This map shows the Gold Bar Mine area, the approximate HMA (in solid red) and HA boundaries(in broken red lines), the approximate Mt. Hope Mine Project area and well field, and the approximate combined Gold Bar Mine and Mt. Hope Mine 10′ water drawdown area (in blue).  The 10′ water drawdown (in blue) effects almost the entire Roberts Mountain HMA.  The 1′ water drawdown will effect a much larger area.  (Streams can dry up with as little as a 1′ water drawdown.)

BE SURE TO LOOK AT ALL 8 MAPS AT THE BOTTOM OF THIS ARTICLE.

It’s best to write comments in your own words so that the BLM counts each comment as one, instead of counting a thousand similar comments/form letter as only one.  You can read the joint comments submitted by Wild Horse Freedom Federation and The Cloud Foundation below, and a quick summary on pages 5-41 of the DEIS HERE.  Comments are due by April 17, 2017.

Some suggested talking points are:

1. Be sure to ask for the NO ACTION ALTERNATIVE.
2. The Gold Bar mine project will use over 2 billion gallons of water in 10 years.  The BLM needs to take into consideration past (historic), current and likely future droughts and climate change when deciding if they will approve this DEIS.
3. The Project will negatively impact the water, forage, safety, and “free-roaming” abilities of the Roberts Mountain wild horse herd on the Roberts Mountain HMA, as well as the nearby wild horse herds on Whistler Mountain and Fish Creek Herd Management Areas.
4. The BLM is minimizing the area of impact by only indicating the 10′ water drawdown, and not the 5′ or 1′ water drawdown.  The 5′ and 1′ water drawdown will cover a much larger area of land.  A stream can dry up with as little as 1′ of water drawdown.
5. When the nearby Mt. Hope mine becomes operational, it is proposed that it will use an additional 7,000 gallons per minute for the life of the mine (40-50 years).  Mt. Hope mine will use over 3 1/2 billion gallons of water per year and over 36 billion gallons of water in 10 years.
6. The BLM refers to the 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).  These are 25 years old and outdated.  Ask for updates of this Plan and Handbook for this DEIS.
7. The area of Gold Bar Mine will be expanded by 40,000 acres or 62.5 square miles, creating more environmental degradation.

The DEIS is available online at HERE.   Interested individuals should address all written comments to Christine Gabriel, Project Manager, using any of the following ways:

Fax: (775) 635-4034

Email:  blm_nv_bmdo_mlfo_gold_bar_project_eis@blm.gov

Mail:  Bureau of Land Management

Mount Lewis Field Office

50 Bastian Road

Battle Mountain, NV 89820

Wild Horse Freedom Federation and The Cloud Foundation submitted these joint comments regarding the BLM’s Gold Bar Mine Project:

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Road

Battle Mountain, NV 89820

Email: blm_NV_bmdo_mlfo_gold_bar_project_eis@ blm.gov

DATE:  April 5, 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 oppose 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.

Economic Uncertainty

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.

Sincerely,

Ginger Kathrens                             Debbie Coffey

Executive Director,                         Vice-President,

The Cloud Foundation, Inc.          Wild Horse Freedom Federation

107 S. 7^th Street                                P.O. Box 390

Colorado Springs, CO 80905        Pinehurst, TX  77362

MAPS:

Map 1

http://wildhorsefreedomfederation.org/wp-content/uploads/2017/03/Gold-Bar-Mine-Map-1.pdf

Map 2

http://wildhorsefreedomfederation.org/wp-content/uploads/2017/03/Gold-Bar-Mine-Map-2.pdf

Map 3

http://wildhorsefreedomfederation.org/wp-content/uploads/2017/03/Gold-Bar-Mine-Map-3.pdf

Map 4

http://wildhorsefreedomfederation.org/wp-content/uploads/2017/03/Gold-Bar-Mine-Map-4.pdf

Map 5

http://wildhorsefreedomfederation.org/wp-content/uploads/2017/03/Gold-Bar-Mine-Map-5.pdf

Map 6

http://wildhorsefreedomfederation.org/wp-content/uploads/2017/03/Gold-Bar-Mine-Map-6.pdf

Map 7

http://wildhorsefreedomfederation.org/wp-content/uploads/2017/03/Gold-Bar-Mine-Map-7.pdf

Map 8

http://wildhorsefreedomfederation.org/wp-content/uploads/2017/03/Gold-Bar-Mine-Map-8-with-mining-water-drawdown-and-grazing.pdf