By Martin Webb
After a careful review by the county-chosen contractor based in Sacramento, the citizens and organizations that make up Nevada County can safely say they have been vindicated by the Draft Environmental Impact Report (EIR) recently released to the public regarding the long-shuttered Idaho-Maryland Mine (IMM).
The over-1,000-page document contains research, analysis, and a summary report. For the reader’s understanding, it contains a helpful “List of Acronyms” section that offers up generous lists of acronyms starting with virtually every letter in the alphabet, except Q, X, and Z, and runs ten pages long all by itself…that’s right…10 pages of acronyms alone.
As part of the Draft EIR’s preparation there was a brief 30-day window of opportunity for individuals and agencies to voice their concerns for the project, listing potential adverse and negative impacts of re-opening an old mine, done via letter. This took place from July 17, 2020 through August 17, 2020 and also included a virtual public meeting on July 27, 2020 for receiving live in-person comments on the scope of the EIR and which adverse impacts to assess.
During that 30 days, comment letters were received from over 750 interested public agencies, people, and groups. This represents a line so long that, if each agency or group were given an hour to express their concerns and ask questions, it would have taken over a month to get through them all without stopping.
As noted in the Introduction, “all comments were taken into consideration.” After analyzing the 750 comment letters for redundancy, the draft EIR listed a grand total of 85 individual and separate concerns (in Table 2-1) regarding the immediate adverse impacts of opening the mine.
These 85 separate negative impacts covered the “following environmental issue areas…addressed in the EIR,” listed as 25 distinct areas of local concern and then grouped into these 13 general categories for the report:
1. Aesthetics
2. Agriculture & Forestry Resources
3. Air Quality, Greenhouse Gas Emissions, & Energy
4. Biological Resources
5. Cultural & Tribal Resources
6. Geology, Soils, & Mineral Resources
7. General Hazards & Hazardous Materials
8. Hydrology & Quality of Water
9. Land Uses, Housing, & Population
10. Noise & Vibration
11. Public Services & Utilities
12. Transportation
13. Wildfire
After analyzing all 85 individual local adverse impacts submitted based on their technical merits, Table 2-1 of the report itemizes them all and tellingly assigned the lowest dismissive designation of “No Impact” (NI) to only two out of 85 areas of concern submitted over the 30-day comment period. Both were related to farming. All other concerns have legitimate merits.
Far from being outliers, or NIMBYs with concerns based more on emotions and prejudice than facts, the report confirms that virtually all local concerns are based on technical validity, covering 83 adverse effects on our community, literally dozens and dozens of negatives. The draft EIR proves that locals know their community in significant ways that out of towners don’t.
So 83 negative impacts and concerns for the community are deemed true and legitimate by the report and its analysis, adverse in varying degrees across dozens of areas, with some rated “less than significant,” some rated “cumulatively considerable,” or even others “significant.” The word “significant” is, well, significant because CEQA law requires any negative effect rated at that level to be required to have a mitigation plan to reduce the level of significance if at all possible. Regardless of their EIR rating, these 83 are all listed as real and they are all negative.
Out of the 83 confirmed negative impacts, 32 rise to the level of significant or cumulatively considerable, the most dangerous of pre-mitigation ratings. The other 51 adverse impacts to the community remained, but were not each called “significant” when measured in isolation.
However, any thinking person can conclude that 51 separate negative impacts levied at the same time to a small local community’s cherished environment – harming everything from natural character to air & water quality to wildfire threats to hazardous materials, traffic, noise and vibration – in 51 different ways – is by definition itself one very significant impact.
Because the draft EIR considers them less than significant, nothing is to be done about any of them at all, because the EIR is allowed to rate all 51 impacts occurring in a vacuum, apart from each other in time or space. Only someone who doesn’t live in a community could ignore the combined significance of 51 negative impacts, harming our resources from air to water to fire suppression and everything in between. We don’t have that luxury.
