Ted Trueblood Chapter, P.O. Box 1971, Boise, Idaho 83701

Idaho Trout Unlimited, 764 Moran Drive, Chubbuck, Idaho 83204

June 9, 2006

Richard Smith, Forest Supervisor

Boise National Forest

1249 South Vinnell Way, Suite 200

Boise, Idaho 83709-4100

Re: Atlanta Gold Company Proposal for Cyanide Heap Leach Mine

Dear Mr. Smith,

Idaho Trout Unlimited and Ted Trueblood Chapter Trout Unlimited submit these comments for consideration under the National Environmental Policy Act (NEPA) in connection with the proposal of the Atlanta Gold Company to operate a cyanide heap leach mine near Atlanta, Idaho.

The Ted Trueblood Chapter of Trout Unlimited is a membership organization and a chartered chapter of Trout Unlimited, Inc. The Ted Trueblood Chapter represents over 800 members in the Treasure Valley. Idaho Trout Unlimited represents approximately 2,200 members throughout the State of Idaho. Trout Unlimited is a non-profit corporation qualified under Section 501(c)(3) of the Internal Revenue Code. Idaho Trout Unlimitedπs mission is to conserve, restore and enhance coldwater fisheries throughout the State of Idaho. The Ted Trueblood Chapter has advanced this mission by engaging in numerous conservation, restoration and enhancement projects in Southwest Idaho, including within the Boise National Forest.

At present, Trout Unlimited is assisting in the restoration of a section of Mores Creek within the Boise National Forest by providing funding, labor and other in-kind assistance. Trout Unlimited has also devoted funding and in-kind assistance to a project to remove a culvert and replace it with a bridge on the Roaring River tributary to the Middle Fork of the Boise River. In the past, the Ted Trueblood Chapter has assisted with other projects to enhance and restore fisheries in the Boise watershed, including on Cow Creek tributary to the South Fork Boise River.

Trout Unlimitedπs (TUπs) concerns with the Atlanta Gold proposal can be divided into three categories: incompleteness of the proposal; impacts on existing uses of the National Forest; and impacts on water quality and fish habitat in the North and Middle Forks as well as tributaries. If this proposal proceeds to a Draft EIS, that EIS should consider specific alternatives which will reduce impacts on existing uses and on water quality.

I. The Supplemental Plan of Operations is Incomplete

The Boise National Forest (BNF) is considering a Revised Supplemental Plan of Operations submitted by Atlanta Gold Co. (AGC) on April 27, 2006. Previously, BNF had received a Proposed Plan of Operations and a 2005 Supplemental Plan of Operations. Despite these multiple attempts by AGC, the Revised Supplemental Plan of Operations (SPOO) is too incomplete to permit meaningful public evaluation and response. Before proceeding to a draft EIS, the BNF should require AGC to submit a more complete proposal which would allow meaningful public review, comment and participation in the NEPA process.

The SPOO is incomplete in that it omits critical elements of a complete mine plan including a Storm Water Pollution Prevention Plan, a Final Reclamation Plan, Reclamation Cost Estimate, and an Environmental Monitoring Plan.

A. Without a Storm Water Pollution Prevention Plan, TU and the Public Cannot Meaningfully Participate

Initial construction of mine facilities would start, under the SPOO, as soon as AGC receives appropriate permits. Initial stages of construction would include substantial road building, construction of multiple buildings for personnel and mine operations, and construction of a fuel depot. Each of these construction projects will disturb large areas and involve removal of significant amounts of plant material, soil and bedrock. Construction on this scale involves significant risk of erosion and resulting siltation of nearby streams and, ultimately, the Middle Fork of the Boise River.

