Search our Library

The County's Final Environmental and Economic Impact Reports have been published. On May 11, 2023, the Planning Commission voted unanimously to recommend denial of the project and the environmental impact report. The final decision will be made by the Board of Supervisors on October 2 & 3, 2023. CEA Foundation and MineWatch Coalition technical and legal experts prepared a series of strategic arguments that were delivered to the County. Read below to learn why the County has no obligation to the approve the mine. Get smart about the top six reasons why the project should be denied and the environmental report should NOT be certified. The County has no obligation to approve the Mine. The many environmental impacts associated with the mine, as well as its inconsistency with Grass Valley’s and the County’s land use plans provide ample justification for denying the mine project. The Final EIR (FEIR) also has serious deficiencies and should not be certified. It fails to substantiate several claims that impacts would not be “significant” and does not comply with CEQA (California Environmental Quality Act). ● Environmental impacts unavoidable - The FEIR lists several significant and unavoidable environmental impacts that endanger this community's health and quality of life. These include aesthetics, traffic, and noise. There are also serious deficiencies in the FEIR that put the County and its citizens at even greater risk. Key deficiencies are shown in sections 2-6 below. ● Inconsistent with General Plan - The Mine project is inconsistent with numerous Nevada County General Plan goals and policies. The Plan’s goal 17.1 calls for recognizing and protecting mineral resources in a manner that does not create land use conflicts. And yet, multiple conflicts exist with goals for not only land use, but also economic development, safety, climate change, noise, aesthetics, water, and coordination with cities and towns. A specific list of conflicts can be found here. ● Legal considerations - The County can confidently proceed with denial knowing the decision does not qualify as “taking”, which is a legal term that describes a project rejection that denies an owner their right to develop a property. Both the Brunswick and Centennial properties are currently zoned“ Light Industrial”, which provide a reasonable use of the properties. The applicant would need to secure approval of rezoning the Brunswick site to M1-M1 (Light Industrial with Mineral Extraction) in order to proceed with the project. There is ample case law to uphold the rejection of FEIR certification if a project is denied. If the current FEIR were to be certified, then the project later denied, it will be a flawed EIR in County records that could be used in future applications. Read more legal considerations here. ● Inadequate economic justification - The Economic Impact Report on the Mine showed a huge range of possible revenue outcomes from very low to very high, making actual revenue potential uncertain. Only the lower estimates were backed by proven gold reserves. Expert community reviewers found that even low-end figures were overly optimistic with a heavy reliance on information provided by the applicant. The assertion that property values wouldn’t decline was a big miss. It failed to recognize local realtor expertise or use acceptable home appraisal methods. Additional downside risk was not evaluated. Learn more about the community review here. ● Just say no! - Continuing with the EIR and project consideration will just cost the County in loss of time and energy as well as that of staff and the community. This community is overwhelmingly opposed to the Mine project, as evidenced by the over 5,500 petition signatures submitted to the County last summer and the fact that 95% of the opinion pieces published in The Union about the mine are against it. More information about opposition can be found here. Following are six key deficiencies of the FEIR. 1 Well Owners Shafted in the Final EIR The FEIR’s conclusion that groundwater impacts from the mine project will not be significant was not substantiated. Serious deficiencies identified by expert reviewers of the Draft EIR were not addressed, resulting in a final report that does not comply with CEQA and fails to identify the potential impacts. ● CEQA requires a current baseline to assess potential impacts and determine mitigations. The computer model used for the analysis did not use current monitoring data from any of the over 300 domestic wells in the mineral rights area. It relied only on sparse patches of data from over 15 years ago. The Final EIR acknowledges that data is needed, but the approach calls for drilling 15new monitoring wells as a basis for verifying the computer model after the EIR is certified! The questionable computer model estimates well waterdrops at 1 to 10 feet for 152 wells, then avoids declaring the impact as “significant” by creating an arbitrary threshold of significance at 10%. ● The final EIR also adds a completely inadequate supplemental domestic monitoring plan for 378 newly-identified properties. Among the many deficiencies, the new program only includes about half the wells in the mineral rights vicinity and provides neither additional NID infrastructure to speed water replacement nor a third-party liaison to negotiate issues if problems arise. Read public comments from the Wells Coalition, CEA Foundation, and San Juan Ridge Taxpayers Association here. 2 Mine Waste Management Inadequacies Risk Water Quality The FEIR’s conclusion that water quality impacts related to mine waste will not be significant is unsupported. The Water Board made it clear in Draft EIR comments that more rock testing is needed to assess the likely concentration levels of hazardous elements in the rock to be mined. The FEIR’s plan for storing and disposing of mine waste has extensive gaps, creating a risk for long-term mine water pollution similar to what this community has seen in the past. ● Rise Gold’s project plans to deposit 1000 tons of tailings and waste rock per day on the Centennial and Brunswick sites for the first11 years. After that, the plan is to dispose of it via off-site sales. However, only waste classified as Group C can be used for engineered fill deposits or off-site sales. The more hazardous Groups A and B require special handling. The FEIR asserts that “mine materials will likely be classified as Group C”, but its conclusions rely on just 11 feet of drill core samples. ● The FEIR does not provide adequate provisions for the storage of Group A or Group B mine waste, which will be required by the Water Board. Since any waste that is not Group C cannot be used for engineered fill or off-site sales, viable alternative strategies must be defined. The FEIR introduced a new suggestion that if not Group C “...the waste rock would be placed underground”, but CEQA requires storage of Group A or B mine waste underground to be reviewed in a Draft EIR. ● This extensive set of gaps in mine waste management also introduces uncertainties about Rise Gold’s ability to operate by disposing of mine waste from off-site sales. Read public comments from CEA Foundation here. 3 Mine Waste Management Inadequacies Put Air Quality at Risk The FEIR’s conclusion that air quality impacts related to mine waste will be effectively mitigated is unsupported. Asbestos is found in all rock types in the Idaho-Maryland Mine in varying concentrations. The FEIR’s plan for managing concentration levels to ensure that mine waste meets safety requirements before being shipped out of the facility is inadequate. ● Management of asbestos emissions is a complicated task. If the rolling average over a 3-month period of asbestos concentration in mine waste exceeds 0.01% by weight, it cannot be shipped out of the mine facility. Rise Gold’s primary approach – as described in the Asbestos, Serpentinite, and Ultramafic Rock (ASUR) management plan – simply proposes that cores would be sampled before excavation and that if asbestos levels are too high, the rock won’t be mined. There is not enough evidence, however, to establish that they can feasibly stay below the limits using this plan. ● The test data in the FEIR for determining the potential impacts from Asbestos is inadequate for CEQA compliance. Of the testing that was provided, which came from just 3 drill cores, 40% of the samples exceeded the 0.01% threshold. Thus, for assessing the impacts of asbestos air pollution, spot sampling has been done on less than 1/1000th of the mine rock that will be excavated over the 80 year life of the Use Permit. Read public comments from CEA Foundation here. 4 FEIR Fails to Assess Impacts of Centennial Site The FEIR excludes the Centennial Site from the full analysis of the impacts of the mine project. This prevents the County from understanding the full environmental impacts and is a clear violation of CEQA, which requires that impact assessments be based on current conditions, not a speculative future condition. ● The 56-acre Centennial site is the location of hazardous waste left over from past Idaho-Maryland Mine operations. The California Department of Toxic Substances Control (DTSC) is managing the cleanup, but their Remedial Action Plan (RAP) is only in draft form. It is unclear when the plan will be finalized or when DTSC might approve the clean up. ● Per CEQA, the EIR must provide an environmental assessment of the current conditions of a project site to establish a baseline in order to determine impacts. This was not done. The FEIR assumes the site will be cleaned up before it gets used to deposit new mine waste. The plan calls for placing 1.6 million tons of mine waste (assuming it qualifies as Group C) over the course of 5 years, covering about 44 acres to a height of up to 55 feet. And yet, the significant work needed to accomplish this clean-up is not disclosed or evaluated in the FEIR. Numerous aspects of this RAP draft have been questioned in public comments and the final project details are unknown. Read public comments from CEA Foundation here. 5 Greenhouse Gas Emission Impacts dismissed in FEIR. The FEIR concludes that the mine’s greenhouse gas (GHG) emission impacts will be “less than significant”, but it uses an unsupportable, obsolete threshold measure to justify its position. The only correct threshold – given current climate studies, CA SB-32, and today’s state goals – is net zero. The County has not formally adopted its own threshold of significance, but it has set ambitious goals to reduce GHG through energy reduction in its Energy Action Plan. The Mine’s sizable energy footprint would be a serious setback. ● The FEIR sets the significance impact threshold of 10,000 Metric Tons (MT) of GHG emissions per year. Mine operations are projected to produce approximately 9,000 MT per year, which is just under the set limit. This does not, however, include the over 4000 MT of additional emissions that will be generated by cement manufacturers to provide the massive amount of cement that will be used to produce cemented paste backfill for 500 tons/day of mine tailings. ● The outdated 10,000 MT/year threshold is one that was used by other air districts such as the Bay Area in the past. More recent projects, however, such as the Sargent Ranch Quarry project managed by the Bay Area Air Quality Management District in 2022, use net zero for the significance threshold. ● The mine’s electricity usage is approximately equivalent to the annual use of 5000 homes. The Mine’s energy use would be so sizable that it would completely offset the amount of residential reductions the County wants to achieve each year in its Energy Action Plan. Read public comments from CEA Foundation here. 6 No Viable Plan for Disposing of Mine Waste. The FEIR does not provide adequate information regarding the viability of the plan to dispose of mine waste through off-site sales and does not have provisions for adequate on-site temporary storage or permanent disposal of mine waste, leading to potentially significant impacts. The project documents call for approximately 11 years of operations in which the mine waste will be disposed of on the Centennial and Brunswick sites as “Engineered Fill,” but the FEIR fails to resolve uncertainties affecting the viability of that plan. Due to inadequate testing information in the FEIR, the mine waste could not be classified as Group C mine waste by the Regional Water Quality Control Board as needed to allow dumping onto these two sites. In addition, due to inadequate testing of mine drill cores for asbestos to establish a reasonable assessment of the potential hazards due to airborne asbestos, numerous management issues regarding the safe handling and placement of asbestos-bearing rock as “Restricted Materials” remain unresolved. Worse still, for the remaining 65 or more years of operations, even if the issues of potential water and asbestos impacts are resolved, significant issues remain as to how and where the mine waste will be disposed. Read public comments from CEA Foundation here. PRINT or share this information with others using these PDFs.

For Immediate Release: April 5, 2022 Contacts: Traci Sheehan Community Environmental Advocates Foundation traci@cea-nc.org 25 Groups Call for Denial of the Idaho-Maryland Mine Grass Valley, CA – MineWatch, a coalition of 25 organizations led by the Community Environmental Advocates Foundation, submitted its culminating letter to the Nevada County Planning Commission and Board of Supervisors today. The coalition formed in 2020 and includes local, state, and national organizations that oppose the re-opening of the Idaho-Maryland Mine located in Grass Valley, CA. The long-shuttered Idaho-Maryland Mine, a mass of underground tunnels and mine waste tailings from the 1800s gold rush era, is proposed to be re-opened by Canadian-based Rise Gold Corp. A Final Environmental Impact Report (FEIR) was released in December 2022. In response, many hundreds of comments were submitted by citizens to the County expressing serious concerns about the risks of the mine and the inadequacy of the report. The County Planning Commission is set to consider the issue at a public hearing on May 10, 2023. The coalition is calling for the Nevada County Planning Commission and Board of Supervisors to avoid prolonging the battle over the mine. Asking the County to deny approval of the mine and not certify the Final Environmental Impact Report (EIR), the letter states; “We believe that continuing to process the EIR will just cost the County staff and the community a loss of time and energy.” They conclude that the “…reopening of the Idaho-Maryland Mine is not supported by a majority of Nevada County constituents. Nevada County is no longer a resource extraction county. We have shifted onto a new 21st century green economy. And our residents support this shift. Are a few jobs and uncertain tax revenue worth the risk?” CEA Foundation President Ralph Silberstein commented on the letter saying: "MineWatch has worked on the mine project diligently over the last three years to produce an accurate and detailed analysis for the community and the County. Coalition members span a wide range of organizations and expertise, and our analysis has led us all to the same conclusions. We are very concerned that the Final EIR has completely failed to adequately assess and mitigate the impacts of the proposed mine, and we view it as a significant threat to our community." The letter specifically states: "The FEIR lists several significant and unavoidable environmental impacts that endanger this community's health and quality of life. These include aesthetics, traffic, and noise. There are also serious deficiencies in the FEIR that underestimate numerous other significant and unavoidable environmental impacts which our organizations and the community have identified throughout this process." The letter goes on to outline these concluded deficiencies in detail, including: inadequate analysis of potential impacts to groundwater and residential wells; inadequate testing and provision for storage and removal of hazardous mine waste rock; limited analysis of asbestos risk; lack of assurance that the Centennial waste disposal site can be used; and underestimation of the impact of greenhouse gas emissions. "We are deeply concerned that, should the Idaho-Maryland Mine reopen, mining operations would pollute our waterways, dewater groundwater, dry up private wells already impacted by drought, and degrade wildlife habitat,” stated Aaron Zettler-Mann, Interim Executive Director of the South Yuba River Citizens League (SYRCL), a MineWatch Coalition member. “The Final EIR fails to adequately address environmental concerns raised during the EIR review period, only listing aesthetics, traffic, and noise as significant and unavoidable environmental impacts. Denying approval of the mine and not certifying the FEIR is the only way to protect our air, water, and quality of life." “Given the Nisenan's devastating experience with the mining industry and the lasting environmental destruction that can be seen from space, the Nevada City Rancheria Nisenan Tribe and its supporting non-profit CHIRP, believe the mine (the 'mul mul mul') is not in the best interest of the land, the people and the animals of today,” stated Shelly Covert, spokesperson for the Nevada City Rancheria Nisenan Tribe, which is also part of the MineWatch Coalition.“As a community, we need only look to the vast evidence around us to see the environmental and humanitarian lessons left by the gold rush that should have been learned the first time around.” The MineWatch coalition notes that the County is under no obligation to approve the project, noting that it is inconsistent with the Nevada County and Grass Valley General Plans; that there is no economic justification for the Mine; that there will be severe and unavoidable environmental impacts; and that the community overwhelmingly does not want the Mine to reopen. The MineWatch coalition letter concludes: “Our community is clearly at risk from the reopening of the Idaho Maryland Mine. It threatens to change the character of the community we love.“ The Nevada County Planning Commission is charged with making a recommendation to the Board of Supervisors. That recommendation is two-fold; first, to recommend whether the analysis in the FEIR is adequate and complete, and second, whether the Board of Supervisors should adopt the project. More information on the project can be found on the County project webpage. A copy of the Coalition’s letter is available here. Concerned citizens are encouraged to attend the County’s public hearing on May 10 to voice their opposition. *** 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. www.cea-nc.org CEA Foundation is the leader of MineWatch, a campaign that brings together a coalition of nonprofit organizations, residents, and businesses opposed to the mine.www.MineWatchNC.org Read the full comment letter in this PDF. Version 2 - Including Mountain Area Preservation

26 groups call for denial of the Idaho-Maryland Mine. The MineWatch Coalition, led by the Community Environmental Advocates Foundation, cites numerous reasons for the Nevada County Planning Commission and Board of Supervisors to deny the Idaho-Maryland Mine in this final public comment letter. See the press release here. Download a PDF of the letter here. Updated April 14, 2023 In a lengthy comment to Nevada County decision makers, the MineWatch Coalition of community and environmental organizations provided a long list of reasons to deny the project. Coalition members include: Community Environmental Advocates Foundation The Sierra Fund South Yuba River Citizens League Wolf Creek Community Alliance The Wells Coalition Patagonia California Native Plant Society Redbud Chapter Sierra Foothills Audubon Society Sierra Nevada Group Sierra Club Center for Biological Diversity Friends of Bear River Sierra Streams Institute Nevada County Climate Action Now Elders Action Network Friends of Banner Mountain Brunswick Pine Road Association Brunswick Manor HOA San Juan Ridge Taxpayers Association Earth Justice Ministries Earthworks Fly Fishers International, Northern California Council American Rivers Nevada County Sunrise Sierra Watch Mountain Area Preservation Nevada City Rancheria Read the full comments in this PDF. Version 2 - Including Mountain Area Preservation

