Bureau of Land Management
Mount Lewis Field Office
50 Bastian Road
Battle Mountain, NV 89820
DATE: April 05, 2017
Subject: DEIS MMI Gold Bar Mine Project
Dear Ms. Gabriel:
On behalf of The Cloud Foundation (TCF) and Wild Horse Freedom Federation (WHFF), 501(c)3 non-profit corporations, and our hundreds of thousands of supporters throughout the United States, we would like to thank you for the opportunity to submit scoping comments on the Draft Environmental Impact Statement (DEIS) for McEwen Mining Inc.’s (MMI) Gold Bar Mine Project (Project).
TCF, a wild horse and burro advocacy group and an advocacy group for all wildlife on our public lands in the West, and Wild Horse Freedom Federation, a voice for the protection of wild horses and burros and public lands, strongly opposes the expansion of the Gold Bar mining project and we urge the NO ACTION ALTERNATIVE in this DEIS for the following reasons:
Wild Horse Herds To Be Affected:
The Project will negatively impact the Roberts Mountain Wild Horse Herd as well as the nearby herds of Whistler Mountain and Fish Creek Herd Management Areas.
Sage Grouse Habitat Affected:
Not only wild horses will be affected in this area. All wildlife will suffer.
Open pit mining is the most environmentally destructive type of mining anywhere. Extreme weather events can overwhelm all mandated precautions, threatening migratory birds and small mammals. In the case of a flood, even large mammals like wild horses risk exposure to potentially lethal mining waste.
Direct habitat damage due to mining plus further fragmentation by roads and large equipment traveling on these roads will eliminate hopes for the recovery of the Greater Sage Grouse in this area. The transport process in itself is dangerous-accidents, dust, spread of contaminants, noise, etc.
Greater Sage Grouse were once so numerous that the “sky was black” with these large birds, according to Ginger Kathrens’ late Uncle, Allan Ralston, who spoke of this area after his return from WWII. Now the birds are threatened and a species of critical environmental concern. BLM should prioritize these risks.
Impacts on Water Sources:
Per the Gold Bar DEIS, page 4-147, under 2 different scenarios, the mine will either pump 380 gpm (gallons per minute) or 500 gpm (gallons per minute).
If the mine pumps 380 gpm, this equals 22,800 gallons per hour, 547,200 gallons per day, and 199,728,000 gallons per year. Over 10 years, it will pump over 2 billion gallons of water.
If the mine pumps 500 gpm, this equals 30,000 gallons per hour, 720,000 gallons per day, and 262,800,000 gallons per year. Over 10 years, it will pump over 2 1/2 billion gallons of water.
This does not include the water which the Mt. Hope mine will use once mining begins. Mt. Hope is projected to use 7,000 gallons per minute for the life of the mine (40-50 years).
The project will deplete surface and ground water resulting in the drying up of ephemeral streams. Reducing water tables to dangerously low levels will
negatively impact perennial streams. This DEIS minimizes the impact on water resources by not providing 5′ or 1′ water drawdown maps and thus minimizing the additional area of land that will be effected. A stream can dry up with as little as 1′ of water drawdown.
Maps created by Wild Horse Freedom Federation are included in the Appendix.
Map 1 – (Figure 4.23-11 of DEIS) Gold Bar Mine Wild Horse CESA (Cumulative Effects Study Area). On page 4-265 of the DEIS, it states “The CESA for the wild horses and burros includes Roberts Mountain, Whistler Mountain, and portions of the Fish Creek HMAs, as well as Kobeh Valley and Roberts Mountain HAs where wild horses existed based on past inventories, and where they could be potentially affected by the Project…”
Map 2 – shows the addition of the approximate 10′ water drawdown area – (Figure 4.19-3 of Gold Bar Mine Project), 500 gpm (gallons per minute) for 10 years.
Map 3 – shows the addition of the approximate HMA and HA boundaries.
Map 4 – shows the addition of the approximate Mt. Hope Mine Project area and well field – (Figure 3.13.1 Mt. Hope Project EIS).
Map 5 – shows the addition of the approximate Mt. Hope Mine 10″ water drawdown area – (Figure 3.2.18 Mt Hope Project EIS).
Map 6 – shows approximate sketch of Gold Bar Mine and Mt Hope Mine with HMA and HA boundaries
Map 7 – shows approximate HMA boundaries over grazing allotments map – (Figure 3.7 – 1, Gold Bar Mine EIS)
Map 8 – shows approximate mining, water drawdown, and grazing with the HMA and HA boundaries.
BLM writes in their description of the Roberts Mountain HMA: Water availability is a key influence to wild horse use during summer months. Wild horses will generally travel much farther to water than will livestock. In many HMAs water sources are plentiful and supplied by perennial streams, springs, and human constructed water developments such as livestock water tanks and ponds. In other cases, water sources are limiting, and in drought years, wild horses may have difficulty accessing sufficient water, (emphasis added) especially if the population exceeds the Appropriate Management Level (AML). In these cases, wild horse distribution is closely tied to the location of the available waters, which becomes very important to the health of the herd.
Drought Ridden Region
Drought is common in this driest state in the Union. Emergency removals of wild horses because of the lack of water are common. Removals of 14 wild horse herds occurred in 2009 south of Ely by BLM. The Agency cited the lack of reliable water sources as the reason for the removal of wild horses on 1.4 million acres of public land.
The proposed expansion and creation of more water dependent, extractive uses of the land is irresponsible.
Outdated Plan and Manual
This DEIS is based, in part, on a plan and a manual that are each about 25 years old and outdated. We are referring to the BLM Cyanide Management Plan (1992), (noted in Vol. 1A, 1.4.3) and the Solid Minerals Reclamation Handbook (1992), (noted in Vol. 1A, 1.4.4). We ask that you review these outdated materials and update them if you are going to base any part of this DEIS on these outdated plans.
The potential for failure of this project is so high that the Securities and Exchange Commission (SEC) states: . . .in addition to greater uncertainty as to the economic feasibility of Mineralized Material compared to proven and probable reserves, there is also greater uncertainty as to the existence of Mineralized Material. U.S. investors are cautioned not to assume that measured or indicated resources will be converted into economically mineable reserves. The estimation of inferred resources involves far greater uncertainty as to their existence and economic viability than the estimation of other categories of resources.
Couple the above with the failure of the previous mine developers, Atlas Corporation, who filed for bankruptcy and abandoned the land in an unreclaimed condition in 1999.
Wide Scale Damage
McEwen Mining, a Canadian Mining company, is poised to take over and create even more environmental degradation. The area would be expanded by 40,000 acres or 62.5 square miles, or about 1/3 the size of the Colorado Springs metropolitan area where TCF is headquartered. In other words, this is destruction on a grand scale.
Damage from gold mining is permanent. No amount of mitigation can return the landscape to anything approaching a natural state. Over flights of the area reveal large-scale destruction. Increasing this permanent destruction for the hope of short-term gain is not a reasonable, and certainly not an environmentally friendly decision.
For the above reasons, we urge you to select the NO ACTION ALTERNATIVE for the Gold Bar Mine Project.
Thanks very much for your consideration of our position on this important issue.
Ginger Kathrens Debbie Coffey
Executive Director Vice-President & Dir. Of Wild Horse Affairs
The Cloud Foundation, Inc. Wild Horse Freedom Federation
107 S. 7th Street P.O. Box 390
Colorado Springs, CO 80905 Pinehurst, TX 77362
719 633.3842 1-800-974-3684