Under several laws AGC is required to have an approved Storm Water Pollution Prevention Plan to prevent just such erosion and siltation of local waterways. The SPOO does not include such a plan but simply states one would be developed. The quality of such a plan is directly related to the environmental impacts to be expected from the mine operation and would actually present the very first such impacts. Without knowledge of how AGC intends to prevent storm water pollution of local waterways, TU, its members and the general public cannot determine what environmental impacts are likely or whether appropriate remedial, preventative or mitigating measures are included or need to be required.

B. Without a Complete Reclamation Plan and Reclamation Cost Estimate, TU and the Public Cannot Meaningfully Participate

While the SPOO discusses reclamation in general terms, a Final Reclamation Plan is deferred until ≥Final EIS≤ stage. While the proposed mine has an expected lifespan of 5-7 years, the disturbance to local soils and topography are essentially permanent, and the SPOO recognizes that reclamation may be required ≥in perpetuity.≤ While AGC will reap its profits within that 5-7 year span environmental, social/cultural, and economic effects of the mine will be felt within the BNF for many decades at the very least, and most likely in perpetuity.

The environmental and social/cultural effects of the mine depend to a large extent on the quality of reclamation efforts. The economic effects of the mine include the cost of reclaiming the mine property, remediating discharges from waste rock piles and heap leach pads, and treating water that accumulates in abandoned pits. Evaluation of those economic effects requires an understanding of the likely costs and efforts to ensure those costs are borne by AGC. Yet AGC has not presented a reclamation plan or reclamation cost estimate, and neither TU, its members, nor the general public can comment meaningfully.

In addition, 36 CFR 228.13 requires that in determining the size of the bond, the BNF must consider ≥the estimated cost of stabilizing, rehabilitating, and reclaiming the area of operations.≤ Without an estimate of those costs it is impossible for BNF to comply with that section, or for the public to assess whether compliance has been attempted or achieved.

C. Without an Environmental Monitoring Plan, TU and the Public Cannot Meaningfully Participate

As discussed in more detail in the following sections of this letter, operation of a cyanide heap leach mine creates risks of toxic spills into the local environment while the mineπs transportation plan creates risks of spills into waterways well away from the mine site. Experience teaches that rapid response to spill incidents can often effectively contain the spilled toxins, minimizing contamination of waterways and negative effects on social/cultural values and economic interests. An effective Environmental Monitoring Plan makes rapid response possible and also directs that response in the most effective manner.

Because the environmental, social/cultural and economic effects of the mine operation will depend on the efficacy of environmental monitoring, the lack of a complete Environmental Monitoring Plan makes impossible the full evaluation of those effects and meaningful assessment and participation by TU, its members and the public.

D. BNF Should Require Submission of a Complete Plan of Operations Before Proceeding to a Draft EIS

Before proceeding to a Draft EIS the BNF should require that AGC submit a complete plan of operations that includes a Storm Water Pollution Prevention Plan, Reclamation Plan, Reclamation Cost Estimate, and Environmental Monitoring Plan. Each of these plans is critical to meaningful public review and comment upon the SPOO and implementation of both the letter and spirit of NEPA. The Boise River provides a substantial portion (approximately 20%) of Boiseπs drinking water. The Boise River watershed provides important recreational opportunities to citizens in the Treasure Valley. While the effects of this proposal might be less serious in more remote locations or drainages, the proximity to Boise and the importance of the Boise River to the residents of the Treasure Valley requires that the public be permitted every possible opportunity to review the proposal in detail and participate in the NEPA process.

The details of the missing portions of the proposal, particularly the Final Reclamation Plan and Environmental Monitoring Plan will effect the likely environmental impacts of the proposal as well as the alternatives that BNF should be considering in the Draft EIS. When and if a SPOO containing these missing elements is submitted, BNF should re-open the proposal to scoping comments by the public and all interested agencies.