"The EIR for the mine fails to correctly identify a valid threshold for GHG emissions by assuming an outdated 10,000 Ton threshold without any substantial evidence, failing to consider the current State goals, and it would also effectively undo a large part of the goals of the County Energy Action Plan." Don Rivenes is a board member of CEA Foundation. This opinion piece was also published in The Union. Apr 29, 2023 The County should deny the Idaho-Maryland Mine project and should not certify the Final EIR. The Idaho-Maryland Mine Final Environmental Impact Report (EIR) is inadequate in its assessment of greenhouse gas (GHG) emissions. A valid threshold for GHG emissions was not set in the EIR. As stated in the EIR, CEQA Guidelines allow a lead agency to determine its own thresholds for environmental impacts (including GHG emissions), and “explicitly provides that an agency may consider thresholds adopted by other agencies provided that such decision is supported by substantial evidence.” The Northern Sierra Air Quality Management District has not set thresholds for GHG emissions, so, as lead agency, Nevada County simply applied the 10,000 Ton/year carbon-dioxide emission threshold chosen by some other air districts for this project. However, the justifications for adopting these thresholds are unique to each air district. These other air districts have prepared detailed GHG inventories to identify and evaluate strategies for achieving the statewide GHG reduction goals within their districts. Nevada County cannot simply assume that the justifications used by other air districts to adopt their thresholds also apply in Nevada County. Hence, the EIR failed to provide “substantial evidence” required by CEQA by just considering other districts for setting the threshold. In fact, the EIR provided no evidence beyond just copying what other districts used. But this is doubly wrong because the other air districts originally adopted the 10,000 Ton threshold to achieve the older 2020 statewide GHG goal under California Assembly Bill 32, which is no longer consistent with the current statewide GHG reductions goals. In 2015, the California Supreme Court determined that a project’s GHG emissions should be evaluated based on its effect on California’s efforts to meet its long-term climate goals. Then, in 2017, the California Air Quality Board Climate Change Scoping Plan stated “Achieving no net additional increase in GHG emissions, resulting in no contribution to GHG impacts, is an appropriate overall objective for new development.”. And in, 2018 Governor Brown signed Executive Order 55-18, calling for the state to achieve carbon neutrality as soon as possible and no later than 2045, and to achieve and maintain net negative emissions thereafter] In view of this, the mine’s 9000 tons/year of emissions should be considered significant and unmitigated. The mine is proposing an 80-year project, and no consideration was given to meeting the state’s GHG emission goals. The EIR should have established a net zero threshold for GHG emissions from the proposed project. For example, in considering current goals, the recent Draft EIR for another mine — the analogous Sargent Ranch Quarry project within the Bay Area Air District uses a net-zero significance threshold for operational GHG emissions. This EIR should have done the same. The EIR does not explain why the Project should be exempted. Nevada County Energy Action Plan Nevada County Board of Supervisor’s adopted its objectives for 2023 that included, under Economic Development, to “implement tasks identified in the Nevada County Energy Action Plan”. The plan was adopted one year earlier than the Mine proposal. The Nevada County Energy Action Plan’s goal is to reduce the projected annual grid supplied electricity the county will use in 2035 by 51% and the annual natural gas use by 30% through energy efficiency measures. The mine’s electricity use is equal to adding the electricity use of 5,575 homes in Nevada County and nearly equal to current business electricity use in Nevada County. This almost eliminates the results of any energy-saving measures planned by the county. This project will consume 49,000 Megawatts of electricity, in direct conflict with the County’s energy reduction goals. The FEIR states “...although the EAP is not a Qualified GHG Emissions Reduction Plan under CEQA the project was nevertheless determined to be consistent with the EAP.” This statement is essentially false. In fact, the Mine operation is antithetical to the County’s Energy Action Plan. The Nevada County Planning Commission and the Board of Supervisors should ask the question: Are we serious about meeting our 2023 strategic objectives including the Energy Action Plans? If so, this mine should not be approved. In conclusion, the EIR for the mine fails to correctly identify a valid threshold for GHG emissions by assuming an outdated 10,000 Ton threshold without any substantial evidence, failing to consider the current State goals, and it would also effectively undo a large part of the goals of the County Energy Action Plan. Under CEQA, this EIR is totally inadequate in addressing the significant impacts of greenhouse gas emissions from Rise Gold’s proposed mine. Don Rivenes, CEA Foundation

"What is the worst thing that could happen to us in Western Nevada County? One threat that has been completely consuming over the past two years is the proposed reopening of the Idaho-Maryland Mine (IMM)." Jim Bair is a Stop the Mine Task Force Leader. This opinion piece was also published in The Union. April 28, 2023 What is the worst thing that could happen to us in Western Nevada County? I bet we all have answers to that question. But there’s a more likely threat than wildfires or additional atmospheric rivers. As a 22- year resident of Nevada County, having been a Planning Commissioner (Grass Valley), volunteered for several non-profits, and run two businesses, one threat has been completely consuming over the past two years: the proposed reopening of the Idaho-Maryland Mine (IMM). There are hundreds of excellent publications in The Union and online at Minewatch.com explaining why it’s a very bad idea. Proposed by Rise Gold Corp. of Nevada State and Canada (RISE), the project has generated over 10,000 pages including a Final Environmental Impact Report (FEIR). As a former scientist, I dove into the “science” in the report. The most dangerous impact I found is asbestos air pollution, one of a whopping 86 NEGATIVE ENVIRONMENTAL IMPACTS. Based on dozens of reports, I have concluded that asbestos air pollution cannot be “mitigated.” The FEIR’s claims that asbestos can be made safe are dependent upon government agencies that do not agree it’s possible to measure airborne asbestos, let alone mitigate it. Literally everyone agrees that airborne asbestos can cause cancer and death. So how do we stop 55,845 pounds of airborne toxins including asbestos from being released into our air every year for 80 years? We must support our deciders, the County Supervisors and Planning Commissioners in rejecting the threat. Knowing our Supervisors for many years, I feel that they are committed to doing the best for us. They depend on County planners to provide them and our Commissioners with analysis and RECOMMENDATIONS for approval. In addition, several hundred of us have delivered the results of our investigations in meetings and written comments. So have numerous organizations such as NID, the City of Grass Valley, the Northern Sierra Air Quality Resources District, the Central Valley Regional Water Quality Control Board, and legal firms. BUT Rise Gold Corp. has sophisticated consultants and lawyers. It’s a battle of the Titans, if you include all of us. But as the two sides face off, we volunteers are challenged, not only by the money that RISE has received from high-risk investors and the stock market, but by how the approval process works. We volunteer our time and rely on donations to get legal advice, while the County process is to serve applicants for project approval giving them ongoing access to the Planning Dept. We submit thousands of “comments” which are delivered to the County and, although most are copied in the FEIR, many are relegated to “master responses” in the FEIR (starting p. 74). A project of this magnitude must also fit in with a huge number of other action items managed by the County government. I know that reviewing the thousands pages of the FEIR and related documents is onerous because I have. In addition, the County must deal with the project’s consultants and lawyers whose business is to promote developments. These “expert” consultants are highly skilled at making projects pass the CA Environmental Quality Act (CEQA) and dismissing 100s of public analyses of the negative environmental impacts (see FEIR Chapter 2 – Responses to Comments Page 2-1.) I know that Planning Commissioners are looking for our comments while diligently reviewing both RISE and public input which we can still provide: ATTEND THE PLANNING COMMISSION PUBLIC HEARING, MAY 10, AT OUR ROOD CENTER, 9 TO 5. I expect that RISE’s arguments will be presented by the Planning Department and RISE consultants with numerous slides and “science”. We, including agency representatives, get THREE MINUTES each to speak and NO slides. I’ve submitted over 40 technical pages, but we can all rise to the time limit challenge. We also can deliver our written comments of any length at the hearing. (Note: I have received clear advice from Commissioners to make our comments specific to the FEIR.) But believe it or not, JUST BEING THERE COUNTS ALMOST LIKE A VOTE! Sorry about those who work all day, but with hundreds of businesses taking a stand against the Mine, you could be able to get some time off. Attend and help stop this greed grab from destroying our environment and our health. Jim Bair, Grass Valley

Independent filmmaker, Lou Douros, spent months tracking and attending Rise Gold CEO, Ben Mossman's, trial in Canada. His lengthy opinion piece is very revealing. The first of a three-part opinion piece was published in The Union on April 25, 2023. The full text of all three sections is included below. April 25, 2023 I’m an independent filmmaker. I work largely in nonfiction formats, relying on doubts to propel a story forward. There’s a strange mix of vision, obsession, and luck in my business. For a film I’ve been developing called “Shafted”, I wanted to understand Rise Gold’s proposal to reopen the Idaho-Maryland Mine. My experience has proven that when you look for stories, you most often find people. This is where my journey began. A year ago, I reached out to Rise Gold’s CEO, Ben Mossman. It was my first invitation to subject matter experts requesting an interview for a film about the conflict here in Nevada County. At the time, I only saw opposition to Rise Gold. I’ve since learned that there’s a clandestine population that thinks a gold mine here is a pretty good idea. My request went unanswered by Mr. Mossman. Instead, Jarryd Gonzales, Managing Principal of Good PR Group, took a call to weigh the opportunity. A week later, Gonzales declined the invitation on behalf of the company and wished me luck on the film. There’s a lot of speculation about Ben Mossman - his most recent business failure resulting in criminal trials for alleged environmental misconduct and economic practices that ended in bankruptcy. I set out on a lonely path a year ago through a remote meeting link that connected me to a small provincial courtroom in British Columbia. Since April 2022, I’ve not missed a single hearing of R. vs. Mossman & Meckert, 29244-4C. What follows chronicles my pursuit to understand the story behind the man behind the mine. My day(s) in court Mr. Mossman is currently facing criminal charges for the environmental damage sustained on Banks Island while acting as the CEO and Mine Manager of Banks Island Gold Ltd. I observed the presentation of evidence, witness testimony, and argument. In 2015, inspectors reported 300-400 meters (around four football fields) of significant sedimentation in one location and unpermitted dumping of tailings in another. Meanwhile, samples taken approximately eight months earlier indicated deleterious contaminants were released by the mine into the environment. Neither legal team disputed the fact that there was a spill; that much was obvious. Never mind that the “sediment and blow-down” appeared to the inspectors to have “occurred over a long period of time”. Unsurprisingly, this case pivoted on who was liable for the crimes. Over the past year, Ben Mossman attended only once in person in the courtroom in Prince Rupert, B.C. for his testimony and cross examination. His occasional remaining appearances were accessed via the same remote link I used. For the balance, his attorney appeared as agent for Mr. Mossman. Nevada County residents have expressed intense curiosity about the contents and potential outcome of the Mossman trial in British Columbia. They want to know who is the Canadian CEO of the Idaho-Maryland Mine? They’ve asked me about the extent and seriousness of the criminal offenses, the regulatory violations, their consequences, and what they might portend for Nevada County if Ben Mossman reopens the Idaho-Maryland Mine. I’ve never been a gambler. When playing Settlers of Catan, I always buy sheep when bricks would be smarter. I know little to nothing about asbestos and arsenic prevalent in serpentine rock. But when I review what I’ve heard in the courtroom and seen in content like the now-disabled banksislandgold.com website, it would be irresponsible to keep it to myself. Setting the stage In 2010, Ben Mossman and one other partner, Jason Nickel, set out to reopen the once productive but abandoned Yellow Giant Mine in British Columbia. The following year, Banks Island Gold, Ltd. (BOZ) went public on the Canadian TSX Venture Exchange, with an initial public offering of $1 million CAD. Over the next 5 years, Mossman and Nickel went on to raise the additional millions in capital it would take to bring the abandoned mine into production. Mr. Mossman recruited more than 100 employees, many of whom were unskilled members of the First Nations Gitxaala (pronounced “Kit-Kat’la”) tribe, promising average wages three times higher than what they might make elsewhere. He built and maintained a village to house his workers; roads, a helicopter pad, a boat dock, and most importantly, extensive industrial mine works in preparation for full-scale production at three different sites on the pristine Banks Island. An on-island emergency medical facility was required in the event of job-related injury for workers rotating on two-week intervals. Meals and sanitation, diesel generator power, fuel, food, and transportation were all necessary just to get crews to and from the mine portals. A buddy system kept the workers safe from an active population of wolves that lived off the plentiful prey surrounding the camp. Mossman the boss man From the start, the Banks Island Gold corporate formation and eventually the day-to-day mining operations were under Ben Mossman’s control as Director, CEO, and Mine Manager. He applied for the permits. He leased the mineral rights in his own name, then transferred them to the company. He negotiated with the many vendors required to sustain his work force and extract and process ore in this remote location. Mossman’s institutional knowledge was fundamental in filling out the board of directors and org chart with the most expert talent he could find. The British Columbia Ministry of Energy and Mines issued three MX exploration permits allowing 10,000 tons of bulk sample processing for each of the “Bob”, “Discovery”, and “Kim” mine zones, and a Major Mines permit (#241) for the primary “Tel” portal. During the trial, “bulk sample” was specifically defined to only include the targeted mineral deposits. The MX permits allowed an unlimited amount of excavation to reach the bulk sample, hopefully containing the gold. It’s important to note that everything pulled out of the ground needed to be handled in accordance with permits. " The unpublished text follows. " Not long after building out the facility, Banks Island Gold announced a declaration of commercial production in January of 2015. And that’s when it all went wrong. Not all that is gold, glitters… Just five months later, in June of 2015, the company’s safety manager sent an anonymous complaint to the British Columbia Ministry of Mines. The report included photographic documentation of numerous worker health and safety violations that he had observed and attempted to mitigate while working at the mine site. Improperly stored fuel posed a fire hazard. The mine’s ambulance was missing first aid supplies. After workers complained of headaches, the safety manager discovered a generator chugging carbon monoxide into a nearby air compressor that supplied oxygen to underground workings. Later, CO sensors were allegedly disabled for disrupting productivity. Workers blamed Tessa Brinkman. Described in the trial as Mossman’s second-in-command and now, as I understand, his wife. Escape ladders were blocked by pipes, the list rattles on... The report was damning, but there was something that really caught the attention of the inspectors. Photographs showed sediment and mine waste flowing into the sensitive riparian environment of Banks Island. Images included other permit violations; cement trucks pumping mill tailings into a pit formed by collapsed portion of the Bob site. The complaint inferred that the concerns reported to Ben Mossman, the mine manager, were met with inaction. The anonymous tip elevated inspectors’ planned visit to the mine to priority status. Inspectors from the British Columbia Ministry of Energy and Mines, Environment Canada, and a government conservation officer made two visits by helicopter, a week apart, to Banks Island in July of 2015 to inspect the site. It didn’t take long. The inspectors reported under oath that they could see the spill from the air as the helicopter circled in to land. They found an installed pipe emitting mine sediment up to 6” thick and contaminated water 300-400 meters into a creek, wetlands, and a small lake. Observing the spills and other violations of the mining permits, the government agencies shut down the mine. Shortly thereafter, the British Columbia Securities Commission issued a “Stop Trade” order. Rather than cleaning up the spills and mitigating the safety risks, the board of directors suddenly resigned. Mossman was left to manage bankruptcy, lay-offs, investor, and creditor communications. The employees, including the First Nations Gixtaala, were left jobless and approximately 170 individuals, local supporting businesses, and other creditors, were left with a total of $15 million of unpaid bills. The site was abandoned, and Mossman and two colleagues faced initial criminal charges for failing to report spilling pollution into fish-bearing water, unpermitted activities, and exceeding toxic waste limits. The British Columbia government charged them with dozens of counts of safety and environmental violations. Initially, all but two charges were dropped, but the case was appealed by both parties and eventually was heard by the B.C. Supreme Court. After a legal process spanning several years, a new trial was ordered which commenced in April of 2022, beginning with “voir dire” hearings to determine what evidence was admissible. Prince Rupert Provincial Court, Room 200 April 14, 2023. Following the voir dire decisions, Prosecutor Geoffrey McDonald for the government of British Columbia, the “Crown”, argued in his final submissions to the court that the mine manager bears liability and responsibility for criminal action or negligence by a mining company that endangers public or environmental health. He held that a corporation should not be allowed to hide behind a bankruptcy after failing to protect the public. Mossman’s defense team, Mr. Chilwin Cheng and Ms. Janessa Mason, argued that the corporation, the now-defunct Banks Island Gold, Ltd., was the liable party and that Mr. Mossman bore no responsibility for the operational decisions. The trial series began in 2015 and has exposed many issues related to Charter Rights (Canada’s equivalence to our Bill of Rights) and due process. The Hon. Judge Patterson of the provincial court in Prince Rupert, B.C. is scheduled to read his final judgement and publish it with the voir dire reasons on June 19, 2023. What I’ve learned from the trial Regardless of Judge Patterson’s decision, Ben Mossman’s years on Banks Island raise serious questions for Nevada County’s decision-makers. He may be found personally liable and sentenced to time in prison. Or, he might be spared, leaving the empty husk of his prior company hanging from the gallows of liability. Nevada County’s Planning Commission and Board of Supervisors would be wise to study the whole of what happened at the Yellow Giant Mine. Mr. Mossman’s pitches always include a kind of dog whistle for his potential investors. “Nevada County”, he says, “is the lead agency for the permitting process. It’s not the state and not the federal government.” The secret message doesn’t require a decoder ring to figure out. It’s been eighty years since the Idaho-Maryland was part of a mature, knowledgeable mining culture. Investors in junior mines have lost millions because of government meddling. Nevada County is the perfect soil from which to reap mining’s most abundant treasures unabated. Using doubt as a lever to peer under the rock, here are some take-aways from my weeks as a virtual visitor in a small provincial courtroom in British Columbia. Regulations Canadian statutes ensure that mine owners and corporations operate responsibly, as governed by the Mines Act, the Waters Act, the Environmental Management Act, and the Fisheries Act. The strict liability placed on the mine manager is intended to threaten handcuffs for anyone who might be tempted to acquiesce to criminal conduct. But what will govern a mine in Nevada County, a local government that has no working memory of ore extraction? Do our statutes deeply and specifically address the details of modern mining, or do they leave gaping holes through ambiguous and nearly unenforceable terms? A pirate code, more… guidelines, than actual rules. Regulators Statutes are only as effective as the agencies that enforce them. And in British Columbia, where mining has continued uninterrupted for centuries, multiple agencies at least try to ensure accountability specific to mining. While environmental managers in B.C. have been steeped in the complexities and risks involved in mining, Nevada County’s expertise is in writing permits for rooftop solar and deck additions. So, who will have our backs if Rise Gold, vastly larger than Banks Island, racks up millions in debt and trips over mismanagement of a complex business. As history is wont to repeat, would Mossman find the best attorney money can buy to incarcerate a nonhuman entity drained of its cash as he looks to the next frontier in resource extraction? Expert Analysis Scientific reports and expert analyses don’t solve problems. Scientists can try to describe what happened in the past. Analysts can model potential future outcomes to quantify risk. Compared to B.C., Rise Gold relies heavily on non-mining-specific environmental laws in addition to scientific reports to claim it will ensure public safety. Presumably, Mr. Mossman published the same expert analysis and proformas for investors and inspectors before reopening the Yellow Giant Mine. Ironically, it was science that quantified the resulting damage to the environment. The judge will only decide who is responsible for something everyone admits was a crime. Job Security Rise Gold has promised sky-high wages as long as they’re in business. When a Grass Valley mine failed in 1940, there were any number of local operations still hiring. Gold was like that back then. Since the 1970’s in Nevada County, talent from the Bay Area put on the Grass Valley Group’s “pinecone handcuffs” and relocated here. Now, there are engineers who regularly entertain valuable offers from within our new economy without relocating, missing a car payment, or their dream vacation. Even Banks Island Gold workers could apply at another mine in B. C. Where will the former Rise Gold miner go for work? Payroll The promises Ben Mossman made to starry-eyed workers in B.C. are strikingly similar to Rise Gold’s Facebook blitz targeting Nevada County’s young men. The 100 or so mostly male workers on Banks Island never dreamed they’d be unemployed inside of a year. Many of them never reached their first “$100,000 average annual salary”. I wonder if they received the severance package listed in the unsecured creditors chart or if they had to foreclose on their first-time home purchase. Did they have to sell the new truck they bought to avoid their own credit hit? Economic Growth Banks Island Gold’s board of directors all fled within months of the spill. The tally of creditors, including severance packages and vacation pay, and local businesses who gambled on Mossman’s projections approached $15 million. Furthermore, the company’s bond of $420,000 didn’t come close to covering the costs of environmental cleanup. Canadian taxpayers inherited a rusting industrial wasteland, gaping flooded caverns that were once mine portals, deforested roads-to-nowhere scars, discarded fuel barrels, and unmeasurable seepage into the ocean. Can Nevada County sustain a similar hit by a substantially larger Rise Gold collapse? It would be one thing if we were being told, “this time it’ll be different”. A little humility goes a long way. But that’s not the message coming from Ben Mossman, not even from Rise Gold or Jarryd Gonzalez. Their message is “trust us, it’s all going to be fine”. There are proponents on social media who have tried to wave off the environmental and safety concerns under Mr. Mossman’s watch, minimizing what they call “a little bit of mud”. But how could something so small could devastate such an otherwise intelligent and well-funded operation? It doesn’t add up. Not even the Crown Prosecutor, Geoffrey McDonald or Chilwin Cheng, Ben Mossman’s, attorney denies the presence of the environmental disaster. They’ve lived with this story for almost a decade. No, the matter currently in The Hon. Judge Patterson’s hands is, who did this? Who is liable? He will depend on specific laws and active regulators who guide thousands of active mines to operate profitably and safely. Most of them fall out of compliance at times. Most of those recover as a result of good management and disciplined practice. There aren’t thousands of mines under consideration here. There’s only one. If California’s laws are even slightly unclear about who is liable for keeping all of us safe from the Idaho-Maryland Mine, it’s the doubter in me that says Ben Mossman will likely make sure it isn’t him. Lou Douros, Grass Valley

