To: Colorado Division of Reclamation, Mining and Safety (DRMS)
Re: Mining Permit Number M2021046
We are writing on behalf of Trout Unlimited Chapter 509 (Pueblo); Pikes Peak Chapter (Colorado Springs); Collegiate Peaks Chapter (Salida); and Colorado Trout Unlimited (statewide) to express our concerns with the mining permit application of Zephyr Minerals for the Dawson Gold Mine (DGM) located 4 miles southeast of Canon City, 1.5 miles from the city limits and 1.3 miles from Grape Creek. Our major concern is the potential for negative impact on the fisheries of Grape Creek and the Arkansas River. Grape Creek is a well-known wilderness fishery – providing local anglers and tourists the opportunity to catch healthy Rainbow and Brown Trout in a high-quality small stream setting.
Specifically, we are concerned with three (3) potential issues:
Dewatering of Grape Creek
The design and use of a FTSF (filtered tailings surface facility) for tailings disposal and potential surface/ground water pollution
Plans and projected cost of reclamation
The Bureau of Land Management has worked hard with the DeWeese-Dye ditch company to augment and reduce low winter flows and we are concerned this could be negated by the mining operation.
According to the mining application, “Grape Creek to the north of the mine area appears to be in connection with the Precambrian material based on winter base flow conditions and the perennial nature of the creek. Based on the local topography, Grape Creek appears to be a gaining stream draining the Precambrian material immediately adjacent to it.” Zephyr claims no ground water within 1.1 miles of the mine will be affected (Grape Creek is 1.3 miles), but also states “As indicated above, Grape Creek will be identified as a point of depletion for augmentation purposes, but actual impacts are unlikely due the fractured rock geology at the site. The mine operator will implement the augmentation plan, including the acquisition and dedication of any necessary water rights to operate the plan. The augmentation plan will protect senior water rights from injury resulting from depletions to the surface water system.” What is the actual augmentation plan? How will Grape Creek be monitored for depletion and by whom? What water sources will be acquired to augment? Are there senior water rights that can protect the stream? Has Zephyr been in contact with the DeWeese-Dye ditch company to discuss this issue prior to application?
Although Windy and Dawson Gulches do not directly enter Grape Creek, they terminate in sedimentary rock and the identified Dakota Formation aquifer and connect to the drainage to Grape Creek. An above ground disposal of mine/mill tailings (FTSF) has been proposed with channels to divert ground water during precipitation events and buttresses to prevent tailings from moving down-slope at the beginning of the disposal process. Any breach of the FTSF would result in movement of tailings toward Grape Creek and possible contamination of the aquifer. Are these channels designed for a 100-yr event, a 500-yr event? A 1000-yr event? Zephyr states they anticipate a 50% infiltration rate – this appears unlikely given the Precambrian geology and steep topography of the mine site. Will these channels be maintained or improved after mining is completed? What is the consequence of the “dry” tailings becoming saturated?
The entire proposed budget for reclamation is $261,813. This seems unrealistically low and doesn’t appear to factor in inflation and continual monitoring of ground and surface water, or condition of the FTSF after mining is completed. The Pueblo TU Chapter is addressing several spots of erosion on the tailwater below Pueblo Dam and the projected cost may be greater than Zephyr’s total proposed reclamation budget for an underground mine with above ground mill operations and tailings, affecting 80+ acres.
With a projected LOM of only five-years, we are also concerned that Zephyr could abandon the project mid-stream if the multiple factors needed to make these “potential reserves” viable failed to materialize. The whole project appears speculative in nature, with unproven reserves as stated in their Gold in Colorado presentation dated August 17, 2021 – “It should be noted that the Dawson Property PEA is preliminary in nature and includes inferred mineral resources that are considered too speculative geologically to have the economic considerations applied to them that would enable them to be categorized as mineral reserves. There is no certainty that the PEA forecast will be realized or that any of the resources will ever be upgraded to reserves. Mineral Resources that are not Mineral Reserves do not have demonstrated economic viability.”
This last statement seems to contradict the standard reason for applying for a mining permit. Combining all these factors, we are strongly opposed to the mining permit as submitted by Zephyr Minerals.
David Nickum, Executive Director Colorado Trout Unlimited
Steve Wolfe, President Southern Colorado Greenback Chapter of Trout Unlimited (Pueblo)
Allyn Kratz, President Pikes Peak Chapter of Trout Unlimited (Colorado Springs)
Rick Helmick, Vice-President Collegiate Peaks Chapter of Trout Unlimited (Salida)