorizing Rise to share their names. What was the rest of the community doing in the meantime? Wait for it … They were playing by the rules. Several nonprofits and impacted agencies like NID and the City of Grass Valley submitted comments to the County, as did many hundreds of individual citizens, creating a total of over a thousand legitimate comments. Now comes the part where Rise Gold uses simple math to create the illusion of a “win.” They divided their 1,600 into the total of some 2,850 comments to create a talking point with a claim that 59% are in favor of the mine. Pretty slick, huh? OK. Perhaps they can fool their investors. But they are not fooling us. The fact is that far more people in this county oppose this mine than support it. CEA Foundation/ MineWatch volunteers made that abundantly clear at the Nevada County Board of Supervisors meeting on July 12. CEA Foundation President Ralph Silberstein, delivered over 5,500 petition signatures which, included 1,500 unique and personalized comments to the supervisors, all expressing opposition to the mine. These petitions were gathered in person and online. The paper petitions were collected with the help of over 100 trusted volunteers who reported that encounters with actual mine supporters were very rare. The online petitions used a well-known security tool called reCAPTCHA to reduce the risk of compromise by automated bots. The original count had been well over 6,500, but volunteers took the time to remove duplicates so the county could receive an honest count of voices against the mine; 4,714 of the signatures were from Nevada County residents, with the remainder from nearby counties, visitors, and others. But that’s not the only proof. ∎ This community delivered a powerful presence when the planning commission meeting hosted the comment meeting for the draft environmental report in March 2022. Almost 500 people were in attendance. Of the 101 who took tickets to speak, only one spoke in support of the mine. [Update: almost 1000 opponents attended the hearing for the final environmental report in May 2023.] ∎ Of the 168 opinion pieces that have been published in The Union newspaper about the mine, only eight of them were pro-mine. That’s 95% opposed. ∎ MineWatch social media groups are over 2,500 members strong. ∎ “No Mine” signs abound on residents’ lawns, with nary a pro-mine sign to be found. Let’s put this debate to bed, shall we? Despite Rise Gold’s claims to the contrary, the people of Nevada County are overwhelmingly rejecting the proposed re-opening of the Idaho-Maryland Mine. If you are as outraged by Rise Gold’s behavior in this as I am, please send a letter to your supervisor. Mining is a toxic, risky business that relies on companies to self-report most compliance measures. Ethics matter. Learn how at http://www.MineWatchNC.org/take-action. Christy Hubbard is a Grass Valley homeowner, a volunteer with Community Environmental Advocates Foundation, and a leader in the MineWatch campaign. Guarionex and Sharon Delgado: We never supported Rise Gold; why do they list us as so? July 19, 2022 Originally published in The Union. Earth Justice Ministries is a local interfaith nonprofit organization that we founded with other clergy and laity almost 30 years ago. We have made clear our unwavering opposition to the reopening of the Idaho-Maryland Mine, as individuals and as an organization. We have circulated petitions, written op-eds, spoken at public forums, sent letters to public officials, and submitted comments on the draft environmental impact report to the Board of Supervisors on the dangers we see posed by the mine. We know that many other community members have done the same. With all the public opposition to the mine, when we read Rise Gold’s recent press release stating that most of draft impact report comments sent to the Board of Supervisors showed support for the mine (1,600 out of 2,850), something seemed very wrong. It just didn’t add up. For one thing, that’s not the point of the draft environmental impact report. Rise Gold is misusing the process as a public relations campaign. The point is not to count how many people support or oppose the mine, but to comment on impacts of the project. Rise Gold is treating the comments like a poll or survey by tallying up pre-written, postage-paid postcards and electronic form letters supporting the mine. They did not even check for duplications. It was the hard-working MineWatch volunteers who looked closely at the names and discovered that over 500 were duplicates. Also, the names of several so-called mine “supporters” were actually MineWatch volunteers, like us! How could that be? We were shocked to discover that our names were listed as having emailed comments to the Board of Supervisors in support of the reopening of the mine, not just once, but three times! When we saw the actual emails that had been falsely submitted in our names, all three were identical. Each email was just one sentence that said, “I support the reopening of the Idaho-Maryland Mine,” with our names pasted electronically on all three. Strangely, although our actual email address was listed, the only return email address we could identify was Sharon and Guari Delgado . The same thing happened to Holly Rose, who had five emails sent in her name, identical to the ones sent in our names, also from this third party. We know that this also happened to other people, and that these false emails were part of what Rise Gold claimed were legitimate comments on the report. Without Minewatch oversight, we wouldn’t have known. Jarryd Gonzales, the spokesperson for Rise Gold, did not explain this behavior but rather made the vague claim