"Grass Valley property owners gathered on Thursday evening to organize and sign a group letter from the Wells Coalition to present to the Nevada County Planning Commission." Excerpts from a Union article by Staff Writer Marianne Boll-See Apr 8, 2023 Christy Hubbard, spokesperson for the Wells Coalition, urged the audience of more than 50 well owners to sign a letter stating that the protections from Rise Gold Corporation offered to well owners in the Final Environmental Impact Report (FEIR) for the Idaho-Maryland Mine are unacceptable. The letters are addressed to Matt Kelly, Nevada County Planning Department and will be submitted to Kelly at the May 10 and 11 scheduled meeting. Two days are scheduled for this meeting because of the high number of individuals planning to speak during public comment. The protections and mitigation offered to well owners by the Rise Gold Corporation is too little, too late, and too insufficient, according to Hubbard. Read the rest of the article online at The Union.

"It is our responsibility and honor to provide the ethics of care and guardianship to this land. Prioritizing profit over sustainability is an equity and rights concern for indigenous peoples and all local communities. We say NO to this egregious IMM project, and NO to certifying the FEIR." Marion Blair is with Earth Justice Ministries. This opinion piece was originally published in The Union. April 22, 2023 Record drought and wildfires, and a winter of a dozen atmospheric rivers in California make it clear that we have a climate crisis impacting California, our beloved communities of Grass Valley and Nevada City, and beyond. Earth Justice Ministries’ mission statement includes the following: “We connect faith to actions that bring hope for the earth, the human family, and the community of life to further the cause of peace, justice and healing of the earth.” We feel it is Earth Justice Ministries’ responsibility to protect our community and combat climate change, among other things. The proposed reopening of the IMM will not bring hope for the earth, the human family, and the community of life. As a community we need to be pushing for a just and equitable energy transition away from fossil fuels which are the driving force behind the climate crisis. In fact, California’s Senate Bill 350 aims to establish clean energy, clean air, and greenhouse gas (GHG) reduction goals, reducing its GHG emissions significantly within the next decade (to 40% of 1990 levels by the year 2030). SB 350 also requires the state to double statewide energy efficiency savings in electricity and natural gas uses by 2030. Yet mine operations are projected to use as much electricity in one year, as the entire town of Grass Valley uses in a year (approximately 50,000 megawatts.) Californians have been working hard to reduce greenhouse gas emissions by switching to cleaner energy sources, and since 1990 clean energy sources have increased by 22%. Still, over 40% of GHG emission come from vehicles, a quarter of which are heavy trucks. The FEIR downplays the impacts of GHG emissions this project would create, along with many other environmental impacts that our attentive community questioned in the DEIR. The repeated use of Master responses whitewashes the significance of these impacts under a legal cloak of empty and often conflicting statements. Specifically, the following FEIR Master response 25 states: “The actions within the EAP (Energy Action Plan) are voluntary and do not require the County or community to meet the reduction goals. Nevertheless…the Project is found to be consistent with the EAP.” This statement is followed by a chart of the “assumptions” regarding how the mine will voluntarily reduce its use of electricity. First of all, assumptions are not strategies. Secondly, we do not believe the project owners will voluntarily reduce the use of electricity. They are said to be voluntarily cleaning up the Centennial Site and yet we still have no Department of Toxic Substances Report. This project will not bring hope for the human family, nor will it bring healing to the earth. This land is heritage Nisenan land, which was never ceded to immigrants. There has been little attempt made in the FEIR to consider the cultural resources of these indigenous people whose ancestral land and livelihoods were virtually destroyed by gold mining. A recent personal conversation with Wanda Enos, of the Kelly/ Enos Humwak, representing the local Nisenan community, confirms they were never consulted, contrary to the following statement (on p837 Vol 4 of the FEIR) which states: “local tribes were notified and invited to consult on the proposed project, and such information was presented in the DEIR.” This is another whitewash to make it appear that the EIR is complying with CEQA. It is our responsibility and honor to provide the ethics of care and guardianship to this land. Prioritizing profit over sustainability is an equity and rights concern for indigenous peoples and all local communities. We say NO to this egregious IMM project, and NO to certifying the FEIR. Marion Blair, Earth Justice Ministries

"Reopening a toxic mine with significant environmental impacts for the benefit of very few is simply not a risk worth taking, particularly as we consider our role in the larger fight against climate change in California." Gianna Setoudeh is the Policy Director for South Yuba River Citizens League (SYRCL). This opinion piece was also published in The Union. April 21, 2023 In 2019, Rise Gold Corp., a private company based out of Canada, submitted plans to the Nevada County Planning Department outlining a proposal to reopen the long-abandoned Idaho-Maryland Mine – hidden away beneath the vibrant community of Grass Valley, an archive of toxic mine waste and an intricate underground tunnel system dating back to the Gold Rush Era of the 1800s. In a community still recovering from the legacy effects of past mining operations, including exposure to both physical hazards on an altered landscape and chemical hazards such as mercury contamination, acid mine drainage and arsenic, lead and asbestos inhalation, the prospect of reawakening the mine has given rise to intense scrutiny and local activism, calling greater attention to the project’s significant environmental and public health impacts. If you asked the average community member about the project, the sentiment is clear. Driving around the County and beyond you will see bright yellow lawn signs with the simple plea: “No Mine. Protect our Air. Water. Quality of Life.” The project is currently under review by the Nevada County Planning Commission and will ultimately come before the Nevada County Board of Supervisors for a final vote, expected sometime in mid-2023. As it turns out, a decision on this project is much more complex than meets the eye, particularly when considering the boarder context of California’s climate policy agenda. In the fight against climate change, the proposed reopening of the Idaho-Maryland Mine is in direct conflict with not only local climate goals and initiatives, including the County’s own General Plan, but also with the State’s climate policies and long-term goals more broadly. A key question to consider is, what role does our community want to have in the statewide effort to fight climate change? At the local level, this requires going far beyond the simple checking of boxes and comes down to a deeper question of true leadership and ethical obligation. Proposed operations at the Idaho-Maryland Mine would generate an overwhelming 9,000 metric tons of new greenhouse gas (GHG) emissions annually from the proposed site in Grass Valley, plus another 4,000 metric tons of new GHGs from cement manufacturing performed offsite. Nevada County already suffers from poor air quality due to extended wildfire seasons, vehicular pollution, factory emissions and other sources of dust and particulate matter accumulation, yet the community would have to endure further air quality impacts from rock crushing, hauling, and compacting activities that could release hazardous chemicals such as asbestos and silica particles into the air during mining operations. Further, the excessive increase in diesel truck operations, road usage, and traffic generated by this project will only exacerbate local air quality concerns, damage to roadways, and increase electricity demand equivalent to approximately 5,000 new homes. The major uptick in new GHGs from this project reaches beyond local impact and contributes significantly to the state’s carbon footprint, ultimately detracting from statewide environmental goals. This just scratches the surface when it comes to the project’s potential environmental impacts, which also include significant impacts to water quality, groundwater resources and wildlife habitat. These impacts are not only harmful to the community directly, but they are in direct conflict with the state’s climate agenda. So where does the Idaho-Maryland Mine project fit in to the broader context of our state’s climate change goals, and where should we go from here? In 2022 alone, building on the work of years’ past, California enacted a sweeping portfolio of new climate laws, ranging from codifying the state’s long-term climate goal of achieving net-zero GHGs by 2045, to prioritizing clean electricity, to enacting a strong state budget that prioritizes tens of billions of dollars in climate spending – referred to as the “California Climate Commitment.” From building regional climate resilience, to transitioning our state’s workforce to a carbon-neutral economy, to decarbonizing buildings, to prioritizing zero-emission vehicles, all while responding to wildfires, drought, and other catastrophic climate events – forward-thinking climate action is and has been at the forefront of decision making in California. The bottom line is that the Idaho-Maryland Mine simply doesn’t have a place on the state’s path to a cleaner, greener economy, and California simply can’t afford to be set backwards in its intentional fight against climate change. Reopening a toxic mine with significant environmental impacts for the benefit of very few is simply not a risk worth taking, particularly as we consider our role in the larger fight against climate change in California. Every policy decision is a chance to do better for our communities and our environment. That is why our community is relying on our local government and its leadership to do the right thing and reject the reopening of the Idaho-Maryland Mine. Join us in person at the Nevada County Planning Commission hearing on Wednesday, May 10 at 9:00 AM at the Eric Rood Administrative Center, at 950 Maidu Avenue in Nevada City, California, to let our local government officials know this project is wrong for our community and for California. Gianna Setoudeh, Policy Director, South Yuba River Citizens League

"The World Gold Council says there is about 208,874 metric tonnes of gold already above ground, [largely] sitting in vaults, doing absolutely nothing except making bankers feel warm and fuzzy." Excerpt from a letter to the editor of the Union newspaper by Peter Burnes, Grass Valley April 21, 2023 The World Gold Council says there is about 208,874 metric tonnes of gold already above ground, most of it sitting in vaults, doing absolutely nothing except making bankers feel warm and fuzzy. The same source indicates that the annual demand for gold for actual technological use has hovered around 330 metric tonnes per year over the last decade. Based on this authoritative data, there is already enough gold lying around for over 600 years of technology ‘need’ for gold. Someone please tell me why we need to dig up more gold? And if you own gold as an investment, wouldn’t it be logical to be an absolute opponent of all gold mining? There is no need for any more gold mining anywhere, least of all here in Grass Valley. Peter Burnes, Grass Valley Read the rest of the article online at The Union.

"Putting gold back into “Gold Country” seems favorably nostalgic, but has unforeseen far-reaching repercussions. Is the town prepared to expand? More importantly, does Grass Valley want to?" Excerpts from a Union opinion piece by David Briceno, Grass Valley April 15, 2023 In this article David discusses the following possibly detrimental consequences if the Rise Gold mine project gets the official go-ahead from the Nevada County Board of Supervisors: Possible exposure to hazardous-to-health heavy metals that can pose serious medical risks. Water supplies will be affected. Operations can even adversely affect local wildlife over the mine’s roughly 175-acre surface area. The bulk of the mining work would extend throughout unseen labyrinths. The company will own all mineral rights: no gold for townsfolk. Noise pollution and minute toxic dust particles due to increased traffic from trucks hauling out chunks of worthless rock waste to dump. If Rise fails, who pays cleanup for all contamination? Mining is ranked among one of the most dangerous professions: Freak accidents occur with risks of injury, disabilities and fatalities. Rise touts the project will generate “hundreds of jobs”. However there’s no guarantee locals will be mostly hired, which raises the question of where’s everybody going to live. Commute? The region routinely experiences housing shortages. Immediate neighborhood property values could plummet. A large growth in population may result in housing prices, cost of living, and property taxes increasing and quality of life decreasing. Read the rest of the article online at The Union.