II. The SPOO Must be Modified to Reduce Impacts on Existing Uses

BNF lies a few short miles from the City of Boise and Idahoπs Treasure Valley. The mine site is within a few miles of the Atlanta. The Boise Metropolitan Statistical Area (MSA) is among the ten fastest growing MSAπs in the nation according to the U.S. Census Bureau. Because of proximity to a growing population center BNF generally, and the North and Middle Forks of the Boise River in particular, see heavy recreational use. In drafting an EIS for the Atlanta Gold project, BNF must consider alternatives which will minimize or eliminate conflicts with other users.

BNF sees extensive recreational use for hiking, camping, fishing and hunting, among other uses. Different aspects of AGCπs proposed operations will impact these recreational uses.

Hiking and camping will be affected primarily by AGCπs transportation plan. The current transportation plan calls for convoys of multiple trucks driving to and from the mine site during night time hours several nights per week. On both the North Fork and Middle Fork Boise River, developed campgrounds and even ideal spots for dispersed camping lie along or very near to the roads that will be used by AGCπs convoys. The likelihood of convoys of twenty or more trucks driving past a campground at twenty miles per hour, only to return three hours later on the trip back to Boise, will utterly destroy the values sought by many of those who go camping in the first place. AGC should be required to further reduce the number of trips to and from the mine site, and should also be required to relocate campgrounds farther from the roads which make up its primary and secondary transportation routes.

Harvest statistics from Idaho Fish and Game reveal that Unit 39 which encompasses most of the Boise River watershed offers outstanding opportunities for big game and upland bird hunters. In just the last year, the Boise watershed produced nearly 700 deer and over 400 elk for Idaho hunters, and the area has become known for its turkey hunting as well.

The waters that will be effected by the mine operations include well-known and popular fisheries including the North and Middle Forks of the Boise River and Crooked River, among many others. Aside from the risk of either catastrophic or long-term impacts on water quality, discussed below, the mine operation would reduce or eliminate current use of some portions of the waters on the BNF for fishing. Waters within the mine site, which currently hold redband and likely bull trout, would be closed to fishing by the public. Truck convoys, particularly on the Middle Fork road would significantly degrade the outdoor experience currently enjoyed by the thousands of anglers that visit that portion of the watershed.

The Draft EIS must evaluate AGCπs effects on hunting through disruption of wildlife spawning and migration patterns, and consider alternatives to minimize conflicts with the hunting public. Such alternatives should include limiting the transportation of supplies, equipment and workers during the big game hunting season (primarily September and October). In addition, the Environmental Monitoring Plan which AGC has failed to include in its SPOO must include monitoring of effects on game species including deer, elk, turkey, and upland birds.

AGCπs proposal could also impact downstream water users including municipalities in the Treasure Valley, irrigators, and industrial users such as Micron Technologies. Impacts on all of these users should be addressed in the Draft EIS.

III. The SPOO Must be Modified to Minimize Impacts on Fisheries and Habitat

USDA FS regulations are specific as to protection of fisheries and evaluation of mine transportation plans. 36 CFR 228.8(e) requires BNF to ensure that AGC ≥take[s] all practicable measures to maintain and protect fisheries and wildlife habitat which may be affected by the operations.≤ 36 CFR 228.8(f) requires AGC to ≥construct and maintain all roads so as to assure adequate drainage and to minimize or, where practicable, eliminate damage to soil, water, and other resource values.≤ Operations at the mine site and AGCπs transportation plan both present risks of acute and long-term releases of toxins into watersheds. The Draft EIS must present alternatives that, consistent with 36 CFR 228.8(e), require ≥all practicable measures to maintain and protect fisheries.≤

A. Risk of Releases from Operations Must be Eliminated

Release of toxins from mine operations could arise in several ways. The use of cyanide in the leach process involves piping and other wise transporting the solution which presents risks of pipeline and pond ruptures. The use of other toxins in the construction and processing operations presents other risks. The storage of large volumes of diesel fuel and the use of large mining equipment presents risk of spills of fuel, oil and other fluids, all of which could lead to fishkills and damage to local waters. In addition, piles of waste rock and of fully processed ore can easily lead to releases of arsenic, mercury and other naturally occurring toxins which would otherwise be safely isolated within bedrock. Each of these risks must be assessed, and the Draft EIS must consider alternatives to address each of them.