that “an email was sent to the county whenever someone visited the (Rise Gold) project website and completed a support form.” Neither of us ever completed such a form, and we can’t imagine other Minewatch volunteers doing so either. Gonzales also claimed that “there are more duplicates on the side of CEA (Community Environmental Advocates) or Minewatch.” This is false. Minewatch did not send out pre-written cards or form letters for volunteers to submit to indicate their side by stating their opposition to the mine, but rather encouraged volunteers to follow the draft environmental impact report process by studying the impacts of the mine and making their own comments. In other words, the Minewatch Coalition followed the rules of the draft environmental impact report process. Now, appropriately, Minewatch is making public the names of people who have taken a stand in opposition to the mine by submitting petitions to the Board of Supervisors. On Tuesday, July 12, the Minewatch Coalition turned in petitions that included 5,550 names (with no duplications) of people who oppose the reopening of the mine. Volunteers did the hard work of not only circulating petitions, but also removing duplications. From where we stand, we see these petitions as an honest measure of where most Nevada County residents stand on the mine. Guarionex and Sharon Delgado live in Nevada City. Holly Rose: Where did they get my name as a ‘supporter’? July 19, 2022 Originally published in The Union. Alan Riquelmy has a clever headline for his July 12 article: “Panning for support for the mine; Rise Gold and advocates spar over level of opposition to plans to reopen Idaho-Maryland.” But there are errors and omissions. “Other mine opponents claimed their email addresses had been used to submit comments in favor of the mine.” “‘Not just once,’ said Sharon Delgado, ‘but three times.’” I’m not “claiming” they used my information. They did. I presented five actual emails to each supervisor at the meeting. I believe they were also provided to Alan prior to the meeting. There are many people that Rise is claiming supports them, not just Sharon Delgado and myself, that are documented signers of the no mine petitions. MineWatch has the exact number — nine, I believe they said, each probably having more than one entry. I would think mine supporters would want to follow up that they don’t have fraudulent support letters/comments. They can check with MineWatchNC. Jarryd Gonzales, spokesman for the Idaho-Maryland Mine project, said duplicate comments exist on both sides of the mine issue. Those numbers were taken from the county,” he added, noting that 56% of the comments favored the mine. “What you’ll find is there are more duplicates on the side of CEA or MineWatch.” Concerning opponents’ emails being used in support of the mine, Gonzales said an email was sent to the county whenever someone visited the project website and completed a support form. Documentation shows Rise’s numbers should be the only ones in question. I guarantee I never completed a support form and Rise’s numbers still include their duplicates and fictitious emails, not MineWatch’s. With everything presented at the meeting, how did Alan get it so backwards? MineWatch has meticulously gone through and deleted all duplicates so their numbers are accurate. That was stated at the meeting and specifically told to Alan, I believe. Rise’s July 29 press release says it has 59% support. The article states Mr. Gonzales is now claiming 56%. Is Rise actually changing their numbers or was that a typo? I was relieved to let the Board of Supervisors know what Rise is up to and was told The Union reporter was going to cover it. People need to know that our email information and addresses are being fraudulently used in Rise’s numbers and we have no idea how many are fake. They somehow have my residence address, which I don’t give out, except for voter registration. It’s not rocket science to figure out that support numbers Rise claims are incorrect. Holly Rose lives in Grass Valley.

Join us on Saturday February 10, 2024. 1:30 – 3pm at the Mardi Gras Parade in Nevada City. Join the fun! This year's parade is the perfect opportunity to speak out against the mine and ask neighbors to attend the follow week's public hearing where County Supervisors will take a FINAL vote on the fate of the Idaho-Maryland Mine. Help us demonstrate to Supervisors this community’s fierce opposition to the mine! If you’ve marched against the mine before, you know that this is a super-fun community event and a rewarding experience. The crowd cheers, chants, and sings with us! We promise you will be glad you joined. We meet at 1:30 at the top of Broad Street in Nevada City and the parade begins at 2 p.m. You can dress up or come as you are. It’s easy. Grab your sign. Bring friends and family. We'll see you there! More info about the parade can be found here: Mardi Gras Parade 2024 - Nevada City, California (nevadacitychamber.com) More information about the final public hearing can be found here: Special Supervisors Meeting Scheduled for Idaho Maryland Mine Project on 2/15 | Nevada County Please RSVP to traci@cea-nc.org so we can track how many folks we will have and identify a few “helpers”.

Local radio station, KVMR, reported on the County's Hearing to consider Rise's claim for vested rights. Listen to these brief segments to hear how it went. December 15 NevCo Board of Supes: No One Has a Vested Right to Mine The Idaho Maryland Mine December 15 KVMR's Al Stahler Interviews CEA Foundation President Ralph Silberstein December 14 Supes Hear Presentations and Public Comment Regarding Vested Rights, Continue Meeting to Thursday