CEA Foundation, San Juan Ridge Taxpayers Association, and The Wells Coalition (a group of well owners near the Idaho-Maryland Mine), presented a series of five public comments to Nevada County Planning Commissioners in January 12, 2023. Additional Wells Coalition comments and handouts were presented to the Supervisors on April 18. Pick a topic of interest below to skip to a comment, or download the PDF packet January 12. CEA Foundation: Groundwater Baseline Requirements in the EIR, a Legal Perspective Wells Coalition: Overview Wells Coalition: Groundwater Hydrology Uncertainty Wells Coalition: Well Owner's Perspective San Juan Ridge Taxpayers Association: Baseline Monitoring and the County's History on San Juan Ridge Additional Comments, April 18 6. Final EIR for the Idaho-Maryland Mine Unacceptable for Well Owners Attachments: Wells Coalition Group Full-Length Letter Preview (PDF) Understand the Gaps Handout (PDF) Read The Union newspaper's coverage. Without water, my property is worthless:’ Well owners want protection from Rise Gold Grass Valley' ‘Hung out to dry’: Well owners contend with Idaho-Maryland Mine report’s findings Ideas and Opinions: Christy Hubbard: Wake up call for well owners near mine 'Understanding the gaps': Local well owners organize in advance of May meeting on proposed mine reopening 1. Groundwater Baseline Requirements in the EIR, a Legal Perspective Groundwater Baseline Requirements and the Idaho-Maryland Mine EIR Presented as Public Comment to the Planning Commission Jan 12, 2023 The California Environmental Quality Act (CEQA) does not allow the deferral of important studies necessary to characterize a project’s impacts. According to CEQA Guidelines § 15125(a), an Environmental Impact Report (EIR) must include an accurate description of a project’s environmental setting, which provides “the baseline physical conditions by which a lead agency determines whether an impact is significant.”[1] It goes on to state: this baseline “should describe physical environmental conditions as they exist at the time the notice of preparation is published.”[2] (i.e. before the Draft EIR is prepared.) The purpose of this requirement is, per CEQA Guidelines, “to give the public and decision makers the most accurate and understandable picture practically possible of the project’s likely near-term and long-term impacts.”[3] And the court case of Save Our Peninsula Com. v. Monterey County Bd. of Supervisors (2001) affirmed that point: “Without a determination and description of the existing physical conditions on the property at the start of the environmental review process, the EIR cannot provide a meaningful assessment of the environmental impacts of the proposed project.”[4] Note that the Rise Gold project Final EIR clearly acknowledges that this baseline is needed. It states that for each domestic well, a projected and seasonally averaged water level shall be estimated “...which will serve as a baseline groundwater level.”[5] But this incorrectly defers the collection of the needed additional groundwater data to after the EIR process is over. Let’s look at it using common sense. Unless the EIR identifies current well levels and related data, it cannot establish performance criteria and evaluate how dewatering may impact wells, and it’s not possible to define appropriate mitigations. For example, Rise Gold’s hydrology model estimates that water levels will drop between 1-10 feet for over 150 wells. But there is no current data that could tell what the impact would be to well owners. A two foot drop could be critical. How would that be determined? Are some wells near failure? We don’t know. CEQA law, County precedents, and common sense all say the same thing: Collection of the well data should have been included in the Draft EIR, not deferred until after the CEQA decision has been made. Current domestic well monitoring data should have been collected and included in the EIR to establish a baseline so that it can be reviewed and then used in the decision making process. The County has ignored this critical step and released an inadequate Final EIR. Thank you. ///References/// [1] CEQA Guidelines § 15125(a), https://casetext.com/regulation/california-code-of-regulations/title-14-natural-resources/division-6-resources-agency/chapter-3-guidelines-for-implementation-of-the-california-environmental-quality-act/article-9-contents-of-environmental-impact-reports/section-15125-environmental-setting -Refer to complete comments provided by Shute, Mihaly & Weinberger: https://www.cea-nc.org/wp-content/uploads/2022/04/SMW_FinalComments.pdf , pgs 15-23. [2] Ibid. [3] Ibid. [4] See https://casetext.com/case/save-our-peninsula-v-monterey-county [5] Idaho-Maryland Mine Draft EIR 4.8-2(a) -(4), pg 4.8-67, https://www.nevadacountyca.gov/DocumentCenter/View/41605/48_Hydrology-and-Water-Quality 2. Wells Coalition: Overview Subject: Protection for Wells Near Idaho-Maryland Mine Still Not Adequate The Wells Coalition is a group of well owners near the Idaho-Maryland Mine. Our purpose is to protect our only source of water, our wells. We are astounded that a comprehensive domestic well monitoring program was not established before the Draft EIR was published last year. Such a program is a necessary step to establishing the baseline data required by CEQA. It’s clear that this omission was recognized in the Final EIR, but the proposed solution is little more than a band-aid that doesn’t actually address the serious, underlying problem. Even though there are over 300 properties with wells within 1000 feet of the Mine’s mineral rights area, neither the draft nor final EIRs provided current monitoring data from these domestic wells. They relied only on sparse patches of data from over 15 years ago. The quality of this input data is one of many concerns identified by numerous experts who contradicted the findings of the Draft EIR’s groundwater study in their written comments. The EIR’s primary approach is to install fifteen non-domestic monitoring wells over a limited area to do the job of predicting impacts for all water supply wells. With our complex fractured bedrock spread over thousands of acres, this approach is inadequate. This is further complicated by the fact that the estimated area of potential impact is based on the findings of a questionable study. In addition, the 378 properties identified in the Final EIR’s supplemental domestic well monitoring program only capture about 150 of the 300 plus wells in the mineral rights area. Timing of baseline data collection, however, is really the central issue. CEQA requires that a baseline be established prior to the evaluation of potential impacts. This was not done. With mine dewatering, previous dry years, and drought still predicted for the future, it is imperative that we get this right. Adding a well monitoring program after the project is approved and just one year before the mine is dewatered - as the Final EIR proposes - is not only out of compliance with CEQA, but is also extremely shortsighted and risky. Multiple experts provided comments telling us that it takes a minimum of 3 years to establish a reliable baseline in order to account for year-over-year variations. Also, under CEQA a mitigation measure must be achievable, enforceable, and must be capable of actually reducing the Project’s impacts. The Final EIR’s supplemental domestic well monitoring program is not even defined as a mitigation. Not having a baseline established by a properly constructed domestic well monitoring program before publishing a Final EIR is unacceptable. Our wells are not currently being monitored. Since it will take several years for Rise Gold to establish a reliable baseline, we request the current EIR be rejected and that any future EIRs include at least 3 years of comprehensive well monitoring data. Sincerely, Christy Hubbard (District 3 resident) The Wells Coalition wells@cea-nc.org 3. Groundwater Hydrology Uncertainty Subject: the Idaho-Maryland Mine Final EIR groundwater hydrological model predictions and risk to domestic wells in the area of the Project. The proposed well mitigations in the Final EIR for Rise Gold fail to acknowledge that there are significant risks posed to domestic wells in the surrounding area of the Idaho-Maryland Mine project, and it does not comply with CEQA. The Final EIR for Rise Gold states: “ All potentially impacted wells are located in the E. Bennett Road area. Domestic water wells outside this area will not be impacted.” [1] But expert opinions contradict the certainty of these statements, citing repeatedly the uncertainties in hydrologic predictions and impacts to wells: Emgold’s 2008 DEIR for the Idaho-Maryland Mine states “Due to the uncertainties regarding the complex geology and groundwater flow, dewatering impacts to domestic water supply wells cannot be accurately predicted.” [2] Also, Emgold’s project description states “The geologic formation in which the mine is located is fractured bedrock whose hydrogeology is difficult to predict. Therefore, reliance on Domestic Well Level Monitoring Program data will be required to assess impacts and discern appropriate mitigation measures for each domestic well owner.” [3] After reviewing the hydrology computer model from the EIR for Rise Gold an expert hydrogeologist in groundwater modeling stated “Even a well calibrated model has a large uncertainty to it, in its predictions. It turns out that this model is not well calibrated, so the uncertainties are almost certainly larger.” [4] The hydrology report for the Idaho-Maryland Mine’s 2008 EIR affirms the uncertainty in predicting whether ground water from near surface well waters may drain down into the deeper mine workings. “The groundwater in this particular area is contained in and flows through fractures in near surface bedrock and because of this fracture flow regime, the groundwater flow in quantity varies considerably with location and cannot be predicted with certainty. Furthermore, complete hydraulic separation between the deeper groundwater within the underground mine workings and the shallow groundwater within fractures and supplying the domestic wells cannot be assumed.”[9] Even the hydrologist who prepared the hydrology computer model for the EIR, told the NID board of directors. “With fractured rock there will always be uncertainty and during my career there won’t be any 100% confidence in predictions.”[5] It is because of these uncertainties that we are appealing to you to require protection for all wells with a comprehensive well monitoring plan for at least 3 years to gather baseline data to be used in a revised EIR. Thank You, Gary Pierazzi The Wells Coalition wells@cea-nc.org PS. Additional expert opinion quotes regarding uncertainties in groundwater modeling and fractured rock. ______________________________________________________________________________ “The EMKO Report describes a three-step procedure used to assess potential drawdown effects in perimeter areas. A major assumption underlying the procedure is that flow contributions from the workings are distributed uniformly across the mining areas after correcting for depth. However, the subsurface distribution and orientation of bedrock fractures is not uniform and is subject to uncertainty. Discussion of this uncertainty and the overall uncertainty of the analytical and numerical model predictions with respect to groundwater level impacts on individual wells should be provided. expanded to include an assessment of the uncertainty in the conclusions developed by Todd Engineers.”[6] “Although the analysis is considered conservative in methodology, several complexities in the groundwater system could potentially result in a larger or smaller radius of influence. Although larger impacts seem unlikely, it is difficult to prove that aberrations in the system do not exist.” [9] “Uncertainties in the analysis indicate that monitoring should occur over a slightly larger area than where impacts are predicted. In addition, the monitoring program should consider adjustments specifically for geologic faulting.” [7] “Monitoring locations should also include areas outside of the predicted impact zone to account for uncertainties in the analysis,” [7] “The fracture systems existing in buried bedrock beneath Grass Valley are not mappable within the resolution needed to predict specific dewatering effects. Technology and state-of-the-art hydrogeology have not developed to a level that fracture mapping is possible. Due to this limitation, hydrogeologic modeling is attempted by making an assumption on fracture connectivity.” [8] “Based upon the significance criteria established on page 4.3-4, the risk to all wells within the study area, regardless of risk category, represent a potentially significant impact.” [10] “The study area has not been monitored by an approved groundwater monitoring system designed to observe the dynamics associated with subsurface hydrology. Therefore, many of the initial unknown hydrogeologic and geologic parameters located within the earth between well and mine elevations still exist.” ———————————————— footnotes —————————————————— [1] Idaho Maryland Mine Project FEIR, December 2022, Volume VII, Appendix D, Page 2. [2] Idaho-Maryland Mine Project Draft EIR (2008) p4.7-34 [3] Idaho-Maryland Mine Project, Revised Project Description (May 2011) Appendix N-T-3 [4] June Oberdorfer, PhD, PD, Certified Hydrogeologist (CHG), Review of the March 2020 EMKO Groundwater Hydrology Report, Minewatch Virtual Community Meeting Video Presentation (October 2021) [5] Houmau Liu, hydrologist for Itasca, February 9, 2022 NID board of directors meeting. [6] Appendix K.7 West/Yost Peer Review (August 27, 2020), p8-9, p18, Idaho-Maryland Mine Draft DEIR (December 2021) [7] Todd Engineers (2007), Final Report Hydrogeologic Assessment Idaho-Maryland Mine, prepared for Idaho-Maryland Mining Corporation, August t.p22, p25, p26 [6] Idaho-Maryland Mine Project Draft EIR (2008) p4.7-34 [8] Steve Baker, Certified Hydrogeologist, Response Comment Letter to 2008 Idaho Maryland Mine DEIR [9] Idaho-Maryland Mine Project Draft EIR (October 2008) 4.8 Hydrology and Water Quality, p 4.7.29 [10] Draft Environment Impact Report for The Idaho-Maryland Mine (May 1995) p4.3-5 4. Well Owner's Perspective - Without Water, My Property Is Worthless I’m a resident & well owner in district 1. I can appreciate the inclusion of a well monitoring program in the FEIR, but it falls significantly short of what we really need. I should not have to beg for protection from the county to keep our sacred resource safe. Our well is amazing! It provides safety from wildfires by allowing us to maintain green space. It keeps my family and pets healthy and happy. Just imagine what you would do if the water in your own home suddenly vanished. Your spouse and kids, asking what’s wrong with the water? Oh my god! Without water my property is worthless! How could this have happened? Where is the protection from my county? Experts have weighed in on the amount of monitoring time necessary to obtain a dependable baseline. In some cases, 3 years is not even enough. It’s also a stretch to accept a program that is deficient in infrastructure to replace my water resource if it becomes damaged? As I read the details, I would be subject to some sort of nebulous negotiations with Rise Gold to get my water connected to NID. Would this make you feel protected? To be forced to deal with a CEO that has demonstrated severe environmental failures in Canada, and spreads contrary information through press releases and interviews, stating, “there will be no impacts”, or, “the community overwhelmingly supports the project”? I should not be required to compromise or negotiate when it comes to an intruder causing harm to my family and home. None of the hundreds of well owners asked for this. None of us would be the recipient of any benefit whatsoever. We need complete protection from this potential catastrophe, with a comprehensive well monitoring program that is designed around the adequate years necessary to produce dependable data. This data should have been obtained before the DEIR, according to CEQA. This program must also lay out, in specific details, the transfer to an equal replacement water source, with all necessary infrastructure in place, and independent from Rise Gold for immediate implementation when a well fails. Our stress levels are off the charts dealing with these potential consequences, including financial ruin and loss of our nest egg. The fact that I must beg for protection in 3 minutes here is just as stressful. No one here today would accept even the tiniest risk that they could lose their water in exchange for gold in the pockets of strangers. I implore the board reject this FEIR and take everything back to the drawing board with our protection as top priority. Tony & Lauren Lauria 5. Baseline Monitoring and the County's History on San Juan Ridge My name is Sol Henson, I grew up on the San Juan Ridge and hold a master's degree in hydrology. I am the president of the San Juan Ridge Taxpayers Association and speak for the Association today. I'm here to talk about the importance of baseline monitoring for wells to protect our community from industrial mining impacts. In 1995 Siskon Gold operated a gold mine in the North Columbia Diggings on the San Juan Ridge. During mining operations, they breached a water bearing fault-line 300 feet underground. This breach led to the loss of nearly a dozen wells including the well for our middle school and the community Cultural Center. This was a disaster for those who lost their wells, but we still do not know the extent of well impacts. Some wells may have lost 50% or even 75% capacity but without baseline data, owners could not prove that the mine had impacted their wells. This was a single catastrophic event. Wells are more commonly impacted by the extraordinary amount of water pumped out of mine tunnels just to maintain daily industrial mining operations. Over time, millions of gallons of water a day must be removed from the surrounding fractured bedrock aquifer. In such cases, well impacts can be slow to develop and can be hidden within seasonal cycles. In 2012, the San Juan Ridge Mine Corporation submitted a new permit application to mine the North Columbia Diggings. Exhibiting due diligence, and with community input, the County helped to create a baseline monitoring program for domestic wells. This program established a baseline through monthly collection of water quantity and quality data. This information would have been invaluable for the environmental review process. Should the mine have been permitted, well owners would have had recourse to say with some confidence if their well had been impacted. We firmly support the precedent of baseline monitoring for projects of such scale and impact as the Idaho Maryland Mine. Significant monitoring programs have been developed in the past for the IMM site, including for the 1996 permit to dewater the mine for exploration and the 2008 Emgold Mine environmental review process. It is unclear why the current Rise Gold effort to permit the IMM lacks a monitoring plan that would form a baseline for water quantity and quality of domestic wells in the surrounding area. We believe that the community is owed these safeguards and that CEQA requires it. Thank you very much. Sincerely, Sol Henson President of the San Juan Ridge Taxpayer's Association Additional Comments - April 18, 2023 6. Subject: Final EIR for the Idaho-Maryland Mine Unacceptable for Well Owners The Wells Coalition is a group of property/well owners and residents near the Idaho-Maryland Mine. Our purpose is to protect our only source of water, our wells. We shared our concerns with you about the mine during public comment on December 13th. This was just a few days before the Final EIR was released. All the arguments we shared with you then are all still valid – but there is more to say now. Today, we’re here to formally ask you to REJECT the FEIR and VOTE NO on the project. Huge risks are not being addressed, posing a very real threat to our local groundwater resources and property values. The Final EIR asserts that stronger mitigations and/or financial assurances are “not necessary because no significant impact to domestic water wells are predicted”. But a “prediction” is only an educated guess – NOT a certainty. And in this case, it is based on an analysis that has serious flaws. The stakes are too high to get this wrong. The County’s Economic Impact Report revealed this mine proposal is unprecedented in its proximity to so many homes. Pumping over a million gallons a day from an area with hundreds of wells is a huge risk. If “predictions” are wrong, it could cost the County, NID, and individual homeowners tens of millions of dollars – and years or decades – to connect a permanent water supply to each property. Claiming “no significant impact” defies both science and common sense. In Draft EIR comments, multiple hydrology experts confirmed that groundwater models in fractured bedrock like ours can NOT deliver 100% certainty. They also revealed numerous defects in the groundwater model. The Final EIR dismissed these concerns, but then – in contradictory fashion – agreed that more data is needed for validating the model. Without current well monitoring data, the FEIR’s “threshold of significance” is invalid. The FEIR lacks current well performance baseline data and is inadequate under CEQA. The FEIR relies only on sparse patches of data from 15 years ago. Baseline data is needed to assess potential impacts to groundwater and well owners prior to determining mitigations. It is also the lynchpin in determining what threshold should be used to determine the measure of “significance”. The FEIR sets that threshold at a 10% drawdown in water level, but legal experts call that number “arbitrary” and “invalid”. The FEIR’s addition of a Domestic Well Monitoring Program for 378 properties is a feeble attempt to address the issue, but it’s too little, too late, too short, and it’s not even a mitigation. [Added in spoken comments: We’ll be leaving you a preview copy of our full group comment letter, plus a 2-page handout called “Understand the Gaps” that says a lot more about this.] The Final EIR states that the applicant is in compliance with the County General Plan requirement that “provides for protection of domestic water wells from potential mining impacts” and “ to guarantee a comparable supply of water to such homes or businesses” but the FEIR does not demonstrate or even discuss how or if the Applicant can meet the County requirements. Other than the proposed 30 NID connections along East Bennett Rd, THERE IS NO MITIGATION PLAN IN THE FEIR FOR CONNECTING IMPACTED WELLS TO NID WATER SERVICE. That means: • No additional wells identified as needing mitigation • No water supply assessment • No infrastructure design plans • No permitting, acquiring easements, or rights-of-way • No timetable But most importantly, No financial assurances for design construction and bringing service to impacted well owners. NID has asked for a $14 million dollar bond but the FEIR dismisses the request, stating “A bond for construction of water supply infrastructure in this area is not necessary”. This is a recipe for disaster. Today’s NID projects take many years to complete, but a failure in this project could create a large-scale crisis for NID, the County, and especially homeowners. People will scream “where’s my water?”. And a property with no permanent water supply is worthless. The FEIR is also striking in its absence of accountability. It describes steps for fixing wells or providing temporary water, but all decisions are left solely up to the mine operator, who would take action only if the 15 monitoring wells in the official Groundwater Monitoring Plan flag an impact. This is especially concerning because the complexity of the fractured bedrock geology in the area may mask impacts. With the impact threshold arbitrarily set at a 10% drawdown, homeowners with marginal wells may lose water long before they get a call from the mine operator. What’s missing here is a separate oversight committee or commission authorized to make decisions. They would make determinations of impact to well owners, resolve disputes, provide professional analysis and reporting of data regarding the monitoring, assure timely execution of mitigations, and administer fines or corrective notices. The bottom line is that well owners are being told to trust that nothing will go wrong with their water supply for 80 years based on assumptions and speculation. The Wells Coalition is asking the County to REJECT the FEIR and VOTE NO on the project. Thank you, Christy Hubbard (District 3) and Gary Pierazzi (District 3) The Wells Coalition wells@cea-nc.org bit.ly/wells-coalition Attachments (includes full four-page comment letter with citations, plus a 2-page handout providing an at-a-glance view of the the FEIR's claim vs. gaps.