Out of the 32 significantly adverse impacts, even after throwing all the proposed money, energy, and mitigation planning at them, the draft EIR concludes they will all still remain as adverse impacts to our community, with none ever being given a “No Impact” rating and a noteworthy four major impacts being left as still significant and unavoidable.
These revolve around increased traffic and worsening congestion at a nearby already-dangerous intersection (the Cedar Ridge “Y”), as well as damage to our local natural character in both the short term and long term. Both of those horribly negative, significant and unavoidable impacts are attacking some of the most cherished reasons people move here, visit here, and live here: minimal traffic plus the natural look and character. What a folly to significantly denigrate both of those attractions, with no possible way to avoid either damage.
So the draft EIR confirms we would start with 83 separate negative community impacts across dozens of areas of concern and local importance, and those 83 would remain as negative impacts even after required mitigation, including four rated as majorly significant and unavoidable and one rated as long term, with the other 79 community harms rated as less than significant (note: that is not “insignificant” or “no impact”). This altogether represents an enormous “collective significant impact” of dozens of problems that won’t be addressed.
The draft EIR also confirmed that this inappropriate land use would require the County to:
– Rezone parcels for different industrial use than was currently allowed or planned for
– Ignore existing building height limits in order to “allow for the construction of several structures up to a height of 165 feet” according to the draft EIR, essentially a sudden series of skyscrapers in the forest over 16 stories tall, where current zoning allows a maximum height of only 45 feet
– Allow development in potentially high-erosion areas with steep slopes greater than 30 percent
– Allow industrial development to ignore a required setback for a protected watercourse and riparian area
– Allow grading to ignore the County’s 100-ft buffer to protect the Wolf Creek floodplain
To add insult to injury, the industrial use permit being requested from the County to inflict all this ongoing damage (now confirmed as affecting several dozens of areas of our community) would kick open this door of ongoing significant damage and negative impacts for 80 years, to whoever wants to buy these rights to damage our community in the future.
Only someone that doesn’t live here, and stands to make money off selling the ground out from underneath Nevada County, while leaving behind a spoiled community with 83 negative impacts, could celebrate this draft EIR as some sort of victory or beneficial document of any kind.
This report vindicates and confirms the 750 comment letters – excluding the ones related to farming – that this proposed project would clearly damage and cause collective significant harm in 83 diversely negative and concurrent ways to our local Aesthetics, Forestry Resources, Air Quality, Greenhouse Gas Emissions, Energy Use, Biological Resources, Cultural & Tribal Resources, Geology, Soils, Mineral Resources, General Hazards, Hazardous Materials, Hydrology, Quality of Water, Land Uses, Housing, Population, Noise, Vibration, Public Services, Utilities, Transportation, and Wildfire. That is what the draft EIR says. That is what we should heed.
With mining among the lowest job creators in U.S. industry, and global industry data showing 90% of gold used for investment speculation, wealth hoarding, and jewelry, this is clearly a project no one needs, other than those who have staked their income on selling a story that this is a necessary project designed to significantly harm parts of Nevada County for the false notion of adding an insignificant <1% to our existing local job market, an existing job market that dwarfs the airy promises of IMM’s executive sales people, jobs created by the valuable gold located between our residents’ ears. If you’re looking for the gold, we already mine it.
If someone really wanted to bank on Nevada County, to invest in it and create jobs for locals, then injecting tens of millions of dollars into helping create a local business loan program would pay higher dividends than the failed IMM proposal, would create more jobs and wealth, and would not damage our community’s environment and character in dozens and dozens and dozens of ways.
We know how to create local jobs better than anyone. But investing in the community and creating jobs is clearly not the goal. Extracting local ground and turning it into out of town wealth is. We are not “people” they want to help, we are statistics they want to modify.
No to the Mine. The Mine is Dead.
Martin Webb lives in Penn Valley and is a four-time local business owner as well as 20-year local radio host. 
OTHER RESOURCES:
MINEWATCH website
GUIDE TO COMMENTING ON THE EIR (Take Action)
Randall J. Newsome
Paul Schwartz lives in Grass Valley and is a former University Capital Planner at 
Nevada County Mine Talk 