This opinion piece was originally published in The Union. April 19. 2023 Since the beginning of 2022, like many other local people, I’ve spent a LOT of time studying the environmental and economic reports for the proposed Idaho-Maryland Mine. I’ve spoken to the primary author of the economic report and made comments to Planning Commissioners and Supervisors. I’ve participated as a panelist at the MineWatch Community Review of the County’s Economic Impact Report. Click this link for the video (http://bit.ly/MW-Economic-Review). In short, I’ve had a great deal of time to think about what Rise Gold’s mine proposal is really about – and what’s it’s NOT about. The issues with Rise Gold’s proposal ARE NOT ABOUT: Whether Rise’s production, revenue and cost estimates have any basis in current, provable measurements or industry standards (they do not). Whether the consultant who prepared the Economic Report did a good job (they did…but critical parts of the input came from Rise Gold). Whether our elected representatives and the people who work at Nevada County are doing their jobs and care about this community (they are and they do). Whether there would be some economic benefit (there may be, although best case the benefits are half of what is projected in the Economic Report and there is no consideration of risks). Whether the economic reports include all the costs or the cost of risk (they do not). Whether the Rise Gold profits shown in the Economic Report are overstated which inflates County benefits (they are and they do). Whether some of the Final Environmental Impact Report (EIR) responses demonstrate a bias towards Rise Gold (they do). The issues with Rise’s proposal ARE ABOUT what RISK we, and our elected representatives, are willing to accept in trade for jobs and County revenue. Over 5,500 individuals and 250 business owners signed petitions and/or wrote letters to the Supervisors opposing the mine. 95% of the letters and opinions pieces on the topic in The Union newspaper have been opposed to the mine. The vast majority of the opposition to the Rise Gold proposal are thoughtful people who have done their homework, who care about this community and are committed to a better future outcome than what Rise proposes. If you study the EIR and the Economic Reports you will find risks related to toxic mine waste, air and water pollution, well drawdown, property values, traffic, and many others. You will find the cost of those risks are not included in the economic analysis. You will find that local jobs, local spending and County revenue are inflated based solely on assumptions provided by Rise Gold. Are we willing to take the risks for 80 years? In trade for the possibility of more jobs and more County revenue: Are we willing to accept that some toxins may leak into our streams or water supply? Or a few wells go dry? Or that property values for many homeowners will go down? Or a few of our children or grandchildren or great grandchildren may have lung issues from “fugitive” asbestos dust? Or that County revenue will not even come close to the cost of fixing any number of potential environmental catastrophes? Or that local prices and housing costs will go up for everyone not working at the mine as a direct result of Rise’s inflated salaries? Don’t be fooled by wild claims of economic benefits and jobs and proposed mitigations. The data provided by Rise is designed to sell their story. It is not designed to show the facts. Please contact your Nevada County Supervisor and demand they “Just Say NO” to the Final EIR and the Rise Gold proposal. This link provides a set of facts and an easy way to submit a letter: https://www.minewatchnc.org/send-a-letter John Vaughan, Grass Valley

Please commit to involvement, first by imagining a noisy, messy, incompatible mine in operation in our quiet, small town; and second by joining your neighbors at the Planning Commission meeting on May 10 and 11. The following opinion piece was first published in The Union. Apr 13, 2023 Are you paying attention to the Idaho-Maryland Mine controversy? Do you understand what a mess re-opening this mine will make? Not might make; will make. The proposed mitigations are pitiful. The Economic and Environmental Reports are misleading and full of holes. Tune in to a group of your fellow citizens dedicating a pile of volunteer hours digging into the thousands of pages of misleading environmental details, incomplete data, and empty “fixes” for what an operating mine would spin-off. Their concerns? The negative impacts on Wolf Creek. Piles of toxic mine tailings. Continuous heavy truck traffic on Brunswick Road. Substantial damage to air quality from asbestos. Damage to wooded acres with healthy identified floral and bird species. Threats to local wells. And noise, lots of noise. What can you do to push our county’s decision-makers to say “NO!” to this backwards-looking project? First, mark your calendar: On May 10 (and likely May 11, too) plan on committing hours to attend a critical County Planning Commission meeting. Just attend. All or part. If you have something to say – three minutes – this is the time and place. Should Grass Valley revert to being a mining community? The Commission will recommend one way or the other, to proceed with this project or not, to the Board of Supervisors. Your presence at the Rood Center at 9 a.m. — or earlier if you have a comment — would be your worthy statement on our local quality of life. Second, as you drive around Brunswick Basin or on Whispering Pines (that road name would be meaningless if the mine opens … maybe, Toxic Dust Pines?) or out Brunswick Road by the mine site or along E. Bennett Road, picture the mine in full operation. Be aware of the sweet little So. Fork of Wolf Creek that runs through the mine site and along E. Bennett and the State Park’s meadow there. Picture toxic mine waste in the creek. Real estate for sale signs. Picture a truck full of tailings on your bumper. They’ll be dumping — thousands of cubic yards of toxic waste rock for a decade — in the Centennial site right there off Whispering Pines where the fire was. Kiss that whole area good-bye. Some of that site looks ugly now, but it is reclaimable — unless Rise Gold ruins it. Third, imagine you own property on E. Bennett, Brunswick Road, or Greenhorn … or you have a business along the trucking route. This mine project is right in your face. This is heavy, polluting industry in the middle of a peaceful residential part of a small town. People have wells. Nights are quiet. Folks commute or drive to schools safely on these roads. Bike riders cruise these routes. Kiss all that good-bye, too. The operation of a gold mine in town is so incompatible to our lifestyle that it’s a sad joke. A head-shaker. The current light industrial zoning designation is correct, proof that a mine does not belong here. Rise Gold — or whatever mining outfit from far away they sell the mine to — will blast and excavate and pile mine tailings in a huge, toxic mound visible from Brunswick Road. Folks on Greenhorn will get to hear the cacophony. These safe roads will change for the worse, will deteriorate under Rise Gold’s fleet of trucks. The surrounding neighborhoods will be next door to heavy industrial mining. The County’s General Plan will have to change to allow Heavy Industrial in this neighborhood. Please commit to involvement, first by imagining a noisy, messy, incompatible mine in operation in our quiet, small town; and second by joining your neighbors at the Planning Commission meeting on May 10 and 11. Each of us is represented by one of the Commissioners. We need these individuals to know what we think about our county’s bringing industrial scale gold mining into our neighborhoods. Our Planning Commissioners are preparing to make motions about the mine project and cast their votes. Join in on opposing this incompatible, impactful mining project. George Olive, Banner Mountain

Rise Grass Valley’s advertising boasts the mine’s “minimal environmental impacts.” That’s like saying the Donner Party suffered only ants at their picnic. This opinion piece was first published in The Union. Apr 12, 2023 Rise Grass Valley’s advertising boasts the mine’s “minimal environmental impacts.” That’s like saying the Donner Party suffered only ants at their picnic. Intent exclusively on churning our county for profit, RGV issues propaganda that disintegrates in the light of truth. The proposal’s Environmental Impact Report (EIR), however deficient in some areas, actually predicts devastating damage to our water, air, traffic, fire safety, health, and quality of life. According to RGV, for example, “The dewatering of the existing mine and new mining have very limited effect on the water table.” “Limited effect” for people who don’t live here, that is. No one can confidently say that the water table won’t significantly drop. Mining history is full of operators’ cheerful assurances, and equally full of exactly those disasters. The Siskon gold mine on San Juan Ridge is one example. In 1995 miners drilled into an unexpected fault. The subterranean water vanished, and wells as far as two miles away went dry. And south of here, in Jamestown, Tuolumne County taxpayers got stuck with a cleanup bill of $5 million when industrial gold miners left town after fouling 180 private wells with heavy metals. As for air quality, RGV promises “zero emission underground mining.” But at the surface, where most of us breathe, it’s a different story. The EIR states that mitigated (that is, best case scenario) air emissions will include 105 lbs of known poisons and carcinogens daily during the first year of operation. The Report says that amount isn’t significant, but fails to calculate that over the mine’s eighty-year operation it will emit 3,600 tons of these poisons, not including 200,000 annual minutes of diesel idling. The California Air Resources Board estimates that 70% of our risk of getting cancer from what we inhale comes from diesel exhaust. Children will be especially affected, as they’ll breathe these poisons their whole lives. How about noise? Don’t worry, says RGV, it won’t be significant. A renowned acoustics consultant, Salter Associates, disagrees: “...nighttime industrial activities amongst a community that currently enjoys low ambient noise levels represents a significant risk for project noise to impact the community, annoy residents, and cause sleep disturbance.” RGV is embarrassingly revealing in what its misleading ads fail to say. RGV doesn’t mention, for example, that it will pump 3.6 million gallons of mine water daily into Wolf Creek for 6 months, then 1.2 million gallons daily until 2102. It doesn’t mention blasting 1,900 lbs of explosives beneath Grass Valley every day. Salter Associates states, “...strongly perceptible and borderline unpleasant vibration on a regular basis for the rest of [residents’] lives should be considered a significant impact.” RGV admits that its tailing-hauling trucks — 20-ton mammoths — will run every 20 minutes, 16 hours every day, but that’s only one way; presumably they’ll return, too. It doesn’t disclose that its emission of carbon dioxide, a major greenhouse gas, will exceed 16 million lbs every year. A car would need to drive 1,600 years to emit that amount. Nor do RGV ads mention asbestos, the vicious carcinogen assumed to lurk in the mine’s rock. Shorter asbestos fibers, which are difficult to detect, carry a high risk of malignant mesothelioma. Since the Northern Sierra Air Quality Management District isn’t equipped to monitor shorter fibers, asbestos tests on tailings of 1,000 tons daily will necessarily be done elsewhere, a two-week turnaround. There’s no plan for storing this material in the interim. RGV fails to state that the mine would nullify Nevada County’s Energy Action Plan, which calls for a reduction of roughly the same amount of electricity that the mine will use every year. Astoundingly, RGV claims with a straight face that the project enjoys strong local support. Quite the contrary. RGV’s clumsily biased “surveys” grossly misrepresent results, even including as “supporters” residents who are publicly vocal opponents. At a 2022 Planning Commission meeting, 100 residents spoke knowledgeably and passionately against the proposal, with only a single speaker favoring it. And if the mine will truly deliver the prosperity RGV claims, why has not a single business entity declared support for it — not a Chamber of Commerce, not the Economic Resource Council, not the Downtown Association, not the Board of Realtors. The Environmental Impact Report should not be certified, as it ignores significant threats. But even in its inadequacy, it predicts devastation of our community. We urge residents to attend the Nevada County Planning Commission hearings May 10 and 11, and oppose certifying the EIR. Sometime after that our five county supervisors will decide whether to permit the mine. We doubt any of our supervisors wholeheartedly support the proposal. If they oppose it, their hand will be strengthened by a massive attendance of citizens at both hearings. Yasha Aginsky Rob Agrimonti Charlie Brock Jeff Gold Jeff Kane Scott Kellermann Brad Miller Randall Newsome Kathy Ogburn Tim Ogburn Rondal Snodgrass

If you own a well near the Idaho-Maryland Mine, you should be deeply concerned. The proposed operation poses a serious threat to our local groundwater and our pocketbooks. This opinion piece was originally published in The Union. April 6, 2023 The Wells Coalition – a group of well owners near the Idaho-Maryland Mine – has completed its review of the Final Environmental Impact Report (FEIR). We are deeply concerned about the proposed reopening of the mine. If you own a well near it – you should be too. The proposed operation poses a serious threat to our local groundwater resources and our pocketbooks. 100% certainty is a myth: The FEIR asserts that stronger mitigations and/or financial assurances are “not necessary because no significant impact to domestic water wells are predicted”. But a “prediction” is only an educated guess – NOT a certainty. In this case, it is based on an analysis that has serious flaws. The stakes are too high to get this wrong. The County’s Economic Impact Report revealed this mine proposal is unprecedented in its proximity to so many homes. Pumping over a million gallons a day from an area with hundreds of wells is a huge risk. If “predictions” are wrong, it could cost the County, NID, and individual homeowners tens of millions of dollars – and years or decades – to connect a permanent water supply to each property. Claiming “no significant impact” defies both science and common sense. Predictions of the groundwater model have limited reliability: In Draft EIR comments, multiple hydrology experts confirmed groundwater models in fractured bedrock like ours can NOT deliver 100% certainty. They also revealed numerous defects in the groundwater model. The Final EIR dismissed these concerns, but – in contradictory fashion – agreed more data is needed for validating the model. Without current well monitoring data, the FEIR’s “threshold of significance” is invalid: The FEIR lacks current well performance baseline data and is inadequate under the California Environmental Quality Act (CEQA). The FEIR relies only on sparse patches of data from 15 years ago. Baseline data is needed to assess potential impacts to groundwater and well owners prior to determining mitigations. It is also the lynchpin in determining what threshold should be used to determine the measure of “significance”. The FEIR sets that threshold at a 10% drawdown in water level, but legal experts call that number “arbitrary” and “invalid”. The FEIR’s addition of a Domestic Well Monitoring Program for 378 properties is a feeble attempt to address the issue, but it collects data after the fact, doesn’t last long enough, and excludes wells in NID-served areas. Toothless mitigations mean serious risk for well owners: Other than 30 properties on E. Bennett Road, there are no plans or financial assurances for connecting to NID if wells are rendered useless. NID asked for a $14M bond to cover costs if wells fail, but the FEIR dismissed it, insisting NID needs nothing. That means no bond, no water supply assessment, no design plans, and no easements. This is a recipe for disaster. Today’s NID projects take years to complete, but a failure in this project would create a large-scale crisis for NID, the County, and especially homeowners. Costs could run into $10’s of millions as people scream “where’s my water?”. And a property with no permanent water supply is worthless. The FEIR is striking in its absence of accountability. It describes steps for fixing wells or providing temporary water, but all decisions are left solely up to the mine operator, who would take action only if the 15 monitoring well locations in the official Groundwater Monitoring Program flag an impact. This is especially concerning because the complexity of the fractured bedrock geology in the area may mask impacts. With the impact threshold arbitrarily set at a 10% drawdown, homeowners with marginal wells may lose water long before they get a call from the mine operator. The bottom line is well owners are being told to trust that nothing will go wrong with their water supply for 80 years based on assumptions and speculation. The Wells Coalition is asking the County to REJECT the FEIR for the Idaho-Maryland Mine and VOTE NO on the project. If you’re a well owner whose property is within a ½ mile of the mine’s mineral rights area bit.ly/mineral-rights, consider joining the Wells Coalition to make a bigger impact on County decision makers. Visit The Wells Coalition website or send an email to wells@cea-nc.org to learn more. Christy Hubbard, Grass Valley

Rise Gold wants approval for their project, so they tell three main stories: One about jobs, another about economics, and a third about environmental impact. The key is that very few people reading the stories compare one to the other — or to the detailed data underneath them The following opinion piece was originally published in The Union. April 8, 2023 What’s happening with the Rise Gold proposal is a story about stories. Rise wants approval for their project, so they tell three main stories: One about jobs, another about economics, and a third about environmental impact. For Rise, the key is that very few people reading the stories compare one to the other — or to the detailed data underneath them. JOBS – Big promises that don’t hold up when you look closely The jobs story is designed to attract workers with the large dollars being offered in Rise’s marketing program. Virtually none of the locally recruited jobs at Rise are available anytime soon. Construction will take at least 3 years (based on Rise assertions) and up to 6-10 years (based on industry averages). Most of the local hires will work 2,300ft or more underground for 12 hours/shift for 4 days on/4 days off (the story recently changed from 7days on/7days off to 4). The jobs story doesn’t talk about the negative effects of 12 hours shifts, working graveyard, or missing time with your family because you effectively have a single parent household for half the year. The math in Rise’s promotional materials does not add up. For instance, the Underground Mining jobs in Table 2 show annual wages much higher than the same jobs in Table 3. The introduction even says: “Actual wages during operations are subject to applicant experience and labor market conditions.” The bottom line is that even if the annual dollars look good, what is being offered is a long way from “good jobs”. ECONOMICS – Presenting best case scenarios to sell the deal The economic story is based solely on data provided by Rise. That data shows Rise costs to produce an ounce of gold are half of the industry average, which leads to low expenses. When you have low expenses, you can show high profits. High profits make the contribution to the County General Fund look good. As long as you don’t compare the numbers provided by Rise to standard financial reporting, or industry averages, or other gold mining operations, the data appears to make sense. Not so much when you study the numbers. Rise wants the jobs part of the story to focus on annual wages, so they summarized information from a report by The World Gold Council (WGC). However, the WGC report also says: “...higher wages due to the presence of a mine can lead to price inflation for housing, food and essential services in the mine’s vicinity, leaving workers and households who are not part of the supply chain with lower purchasing power.” So, virtually everyone not working at Rise is negatively impacted for 80 years. ENVIRONMENT – Hiding behind compliance standards and weak excuses The environmental story is similar, promising that nothing bad will happen at any time for any reason for 80 years. This story also includes “mitigations” where something actually is bad but is modified to make it less bad than some arbitrary standard. It’s still much worse than it was before the mine, but the story says you are supposed to be ok with that. For this story, Agencies, Groups and individual commenters on the Draft EIR have been met with aggressive, arguably biased, responses in the Final EIR. These responses often claim that Draft EIR comments are speculation or responds with some form of “we can’t afford to do it that way” when an alternative is proposed, or an additional mitigation is requested. As long as you don’t study the asbestos controls, waste rock disposal, diesel emissions, many other inadequate responses, or the economics of “we can’t afford it”, the story holds water. Not so much when you look at the data. TAKEN TOGETHER – A huge negative impact for Nevada County Taken individually, some parts of each story seem to make sense. Taken together, the only story that really matters is one of a huge negative impact on the future of Nevada County. Please contact your Nevada County Supervisor and demand they “Just Say NO” to the Final EIR and Rise Gold proposal. This link provides a set of facts and an easy way to submit a letter: https://www.minewatchnc.org/send-a-letter. Bob Hubbard, Grass Valley

This concerned resident asks County Supervisors to deny Rise Gold and instead focus on shepherding us into the 21st century with fitting and appropriate technology and infrastructure. This opinion piece was originally published in The Union. April 19, 2023 Dear Nevada County Supervisors and Planning Commissioners, I write to you as a very concerned resident of Nevada County to implore you to reject the re-opening of the Idaho-Maryland Mine. I live on Banner Mountain (District 1) and I am terrified of the consequences not only to me and my property, but to the community as a whole, if this mining operation is allowed. In a moment I will briefly summarize some of the significant reasons to reject the proposal, but you are no doubt familiar with those facts, so I wish to begin by something far more obvious and indisputable. That is, if you lie down with snakes you are going to get bit(ten). Rise, and its C.E.O., have a demonstrated track record of environmental carnage, broken contracts, and such. Rise Gold has never opened or operated a mine and has never made a profit. Their C.E.O.’s predecessor company polluted tribal waters, declared bankruptcy, and left responsibility for their cleanup to the Canadian citizens. Their C.E.O. is currently on trial on charges relating to toxic spills in current operations. Why would anyone in their right mind consider doing business with persons or institutions that can so predictably be counted on to compromise public health and cause economic crises and environmental destruction? The economic projections that Rise puts before you in support of their application are neither fact-based nor honest. They are, at most, happy-talk and unbounded optimism. Bear in mind that, “figures don’t lie, but liars often figure.” So is the case here. Why would anyone consider exposing our community to the sacrifice of its character for the benefit of a Canadian company? The re-opening of the mine will cause significant and unavoidable impacts. The increased traffic (18 wheelers) and noise on Brunswick alone is reason enough to reject this proposal, and that traffic increase can neither be denied nor mitigated. The threats to water wells and air quality scream for denial of the application. You simply cannot pump 3.6 million gallons of polluted water every day for six months and another 1.2 million gallons per year for up to 80 years without creating health and environmental damages. The claim in the E.I.R. that this dewatering will not have significant impacts has to be recognized as the unmitigated horse pucky that it is. Our county’s air quality already gets failing marks. How can this not be exacerbated by fugitive dust from continuous rock crushing, hauling, and compacting that will release asbestos and silica particles, in addition to the output from hundreds of diesel trucks each day. Again, the E.I.R. drops the ball here, calling these inpacts, “less than significant.” Many residents, for miles around, will suffer reduced quality of life and diminished property values. The staggering amount of greenhouse gasses (more than 9000 metric tons annually) will contribute to our terminal problem of climate change – shame. There is NO demonstrable need to extract our subterranean gold. There is sufficient gold already in vaults to satisfy the legitimate needs of generations to come. This proposal is only justified by the profit motives and greed of outsiders, untrustworthy outsiders at that. As for the highly suspect predictions of economic benefits to our community, consider instead promoting high-speed, fiber-optic, Internet connectivity. Our area is a mecca for educated professionals fleeing major metropolitan areas to live in our bucolic paradise. But many of these people are working, or want to work, remotely, thus bringing economic benefits to our community with no negative impacts, environmental or otherwise. Why not support, instead, this area of economic growth that poses no downside? Please do not be hoodwinked by the dazzling but false claims by Rise Gold. Please do the right thing as officials we elected or appointed to lead and protect us in an honest and exemplary manner. Please deny Rise Gold and instead focus on shepherding us into the 21st century with fitting and appropriate technology and infrastructure. Thank you. Very truly yours, Peter N. Brewer

Local community member, David Brownstein, hopes our County Supervisors can sort out fact from fiction. I have long been concerned about the erosion of our democracy by the predominance of misinformation. It was bad enough when marketing of products was infused ad nauseum with false ads to sell us everything from bicycles to bath mats. But over the last decade the corruption has moved ever more into the political arena with a suffocating force. And now the clouds of misinformation are striking too close to home. I am speaking of – no surprise here – Rise Gold’s (aka Rise Grass Valley’s) proposed Idaho-Maryland Mine. Of late, throughout the media, we see the same promotional ads touting “Environmentally Responsible Mining.” Really? It’s time for some fact checks. Rise Gold claims “Environmentally Responsible Mining,” but the project operations will generate over 9000 tons per year of unmitigated Greenhouse Gas emissions for up to 80 years. Rise claims “Sustainable Mining for a Greener Future.” By definition mining is not sustainable, since it consumes and damages resources without replacing them...then the ore runs out and the mine closes. Proposing to “reinitiate underground mining...” after “...50 years of closure.” is a failure to get even the basic math right on a project that shut down in 1956. The Rise ads claim the “state-of-the-art facilities ensure that our initiatives won’t disturb the neighbors” but fails to mention that this project will dump mine waste into huge piles near housing, spreading, blending, grading, compacting the sand tailings and waste rock, creating noise, dust, and an eyesore, and for 80 years haul trucks will be passing by on average every 10 minutes. According to independent studies, most of the mine jobs will go to out-of-area experienced miners. For anyone local who is seeking a job, be aware that even Rise Gold’s own documents show at least 3 years before operations start, and any realistic analysis of the project puts it at more like 6-8 years. The project will hurt local real estate values and tourism will suffer. Rise uses the euphemism “Engineered Fill” for their mine waste, which is waste rock and fine sand tailings. They plan to sell it! There is no real market for mine waste, which must be sold as “Restricted Materials” due to asbestos. Rise may not even be allowed to ship it off-site due to arsenic and other contaminants, leaving the mine with no ability of operate. Rise has not provided any valid evidence to support the question in their survey: “Did you know that the majority of Nevada County residents support the reopening of the Idaho Mine?” Rise poses several similar clever questions about what people know...not about what is true...to influence the reader. Rise asks “Will the mine negatively impact Nevada County’s air quality?” and then doesn’t answer the question. The answer is yes. The mine will increase air pollution for 80 years of operation. Rise states “Will the mine accelerate climate change and global warming?” and again doesn’t actually answer the question. The answer is again yes. Comparing emissions with some unknown other projects does not change the reality of using energy equal to more than 5500 homes. No doubt, the mail-in post cards that are provided by Rise Gold will be used to further their claim that the majority of the county’s residents favor the mine. And for the uninformed, what the promotional ads say sounds so wonderful! How many will support the project based upon those misleading claims? Of course, the problem with selective polls is that mostly the people who favor the project would bother to return the mail in cards, which are sent to Rise first, allowing them to trash the hate mail. So if 50,000 people get the cards and even a few thousand mail them in, what does that really mean? Wouldn’t that mean that 47,000 people don’t support the mine? Think about it. Our Board of Supervisors are faced with a difficult decision. Let’s hope they can sort out fact from fiction. David Brownstein

The Final EIR doesn't have a viable plan for disposing of mine waste through off-site sales and its plans for on-site temporary storage and permanent disposal are seriously lacking - leading to potentially significant impacts on the community. March 20, 2023 Introduction The Idaho-Maryland Mine Final Environmental Impact Report (FEIR) does not provide adequate information regarding the viability of the plan to dispose of mine waste through off-site sales and does not have provisions for adequate on-site temporary storage or permanent disposal of mine waste, leading to potentially significant impacts. The project documents call for approximately 11 years of operations in which the mine waste will be disposed of on the Centennial and Brunswick sites as “Engineered Fill,” but the FEIR fails to resolve uncertainties affecting the viability of that plan. Due to inadequate testing information in the FEIR, the mine waste could not be classified as Group C mine waste by the Regional Water Quality Control Board as needed to allow dumping onto these two sites. In addition, due to inadequate testing of mine drill cores for asbestos to establish a reasonable assessment of the potential hazards due to airborne asbestos, numerous management issues regarding the safe handling and placement of asbestos-bearing rock as “Restricted Materials” remain unresolved. Worse still, for the remaining 65 or more years of operations, even if the issues of potential water and asbestos impacts are resolved, significant issues remain as to how and where the mine waste will be disposed. Mine Waste Disposal Plans The mine operations will require disposing of 1500 tons/day of mine waste 365 days/year for approximately 75 years. Five hundred tons/day of sand tailings are to be returned underground in the form of cemented paste backfill. The remaining 1000 tons/day, consisting of 500 tons/day of barren rock and 500 tons/day of sand tailings, will be exported from the containment structures of the processing facility. The mineralized rock (ore) and barren rock will be removed from the mine by hoisting and dropping the materials into the silos on the surface at the New Brunswick shaft. The silos will have a capacity of 1000 tons for the ore and 400 tons for the barren rock. This means that the silos will have a maximum capacity of just under the daily production of 1500 tons. The 1000 tons/day ore will then be run through the processing facility and the sand tailings for export will be loaded into haul trucks with a front-end loader from within an enclosed structure. The barren rock will be loaded directly into haul trucks from the silo. Market Demand The FEIR states that after the Centennial and Brunswick sites are full, “...hauling of engineered fill (barren rock and sand tailings ) would shift entirely to be utilized in local and regional construction markets.” (FEIR Page 2-59). The market demand for this mine waste (barren rock and sand tailings) has not been established. The FEIR mistakenly assumes that the aggregate market is analogous to the market for mine waste rock (or barren rock) and sand tailings. The FEIR then argues that there is substantial market demand for aggregates in the region. (See FEIR Master Response 11, “Evidence for Market Demand”, Page 2-61, 62) The FEIR notes that the Sacramento County aggregate production-construction area has less than 50% of its 50-year aggregate demand currently permitted, and also lists the annual demands for Nevada County, Placer County, and Yuba City/Marysville. The FEIR then concludes, “This master response demonstrates that there is sufficient market demand for engineered fill (barren rock and sand tailings)”. This is a false conclusion based upon selectively excerpting data from the California Department of Conservation Mapsheet52, 2018, (https://www.conservation.ca.gov/cgs/Documents/Publications/Map- Sheets/MS_052_California_Aggregates_Map_201807.pdf ) In fact, the Department of Conservation data shows that Sacramento County has 327 million tons of aggregate supplies already permitted, enough to meet 21 to 30 years of demand. In addition, it is entirely reasonable to expect that within the next 20 to 30 years, more permits may be issued in Sacramento County. In addition, the aggregates map also shows that surrounding counties already have more than enough surplus aggregate supplies to provide for the needs of Sacramento County. Placer County has more than double the estimated 50 year aggregate demand already permitted (387 million tons vs 188 million tons needed), Nevada County has 125% of the 50 year aggregate demand already permitted (52 of 41 needed), and Yuba City-Marysville has almost 200% already permitted (679 of 344 needed). A realistic view of the market for aggregates is that there are abundant aggregate supplies in the region, the aggregate market is very competitive, demand varies significantly by season, and most importantly, the mine waste is ill-suited to compete in the aggregate market. Mine Waste versus Aggregate Demand The FEIR addresses the market viability for off-site sales based upon assumptions of annual mass volume demand of aggregate and erroneously assumes that the mine’s barren rock and sand tailings would be suitable for meeting that aggregate demand. Aggregate production is a business which requires the delivery of specific rock sizes and grades depending on the nature of the customer’s project. A producer must be able to produce and deliver rock that meets the specifications - such as those noted below - in the specific tonnages required by the customers. Regional market demands for aggregates are wildly varied in grade and size and producers must comply with aggregate specifications. Consequently, aggregate producers have to produce and stockpile numerous specific products, which have different production inputs, screening, crushing, and washing needs. The mine will be exporting 500 tons/day of “sand tailings” and 500 tons/day of “barren rock.” The sand will be a mix of medium and fine sand, down to very fine silt that has limited market value (300 - 0.044 mm). The barren rock will be crushed to “approximately 6 inches maximum dimension.” (DEIR appendix H4, p14 ) These two products fulfill only a small portion of the aggregate market. At the very least, in order to compete in the aggregate market, significant processing of the mine waste would be required, and the Idaho-Maryland Mine project does not include any of the facilities needed for that processing. The mine waste material may only be suitable for fill, while the majority of aggregate sales in the region are for specified aggregate types. *Partial Aggregate List From Hansen Bros. Enterprises, https://www.gohbe.com/index.php/rock- masonry . See also https://teichert.com/materials/aggregate-products/, https://unionquarries.com/crushed-stone-sizes-for-construction/ The FEIR speculates that the project can meet the specific business needs of the aggregate market without providing a plan for how to actually produce the aggregates needed to meet the actual aggregate market demands. In addition, the FEIR does not provide any market demand data for the rock and sand tailings that will actually be produced by the mine. Seasonal Demand Furthermore, the market for aggregates is seasonal. There is little demand for aggregate in the winter months, as little construction is taking place due to weather restrictions. In addition, winter weather can shut down any ongoing operations. How will the mine waste be managed during long winter shutdowns? There is no provision for temporary stockpiling of output materials anywhere on the project sites. Asbestos Bearing Mine Waste The FEIR does not provide adequate testing to assess the potential impacts of asbestos bearing rock and air pollution hazards, utilizing samples from just 3 drill cores. The few tests that were conducted represented only approximately 2/10,000 of the mine rock volume planned for excavation. This is inadequate. Management of asbestos bearing rock is described in the “Asbestos, Serpentinite, and Ultramafic Rock Management Plan” (ASUR Plan) in DEIR Appendix E.2. Due to the potential for the occurrence of asbestos-bearing rock in the Idaho-Maryland Mine, which is in an Ultramafic Rock zone, all materials extracted from the Idaho-Maryland Mine are considered “Restricted Materials” under the California Air Resources Board (CARB) asbestos Airborne Toxic Control Measures (ATCM). (ASUR Plan, p18). This requires written documentation to accompany any handling, transport and application of the materials, including testing information, amounts, dates, etc. Reportedly, area aggregate suppliers avoid using Restricted Materials because there isn’t a market for them. In addition, the North Sierra Air Quality Management District (NSAQMD) requires that the 3-month rolling average of asbestos levels in all mined materials that leave the enclosed project facilities must not exceed 0.01% asbestos by weight. Concerningly, there are multiple deficiencies in the ASUR plan which could fail to determine exceedances of this 0.01% rolling average threshold until after the materials have already been shipped out. The ASUR Plan does not adequately safeguard against exceeding the toxic thresholds that are established for this project. These safeguard deficiencies are identified in “MineWaste_Asbestos_Impacts_Comments_Final.pdf” (https://www.cea-nc.org/wp- content/uploads/2023/03/MineWaste_AsbestosImpacts_Comments_Final_3-14-23.pdf ) Contaminated Mine Waste and Water Impacts As mentioned, the FEIR has not adequately determined that the mine waste can be disposed of by off- site sales (see above). Nor has it been adequately determined that the waste can be disposed of by dumping it as Engineered Fill because of its potential to pollute ground and surface waters by the leaching of hazardous chemicals. This inadequacy falls under the jurisdiction of the Central Valley Regional Water Quality Control Board (CVRWQCB, or Water Board). The Water Board classifies mine waste by Groups A, B, and C. Only Group C, which has relatively low levels of contaminants, is clean enough to be used for off-site sales. Groups A and B require more stringent controls. The Water Board requires sufficient mine waste testing to determine its classification. In its response to the Draft EIR, the Water Board states: “The applicant shall not sell or utilize waste rock and tailings from the Project for construction aggregate or fill purposes offsite unless such material has been tested and confirmed to qualify as Group C mining waste...” (FEIR Page 2-61). In the DEIR, the Water Board and numerous other parties identified that there was insufficient testing to determine whether the mine waste would be classified as Group C. Therefore, its suitability for off- site sales is in question. Per the Water Board comments:“...the alternative scenario that the mining waste is not suitable for off-site use should be examined.” The Water Board goes on to state that Rise should assess any constraints or challenges associated with waste disposal, in case they can’t do off-site sales for construction aggregate. They conclude with: “The Draft EIR should be revised to address this comment” (FEIR Page 2-233, 234). The FEIR does not address the Water Board’s comment. This is unacceptable, especially given that Rise Gold could easily have done an adequate amount of testing to accommodate the Water Board’s requests, given the plethora of drill cores and samples to which Rise Gold has access. Rise Gold acquired a collection of drill cores and samples from Emgold Mining when they purchased the mine. In addition, they did over 67,500 linear feet of exploratory drilling, themselves. Yet, from all those samples, they chose to test only 11 feet – of the 67,500 - to characterize what will be over 25 million tons of mine waste that will be produced over the life of the mine (1000tons/day x 365days/year x 75years = 27 million tons). Disposal of mine waste is a critical element of the project with the potential for causing significant, negative, long term impacts if it is inappropriately stored or disposed of. Yet, in spite of the wholly inadequate testing represented in the DEIR, the fact that no further testing of the drill cores was required by the FEIR is inexplicable and unacceptable. The FEIR response uses speculative, unproven assumptions stating that the mine rock “...would not be mined until mine waste characterization has been performed to ensure the rock will be suitable for off-site sale. Rock types that are not suitable for off-site sale would likely not be mined, and if mined, the waste rock would be placed underground,” (FEIR Page 2-60). Mine waste classified as Group A or Group B requires specific management that must be determined by the Water Board and cannot automatically be placed underground. Backfilling with waste rock and tailings is the exact scenario which has led to polluted ground water discharges in so many mines in our area. This new project element, the placement of Group A or Group B mine waste underground, was not included in the Draft EIR and if not addressed adequately has a high potential of creating the same type of long-term toxic mine water discharge again. Even disposal of mine waste on the project sites for Engineered Fill (Centennial for 5 years, Brunswick for 6 years) requires testing and will have to meet the Water Board’s approval. Quoting the Final EIR: “ The barren rock and sand tailings would undergo testing as part of obtaining WDRs [Water Discharge Requirements] for use in the Engineered Fill pads, and compliance with water quality objectives will need to be demonstrated to the CVRWQCB prior to that placement,” (FEIR Page 2-59, 60). This is further detailed in Mitigation Measure 4.8-1 (e) (FEIR Page 3-37,38,39). The FEIR Master Response 11 makes false and misleading assertions. The discussion makes the false claim that “...the historic mine waste has been determined to be Group C mining waste from which any discharge would be in compliance with the applicable water quality control plan, including water quality objectives other than turbidity,” (FEIR Page 2-59).In fact, the historic mine waste has not been determined to be Group C by the Water Board. The site is currently undergoing a cleanup under the Department of Toxic Substances Control (DTSC) and was conditionally deferred from being processed as a superfund site provided the cleanup is completed. See “IMM_TRANSMITTAL_Signed.pdf” at https://www.envirostor.dtsc.ca.gov/public/final_documents2?global_id=29100007&enforcement_id=60472136. The DTSC does not need to do cleanup on sites that have only Group C mine waste. In any event, the legacy tailings on the Centennial site cannot be used to determine the likely classification of the mine waste from the proposed project because: The tailings on the site have been subject to over 67 years of oxidation and leaching, reducing the presence of soluble hazardous chemicals which may pollute the surface and ground waters. The geology varies in the Idaho-Maryland Mine. The samples provide by the DEIR were for selected areas and did not undergo examination and testing to the satisfaction of the Water Board to warrant its classification as Group C. However, the Centennial site does serve as a cautionary tale of the hazards associated with dumping mine tailings. The FEIR fails to provide information necessary to assess the potential impacts to surface and ground waters from the leaching of contaminants from mine waste. The mine waste must be classified as Group C mine waste in order to be used for off-site sales. The Water Board requested additional testing to be done and the DEIR to be recirculated to provide adequate data for review. The FEIR provides no additional testing. The FEIR provides no viable plan for storage or disposal of those materials. Instead, the FEIR suggests that “Rock types that are not suitable for off-site sale would likely not be mined, and if mined, the waste rock would be placed underground,” (FEIR Page 2-60). Mine waste classified as Group A and B requires specific management that must be determined by the Water Board, and cannot automatically be placed underground. The FEIR fails to provide adequate information to reasonably determine how to characterize the mine waste for safe disposal. Conclusion The FEIR Master Response11 states: “If the Project’s proposed engineered fill sites and the Brunswick and Centennial Industrial Sites were complete and there was low demand for barren rock or sand tailings, or the material was unsuitable for construction use, the operation would by necessity reduce or halt generation of these materials until an appropriate market, such as fill material or other use of rock material for which the material met appropriate specifications, could be identified.” As this statement demonstrates, rather than following the requirements of CEQA, the FEIR chooses to ignore the need for assessing the potential impacts of the disposal of mine waste. Instead the FEIR assumes, without substance, that an appropriate market would be found to provide a solution. In addition, the FEIR fails to address a potential that the mine waste may not be suitable for dumping on the project’s two Engineered Fill sites, or provide a mechanism for managing the reduction or cessation of operations. Who would make the determination to halt, and under what authority? How would the contaminated materials that are in process be managed? This is a recipe for a failed project leaving yet another toxic problem. In summary, • No evidence was provided that an adequate market for Restricted Materials in the form of barren rock and sand tailings exists. • Most aggregate sales require rock ground to specifications that require an aggregate processing facility. No facilities or other provisions to produce those materials were provided. • No temporary stockpiling capacity is included in the project description or FEIR to deal with a lack of market demand, or even to accommodate variations in demand. The applicant apparently envisions starting and stopping mining operations as individual orders come in from unknown sources. • The FEIR does not provide adequate testing to determine the potential impacts of the mine from airborne asbestos. • The FEIR does not provide adequate testing to determine if the mine waste will qualify as Group C. • The viability of the critical operational plan to dispose of mine waste is not demonstrated. CEQA requires that the EIR “...give the public and decision makers the most accurate and understandable picture practically possible of the project’s likely near-term and long-term impacts.” (CEQA 15125) This Final EIR fails to meet that requirement.

The Idaho-Maryland Mine is in direct conflict with not only local climate goals and initiatives, including the County’s own General Plan, but also with the State’s climate policies and long-term goals more broadly. This opinion piece by South Yuba River Citizens League (SYRCL) was originally published on YubaNet. In 2019, Rise Gold Corp., a private company based out of Canada, submitted plans to the Nevada County Planning Department outlining a proposal to reopen the long-abandoned Idaho-Maryland Mine – hidden away beneath the vibrant community of Grass Valley, an archive of toxic mine waste and an intricate underground tunnel system dating back to the Gold Rush Era of the 1800s. In a community still recovering from the legacy effects of past mining operations, including exposure to both physical hazards on an altered landscape and chemical hazards such as mercury contamination, acid mine drainage and arsenic, lead and asbestos inhalation, the prospect of reawakening the mine has given rise to intense scrutiny and local activism, calling greater attention to the project’s significant environmental and public health impacts. If you asked the average community member about the project, the sentiment is clear. Driving around the County and beyond you will see bright yellow lawn signs with the simple plea: “No Mine. Protect our Air. Water. Quality of Life.” The project is currently under review by the Nevada County Planning Commission and will ultimately come before the Nevada County Board of Supervisors for a final vote, expected sometime in mid-2023. Nevada County Recreation & Resiliency Master Plan Survey As it turns out, a decision on this project is much more complex than meets the eye, particularly when considering the boarder context of California’s climate policy agenda. In the fight against climate change, the proposed reopening of the Idaho-Maryland Mine is in direct conflict with not only local climate goals and initiatives, including the County’s own General Plan, but also with the State’s climate policies and long-term goals more broadly. A key question to consider is, what role does our community want to have in the statewide effort to fight climate change? At the local level, this requires going far beyond the simple checking of boxes and comes down to a deeper question of true leadership and ethical obligation. Proposed operations at the Idaho-Maryland Mine would generate an overwhelming 9,000 metric tons of new greenhouse gas (GHG) emissions annually from the proposed site in Grass Valley, plus another 4,000 metric tons of new GHGs from cement manufacturing performed offsite. Nevada County already suffers from poor air quality due to extended wildfire seasons, vehicular pollution, factory emissions and other sources of dust and particulate matter accumulation, yet the community would have to endure further air quality impacts from rock crushing, hauling, and compacting activities that could release hazardous chemicals such as asbestos and silica particles into the air during mining operations. Further, the excessive increase in diesel truck operations, road usage, and traffic generated by this project will only exacerbate local air quality concerns, damage to roadways, and increase electricity demand equivalent to approximately 5,000 new homes. The major uptick in new GHGs from this project reaches beyond local impact and contributes significantly to the state’s carbon footprint, ultimately detracting from statewide environmental goals. This just scratches the surface when it comes to the project’s potential environmental impacts, which also include significant impacts to water quality, groundwater resources and wildlife habitat. These impacts are not only harmful to the community directly, but they are in direct conflict with the state’s climate agenda. So where does the Idaho-Maryland Mine project fit in to the broader context of our state’s climate change goals, and where should we go from here? In 2022 alone, building on the work of years’ past, California enacted a sweeping portfolio of new climate laws, ranging from codifying the state’s long-term climate goal of achieving net-zero GHGs by 2045, to prioritizing clean electricity, to enacting a strong state budget that prioritizes tens of billions of dollars in climate spending – referred to as the “California Climate Commitment.” From building regional climate resilience, to transitioning our state’s workforce to a carbon-neutral economy, to decarbonizing buildings, to prioritizing zero-emission vehicles, all while responding to wildfires, drought, and other catastrophic climate events – forward-thinking climate action is and has been at the forefront of decision making in California. The bottom line is that the Idaho-Maryland Mine simply doesn’t have a place on the state’s path to a cleaner, greener economy, and California simply can’t afford to be set backwards in its intentional fight against climate change. Reopening a toxic mine with significant environmental impacts for the benefit of very few is simply not a risk worth taking, particularly as we consider our role in the larger fight against climate change in California. Every policy decision is a chance to do better for our communities and our environment. That is why our community is relying on our local government and its leadership to do the right thing and reject the reopening of the Idaho-Maryland Mine. Join us in person at the Nevada County Planning Commission hearing on Wednesday, May 10 at 9:00 AM at the Eric Rood Administrative Center, at 950 Maidu Avenue in Nevada City, California, to let our local government officials know this project is wrong for our community and for California. Gianna Setoudeh is the Policy Director for the South Yuba River Citizens League

The Final EIR lacks the data needed to assess the impacts of airborne asbestos and the management plan is inadequate. March 14, 2023 Overview Airborne asbestos is hazardous to inhale, leading to lung cancer and other diseases. The Idaho- Maryland Mine Final EIR does not provide enough data to determine the potential impacts of airborne asbestos, and the asbestos management plan (ASUR plan) for preventing hazardous emissions is inadequate. Very limited asbestos testing was done, constituting less than 2/10,000 of the total rock to be mined over the project lifespan. As the Air Quality Board stated “It would be short-sighted to commit to the ASUR Plan for the entire life of the mine based on the few samples that have been tested so far.” (FEIR Page 2-360) The ASUR plan was developed to limit emissions, but it is a flawed document that fails to provide the needed protections. Under the plan, if the asbestos concentrations on any 1000-ton lot of mined materials would put the 3-month rolling average asbestos concentration over a threshold of 0.01%, it would not be allowed to be exported. A key problem is accurate and timely testing. It takes 2 weeks to get the results. The Final EIR has no provisions for stockpiling materials while waiting for results. And no temporary storage on the surface is provided. To avoid the need for stockpiling mined materials, the plan states that exploratory drilling tests will determine what can be mined in advance. Then grab samples will be taken as the rock is loaded into silos for deployment. But the testing is too sparse. The loading into silos of 1000 tons of rock requires about 166 6-ton skip loads. This means that the grab test will only capture, on average, about 1 out of 55 skip loads, and even then, the three grab samples will be mixed together to form one combined test. And even accurate sample testing before shipping will not always prevent exceeding the safe average threshold. Examination of how this system may fail reveals that large quantities of mine waste could pass through undetected. And though the ASUR plan talks about what happens when the delayed testing shows that the threshold was exceeded, it doesn’t actually provide a credible solution or adequate oversight. Finally, it’s important to note that all exported Mine Waste from this mine must be classified as “Restricted Materials” (ASUR 9.2, p18) Aggregate suppliers in the region have indicated that they do not handle Restricted Materials because there is no market for them and there already are abundant aggregate sources regionally. In conclusion, the Final EIR does not provide adequate data on asbestos concentrations, and fails to adequately address processing and disposal of asbestos-bearing mine waste. A. Introduction Asbestos is found in all the rock types within the Idaho-Maryland Mine in varying concentrations, though it is predominantly associated with Serpentinite, which can contain high concentrations. Airborne asbestos is hazardous to inhale. It can lead to mesothelioma cancer, asbestosis, and other diseases, and is closely regulated by the California Air Resources Board (CARB). The mine’s “Asbestos, Serpentinite, and Ultramafic Rock (ASUR) Management Plan” (DEIR Appendix E.2) was developed to address the management of asbestos airborne emissions. Regulation of asbestos emissions falls under the jurisdiction of CARB and the Northern Sierra Air Quality Management District (NSAQMD). Management of asbestos to prevent hazardous emissions is complicated by the difficulties of accurately testing for it and by the fact that concentrations can be found close to gold ore. B. Criteria The FEIR Condition of Approval 3 (COA-3) and the ASUR Plan establish a limit of 0.01% asbestos by weight as the threshold for managing all mine waste that leaves the enclosed project structures or containment structures, such as the silos, conveyors, and processing facility. Under the ASUR Plan, if the asbestos concentrations on any 1000 ton lot of mined materials would put the 3-month rolling average asbestos concentration over 0.01%, then that lot would not be allowed to be sent out of the containment structures. The Final EIR does not provide enough baseline data to determine whether the project can be mined while meeting this threshold. Very limited testing was done. Thirty-seven samples were taken, but they came from only 3 drill holes. (Drill Holes 1-18-11, 1-19-13, and 1-19-14, ASUR Plan, Appendix C, p55-57). Assuming that each sample provided a good estimate of the asbestos concentrations for a 2000 cubic foot volume ( 20’ h x 10’ w x 10’ d ), the tests constituted less than 2/10,000 of the total rock to be mined over 75 years. The criteria for sample selection was not specified and the sampling party was not named. Even so, of the 37 drill core samples from the mine that were tested, asbestos testing (TEM method) determined that 15 had asbestos, and 8 of those had asbestos over the 0.01 limit. A potential hazard clearly exists. There are three test methods. Polarized Light Microscopy (PLM) is fast but not precise, being only valid for detecting above 0.25%. This method is not adequate for detecting the 0.01% threshold, but it is used to define the threshold for surfacing applications under the Airborne Toxic Control Measure (ASTM). The Transmission Electron Microscopy (TEM) process is more accurate, but takes up to 2 weeks to get a result. The TEM test is what dictates most of the management activities in the ASUR Plan to prevent asbestos emissions. (A third method, Phase Contrast Microscopy (PCM), is not valid for rock sampling but is used for air quality monitoring and provides a referential standard for TEM.) (ASUR, p8). The FEIR has NO plans for the temporary stockpiling of mined materials. So, to avoid the need for stockpiling mined materials, the ASUR Plan states that samples from exploratory drilling will be tested for asbestos in advance of mining. If the anticipated rolling average asbestos levels exceed 0.01%, gold ore will not be mined and barren rock will either not be mined or mined using a dust collection system and materials will be disposed underground (ASUR, p9). However, the prescribed testing is sparse and could easily miss rock having higher asbestos levels. Just one combined test per 1000 thousand tons of mine rock is prescribed (1000 tons is approximately equal to an 8’x8’x170’ block). The mined rock will be lifted from the mine to the silos on the surface with skips. Gold ore will be dumped into a silo with 1000 tons of capacity and barren rock into two smaller silos with 400 tons of capacity. From the gold ore silo, material is fed into the processing facility via an enclosed conveyor. The project plans to process about 1500 tons of rock per day, from which 1000 tons is expected to be mineralized rock (gold ore) and 500 tons is expected to be waste rock (barren rock). The gold ore will be run through the processing facility to extract a gold concentrate, leaving 1000 tons of fine sand tailings material which must be disposed. About half of the sand tailings, 500 tons per day, will be mixed with cement to form a cement paste backfill material which will be put back into the mine. The other 500 tons per day of sand tailings will stockpiled to be loaded onto trucks with a front-end loader and trucked off. The 500 tons of barren rock that are mined daily will be moved via conveyors to the truck loading building for export. C. Deficiencies of the Testing and Processing Plans To prevent the 3-month rolling average of asbestos in rock from exceeding the 0.01% threshold, the ASUR Plan relies on developing an inventory of asbestos levels of un-mined rock through exploration and testing, and then avoiding mining the rock that would violate the threshold. However, the critical test that monitors what will be exported is taken when the gold ore and barren rock are lifted and dumped into the silos. A minimum of three grab samples must be taken for each 1000 tons that are transferred. These three samples will then be combined to form a composite sample for a single test result. Each sample is added to the record which tracks the rolling average of exported materials. The materials are lifted into the silos using skip carts that lift around 6 tons (ASUR, Fig 2). The processing of 1000 tons requires about 166 skip loads. Each grab test will only capture, on average, about 1 out of 55 skip loads, and even then, the three grab samples will be mixed together in a combined test. Because of the sparseness of the sampling, 1000 tons of mine rock, or about 50 truckloads worth, could contain excessive levels of asbestos and still pass through undetected. Complicating that, the materials go into a split output stream, with a daily average of 1000 tons going to the processing facility and 500 tons going directly off-site as barren waste rock. It is not specified how the grab samples would be associated with the two output streams. After processing, as described previously, the sand tailings are exported: 500 tons of the tailings will go off-site, and 500 tons will be transported back into the mine and used as cemented paste backfill. The plan should specify separate sampling criteria for each stream of materials which should follow those materials through the process phases. The amount of required testing is inadequate to reasonably detect the asbestos levels of materials leaving the containment structures. The ASUR Plan does not even specify testing of the sand tailings after processing, and there are no provisions for the gold ore to be tracked to associate the specific test results with the 1000 ton loads as the material is sent through the processing facility. If a TEM grab test comes back with unexpectedly high asbestos values, how would the processing system determine which sand tailings from the processing output should be redirected to be used as cemented-paste backfill? This part of the plan is inadequate in assuring that higher-than-expected levels of asbestos are not being exported. The materials’ processing is a stream, but the ASUR Plan tries to manage the materials by testing blocks of un-mined rock. Materials from multiple sites within the mine will be transported, crushed to 6” maximum size and lifted for processing. Most of the materials will then be sent via conveyors to the processing facility, and the resultant sand tailings will be conveyed and accumulated for hauling out. The testing procedure is poorly suited for tracking the materials through the processing system. How will the process keep track of which final outputs were from a given block of un-mined rock? In addition, under certain conditions as described in ASUR Plan Section 6.0-7i (ASUR, p8), gold ore with high asbestos levels would be processed, which means introducing gold processing tailings with known exceedances into the same system. D. Deficiencies in the Moving Average Approach Exceeding the 0.01% threshold would only be detected in hind-sight once the TEM tests are processed. In addition, a series of many individual loads in excess of 0.01% could be shipped out and still not exceed the 3-month rolling average if the average started out low. Given that there is no plan for on-site storage, the possibility is real that, during the 2 week testing lag time, many additional 1000-ton batches of materials exceeding 0.01% asbestos would be processed. Taken together, many weeks’ worth of mine waste with high levels of asbestos could be shipped out. We noted above that one test from 3 grab samples is sparse and can likely give inaccurate results. But even if testing accurately measures the asbestos levels per day, it does not assure that the 3-month rolling average won’t end up exceeding the 0.01% threshold. For example, the following test results would result in a 0.024% average asbestos concentration on Day 120 even after an operations shut down on day 106. Threshold Exceedance Example Day 105: • 75 days exported averaging 0.008% • 15 days exported averaging 0.02% ((75x0.008)+(15x0.02)) /90 = 0.01% average. OK • 15 days exported (test results not back yet, avg 0.03%) Day 106: • 74 days exported averaging 0.008% • 15 days exported averaging 0.02% • 1 day exported at 0.03% (74x0.008)+(15x0.02) + (0.03) /90 = 0.0102% average, SHUT DOWN • 14 days already exported(test results not back yet, avg 0.03%) : Day 120: • 60 days exported averaging 0.008% • 15 days exported averaging 0.02% • 15 days exported averaging 0.03% ((60x0.008)+(15x0.02)+(15x0.03))/90 = 0.024% Results in 15 days exceeding the 0.01% rolling average! In the Threshold Exceedance Example, the 90 day average asbestos level ends up at 0.024% even while complying with the ASUR Plan by shutting down on the first day of exceedance (Day 106). Plus, in total, 30 individual days of output exceeded 0.01% asbestos concentration. The ASUR plan to prevent the asbestos levels from exceeding the 0.01% threshold is inadequate. E. Surface Exposures of Airborne Asbestos at the Engineered Fill Sites There will be about 500 tons per day of sand tailings exported from the ore processing plant. This represents approximately one half of 1000 tons of tested gold ore from the silo. The sand tailings from the gold ore processing is stockpiled inside a containment structure to be loaded onto trucks with a skip loader and shipped off. Operations run for 24/7 but materials are only shipped off 16 hours per day and may have weather related days of no shipping, accumulating the sand tailings, which are loaded into trucks outside the structure (FEIR Page 2-543). Conceivably, the 30 days of gold ore that were processed in the Threshold Exceedance Example could produce sand tailings exceeding the 0.01% threshold. How would it be determined which sand tailings came from the contaminated materials that end up in the sand tailings containment structure? After the sand tailings are delivered to the planned Engineered Fill dumping sites at the Centennial site, and later the Brunswick site, they will be mixed with the barren rock in the open air by “on-site blending of blast rock and sand tailings” (DEIR Centennial GeoTechnical Report, p13). Using the Threshold Exceedance Example, thirty days of materials exceeding the asbestos threshold - equivalent to 1500 truck loads - could be mixed in the open air on the Engineered Fill sites, in clear violation of the ASUR Plan goals for reduction of airborne asbestos. F. Exported Mine Waste is Classified as “Restricted Materials” All mine waste, aka “Engineered Fill” or “sand tailings and barren rock,” from the Idaho- Maryland Mine is considered “Restricted Materials” under 17 CCR 93106(d)(1). (ASUR Plan, p16-17). The Restricted Materials can be separated into two groups, one group being below the 0.25% threshold under the ASTM rule, and the other group being equal or above that threshold. For materials below 0.25% asbestos using the PLM test, the material can be transported and used for Engineered Fill or surface applications, but “Any person who transports Engineered Fill (considered a restricted material) must maintain a copy of all receipts with the material at all times during transit and application” (ASUR p16). The following receipts must be provided: A. The amount of restricted material that was sold or supplied; B. The date that the restricted material was sold or supplied; C. The dates that the restricted material was sampled and tested; and D. A statement that the asbestos content of the restricted material is less than 0.25 percent. Because the ASUR plan establishes a threshold of 0.01% for the rolling 3-month average using TEM testing, it is probable that most of the mine waste that is output from the facility would fall below 0.25%. However, it is worth noting that some 1000 ton daily outputs could exceed 0.25% and still not cause the rolling 3 month average to exceed 0.01%. (For example, 89 days with an average of 0.007% and 1 day with 0.25% asbestos concentration by weight equals a rolling average of less than 0.01%.) For materials at or above 0.25% asbestos, the mine waste is classified as “Asbestos Containing Material” under ATCM for Surfacing Standards. For Engineered Fill materials detected at or above 0.25% using the PLM test, strict usage requirements are imposed to prevent exposure or possible future disturbances. ATCM requires that “the material shall not be used for surfacing applications pursuant to 17 CCR 93106” (ASUR p16). In the case of at or above 0.25%, it cannot be used for surfacing, but it may be used for operations that assure the materials will be handled under strict conditions. All materials in this classification must be accompanied with the following written receipt: WARNING! This material may contain asbestos. It is unlawful to use this material for surfacing or any application in which it would remain exposed and subject to possible disturbances. Extreme care should be taken when handling this material to minimize the generation of dust. Any person who transports Engineered Fill (considered a restricted material) must maintain a copy of all receipts with the material at all times during transit and application. Of course, the three-month rolling average must also be less than 0.01% to even be shipped out. G. The “Restricted Materials” classification may severely limit off-site sales. As the ATCM rules make it clear: “All aggregate extracted from the Idaho-Maryland underground mine, including barren rock and mineralized material sent for processing, is considered Restricted Material under the ATCM for Surfacing Applications” (ASUR 9.2, p18). Aggregate suppliers in the region have indicated that they do not handle Restricted Materials because there is no market for them. H. Unapproved Underground Dumping May Violate Water Board Standards The ASUR Plan does not address how the mine waste which might be diverted to underground storage because of high asbestos levels would be tested to conform with the Water Board’s requirements to prevent pollution of ground and surface waters through leaching of hazardous chemicals. Because the Final EIR did not include adequate testing of the mine rock for possible water contamination, the Water Board is requiring continuous testing to determine whether the materials conform to Group C mine waste, which is required for off-site use, or whether the Water Board will require special processing as the more hazardous Group A or Group B mine waste. I. The ASUR Plan is Ambiguous and Self Contradictory 1) Ambiguous Terms The ASUR Plan discusses the processing and testing of mine waste by utilizing the euphemism “Engineered Fill,” eventually describing it on page 13 in the statement: “...asbestos content of Engineered Fill (barren rock and sand tailings) placed and compacted...” Since there is an intent to simply sell the the mine waste, “Engineered Fill” doesn’t seem to mean the applicant is including the “placement and compacting.” Hence, the document seems to define Engineered Fill simply as “barren rock and sand tailings.” The use of the term “engineered fill” is ambiguous when there are statements such as ““the remainder of the sand tailings will be used for engineered fill.” Substituting the words “barren rock and sand tailings” for “engineered fill” in this statement then reads thus: “the remainder of the sand tailings will be used for barren rock and sand tailings.” Another confusing example is the use of the term “Asbestos Containing Materials.” This term is explicitly defined in the document to mean materials having over 0.25% asbestos under the ASTM rule. However, materials having asbestos exceeding 0.01% are also referred to as “asbestos containing materials,” as seen on ASUR Plan page 20. The ASUR Plan document contains numerous ambiguous statements which distort the meaning and validity of the document. 2) Aggregates, Surfacing and Loopholes Rock aggregates that are used in the construction industry include a wide range of materials mostly consisting of specific crushed rock sizes that are generally screened or filtered to within certain size limits (e.g. ¾” Class II road base) and many also require washing. The barren rock that is produced by the mine will be mixed crushed rock 6 inches or less in size and would need to be recrushed to the right sizes, screened, and sometimes washed to meet most aggregate market demand. The sand tailings are fine sand or silt size granules which have very limited use. (See https://www.gohbe.com/index.php/rock-masonry.) However, the ASUR Plan mistakenly treats Engineered Fill and surfacing materials interchangeably. Engineered Fill made of barren rock and sand tailings is not suitable for surfacing applications. Sand tailings have little use and the barren rock would first need additional processing, which requires facilities that the mine does not provide. The word “aggregate” is commonly known but is not specifically defined in the ASUR Plan. In Section 8.4 (p16), the term is used to describe regulatory restrictions: “If a composite sample determines that aggregate is not Asbestos-Containing Material, a written receipt must be provided to the recipient of the Engineered Fill.” This statement is ambiguous in that it is not clear that the Engineered Fill being referred to is the “aggregate” used in this sentence, or some additional materials. The ASUR Plan repeatedly refers to surfacing materials as if they are equivalent to Engineered Fill. For example, the statement in Section 6.0 -Item 7(i): “If planned mining is projected to result in insufficient material available for Surfacing in Engineered Fill Placement Plan: i. An operational plan will be prepared and approved….” Item 7(i) in section 6.0 also describes ambiguous conditions about “insufficient materials” which seemingly allow mining of Asbestos Containing Material if it is gold ore. Then the subsequent Item 8(i) in Section 6.0 then states that if the 0.01% threshold would be exceeded, gold ore will not be mined. (ASUR, p9) This is in direct contradiction to Item 7(i)! 3) Operations Oversight The ASUR Plan lacks clearly defined oversight for the management of the asbestos materials. Nor are guidelines for approval of changes to operations or procedures provided. Here the responsibility is given to an unspecified “geology department.” “If the three-month rolling Asbestos Inventory for materials hoisted to surface exceeds 0.01% asbestos by mass of PCM equivalent units the geology department will immediately investigate the source of the asbestos containing material and halt mining in the area of concern until a revised mine plan is prepared in compliance with the ASUR Plan” (ASUR, p20). This is inadequate. To provide reasonable safeguards, an independent party should be responsible for overseeing monitoring, investigations, reporting, and corrective actions. What constitutes a valid report should be defined. And guidelines for subsequent actions should be explicitly defined and authorized by the County and NSAQMD, and not be done by employees of the mine. The ASUR Plan was written by Rise Gold (ASUR, p1). Conclusion The Final EIR does not provide adequate data on asbestos concentrations in mine rock to determine the potential impacts under CEQA. In addition, the ASUR Plan fails to adequately address processing and disposal of asbestos-bearing mine waste to meet its stated goals, and the ASUR Plan is internally inconsistent and ambiguous, providing numerous loopholes in regulatory oversight. The potential for hazardous airborne pollution from the mine project is a significant health concern which is inadequately addressed in the Idaho-Maryland Mine Final EIR. This Final EIR should be rejected. The appended figure is from page 106 of Rise Gold’s “Technical Report On The Idaho-Maryland Project” https://www.risegoldcorp.com/uploads/content/I-M_Tech_Report.pdf. It shows the Morehouse Fault and the location of gold ore in close proximity to surrounding Serpentinite rock beds. Serpentinite is generally high in asbestos. The purple shows Serpentinite, the orange shows Gabbro, and the red line shows the gold-quartz ore vein. The region near the bottom of the figure is a primary target for the proposed project. Geology Cross Section from Rise Gold Technical Report PRINT or share this information with others using this PDF.

Local resident, Deni Silberstein, takes issue with Rise Gold's online ad and its questionable representation of miners. Read in The Union. March 11, 2023 Seriously? Does anyone really believe that the picture of the pristinely clean employee proudly displayed in Rise Gold’s online ad is a true representation of a mine worker? Does anyone really believe that that picture honestly portrays a physical laborer – even one who operates a piece of machinery? If you’ve ever been even remotely associated with labor at a construction site, then you know the truth: unless it is the first minute, of your first job at a brand-new-haven’t-yet-broken-ground construction site, a worker never looks like that. And mining is construction. It involves working close to the dirt, close to soil-encrusted rock, close to oil-bearing and grease-demanding machines, close to fabric-snagging obstacles that don’t care if you’ve just bought that new pair of jeans. Not only do you not leave work looking like that pic, but you don’t even ARRIVE at work looking like it – dirt, grease and grime leave stains; fabric rips. That picture is a deception. It’s designed to make you think that an untruth, is true. That picture is symbolic of Rise Gold’s ongoing efforts to hoodwink the citizens into believing that the mine is green, that it’s non-polluting, almost dustless, almost noiseless, and will provide fast-food workers six-digit annual salaries. That picture is trying to convince us that the Emperor is attired in regal and elegant clothes, when, in truth, he’s stark naked...or, at best, dirty, stained, and dead tired. For an honest view of Rise’s intentions: https://www.minewatchnc.org Deni Silberstein lives in Grass Valley.

The nearby city of Auburn in Placer County restricts mining in areas that are incompatible. Nevada County needs to consider the same. The Idaho-Maryland Mine project certainly fits the same description they used. “Because mining activities would already be incompatible with these developed areas due to noise, dust, traffic and other nuisances, the project site should be developed for non-mining uses.” This opinion piece was originally published in The Union. Mar 31, 2023 The economist representing RDN and the Niehaus Economic Impact Report on the proposal to reopen the defunct Idaho Maryland Mine at the 12/15/22 webinar spoke about their research into comparable projects and the impact of introducing industrial mining on real estate values. RDN stated that there were no comparable studies or approvals of mining enterprises as close to residential neighborhoods as the defunct Idaho Maryland Mine is to the 90 homes within a half mile of the proposed industrial site. They also stated they could find no comparable industrial mining enterprises approved or operating 24 hour a day, seven days a week located as close as a half mile to residential development. Therefore, they could only speculate on the impact to real estate values. The obvious question is how many proposed industrial mining projects were rejected by governing municipalities because of the adjacency to residential development and the resulting negative impacts? Excerpts From Exhibit A, Draft Statement of Reasons to Permit Development in a Mineral Resource Zone, City of Auburn Our neighboring city of Auburn approved the Baltimore Ravine Specific Plan that proposed a multi-use residential and commercial development in a Mineral Resource Zone. Within this zone, “the State Geologist has concluded that significant inferred gold resources are believed to exist”, however, in spite of potential gold mining tax revenues and jobs, Exhibit A represented that “Mining is Incompatible with adjacent Land Uses”. The areas around the Mineral Resource Zone have been developed with low-density residential uses. “Because mining activities would already be incompatible with these developed areas due to noise, dust, traffic and other nuisances, the project site should be developed for non-mining uses.” Exhibit A goes on to say that even though mining has been a large part of the past in the area, “mining no longer makes up a substantial portion of industrial activity in the County”. Similar to Nevada County, mining in Placer County represents less than .1% of the economy. Nevada County would be wise to formally acknowledge that industrial gold mining is part of our past and not part of our future. The economy of the future will be built on a diverse mix of clean manufacturing, construction, wholesale and retail trade, healthcare, education, arts and entertainment, recreation and tourism, government and government services. Success will draw on the willingness of County, City, non-profits, State and National Forest, utilities, and private sector leadership to collaborate and partner in solutions that lead us to a sustainable and balanced economic future. Paul Schwartz Grass Valley

Rise Gold is touting jobs, jobs, jobs. But reality is not all it's cracked up to be. All this hoopla for 132 local jobs? 12 hour shifts? 7 days on / 7 off? We can do better. The opinion piece was originally published in The Union. The Idaho Maryland Mine Environmental Impact Report (EIR) and project is coming to a vote by the County Planning Commission and Board of Supervisors soon. As expected, Rise Gold management is putting on a last-minute publicity blast touting jobs, jobs, jobs – even though most hiring may not begin for 6-10 years if the project is approved. CEA Foundation-MineWatch is the group leading up the 21-organization strong opposition to the Idaho Maryland Mine (IMM). As a local resident and decades-long owner of a planning and management firm for large scale development projects including mining, I volunteered with other MineWatch panelists to analyze the economic impacts and jobs expected from the Mine. You can see my presentation at youtube.com/watch?v=sffBFTY78Pw. Doing the analysis helped me understand how weak the jobs outlook from the mine is. Here is what I found: How many jobs are we really talking about? Rise Gold originally claimed they would bring 600 new local jobs to the county. The county’s Economic Impact Report corrected that number to 475. This would include 312 direct jobs when the mine is fully operational, plus 163 indirect jobs hired by other companies, some part time. Of these jobs, my analysis concluded that the Mine will likely result in less than 132 locally held jobs for residents of Nevada County 6-10 years from now. Given the complexity of the permitting and building process, it could easily be 2034 before the mine is financed and operational with a complete workforce. Will these jobs go to locals? There is no guarantee that jobs will go to Nevada County residents. Correcting the boilerplate assumptions used in the county’s Economic Impact Report, I estimate that 58% (not 32%) of Rise Gold’s workforce would be commuters from outside the county. This is because 12 hour shifts with 7 day on/7 day off work schedules favor skilled, but transient miners who commute – often sharing housing or living in an RV. They live in their hometowns and change mine jobs as they develop. Clearly, these transient workers will not spend much of their income in the county. Even the construction jobs for building the facilities are likely to go to outsiders since most of the construction requires contractors with highly specialized experience. Do you want your kids to work in an underground mine? The bottom line is that mining is a miserable job that is physically and environmentally dangerous. We are talking about 12-hour shifts, 7 days on/7 off, 2,300 feet or more underground with heavy equipment – while wearing full protective gear. Mine jobs are not secure Mining is a boom-or-bust business. Risks include a rise in operating costs, a drop in gold prices or ore quantity, an environmental accident, bankruptcy, sudden closing, and wells drying out. Any of these events could result in a sudden loss of jobs. The result: an economic and environmental wipeout instead of the touted jobs windfall. Existing zoning provides for more and better jobs For years, Grass Valley and Nevada County decision makers have responsibly planned for their economic future. The goal is to grow clean businesses, not resource extraction jobs. Approving the mine would require a zone change that would put mineral extraction immediately adjacent to residential areas, but Grass Valley’s current General Plan and zoning provide for a clean Business Park that could accommodate up to 800 jobs according to a report for the last IMM proposal. This is almost twice as many jobs as the mine might provide, without the risk. Let’s stick with the City and County General Plans – which provides more and better jobs for locals. The minimal economic and job benefits do not outweigh the risks I made a simple calculation of the most optimistic scenarios in the County’s Economic Impact Report to reveal that the real economic benefits of the mine will be an inconsequential $7/per year/per County resident. I ask our County Supervisors: does $7/year/resident and only 132 future jobs for current residents override the serious risks of placing a toxic, hazardous and economically questionable business in the middle of an idyllic residential community? My conclusion is no. If you agree, write a letter to your supervisor at www.MineWatchNC.org/send-a-letter. I will be attending the upcoming Planning Commission and Board of Supervisors hearings asking them to Just Say No to the Idaho Maryland Mine and EIR. Jim Steinmann Grass Valley