1. Process Fluid Leaks

Experience teaches that pipelines carrying process fluids including cyanide solution and pregnant solution will leak unless properly constructed. Alternatives to be considered must address methods of pipeline construction that include ≥all practicable measures≤ to protect fisheries. These would include double-walling of pipelines, burying or elevation of pipelines to avoid accidental damage and all other alternatives identified by appropriately qualified engineering staff.

2. Fuel and Lubricant Leaks

AGCπs operation calls for operation of numerous pieces of large equipment. Ore-hauling trucks, loaders, trucks for delivery of materials and supplies, as well as pick up trucks and other small vehicles. AGCπs proposed fuel depot presents a significant risk of diesel leaks into surrounding waters. Alternatives to be considered in the Draft EIS should include indoor storage to ensure that retention structures are not overwhelmed by snowfall and/or stormwater, best available liner materials, and limiting the maximum capacity of fuel storage to limit the effect of any leak.

3. Waste Rock and Processed Ore Discharges

The creation of large volumes of waste rock presents the substantial risk (near-certainty) of release of arsenic, mercury, lead or other materials found in the rock, but presently secure from release by placement within impervious bedrock. AGCπs operations plan calls for capping waste rock piles and heap leach pads with non-reactive materials, soil, and plant material. While such measures may reduce leaching of toxins, they will not prevent it. The Draft EIS must address ≥all practicable measures≤ to prevent such releases including removal from the mine site and complete isolation from natural precipitation in perpetuity.

B. Risk of Releases from Transportation Must be Eliminated

AGCπs transportation plan is deeply flawed and presents substantial risk of catastrophic release of toxins into waterways. The plan calls for convoys of tractor-trailers traversing various forest roads. These roads are well-known to BNF recreational users to be narrow, twisting, poorly maintained, and inordinately dangerous even for recreational traffic. AGCπs transportation plan does not call for adequate road improvements, does not provide for adequate spill response capability, and is too incomplete to allow for meaningful public analysis and comment.

1. Inadequate Road Improvements

AGCπs transportation plan calls for minor improvements to widen certain curves to allow passage of large trucks. These improvements are inadequate and do not comply with either 36 CFR 228.8(e) or (f).

The entire transportation route should be significantly widened to permit passage of large vehicles. Bridges should be upgraded or replaced to ensure their ability to carry the volume and weight of traffic, as well as to ensure the ability of guardrails to contain vehicles of the anticipated size and weight. Appropriate structures to keep such vehicles within the roadway should be constructed. Mine Safety and Health Administration regulations provide an appropriate model for traffic safety including 30 CFR ßß56.9300, 56.9313, and 56.9315 which should be applied to all portions of the primary and secondary transportation routes which are not on paved roadways.

In addition, AGC should be prohibited from using trailered haul equipment, limited instead to solid frame vehicles. Adoption of this alternative would reduce the overall size of vehicles using the roads, making them substantially safer.

2. Inadequate Spill Response Capability

AGCπs transportation plan calls for the convoying of vehicles during nighttime hours on remote mountain roads several hours away from qualified Hazmat spill response teams and equipment. A spill occurring, for instance, along Swanholm Creek would not be reachable by Boise-based Hazmat response crews for a period of several hours, by which time contaminants would have moved far downstream. In order to provide for adequate spill response, all convoy drivers should be fully trained in spill response and clean-up of hazardous materials. In addition, necessary equipment and supplies including protective clothing, self-contained breathing apparatus, absorbent materials and floating booms should be located at intervals of no greater than five miles along the primary and secondary transportation routes. All transportation personnel should be fully trained in the proper and safe use of such equipment.

3. BNF Should Require a Complete Transportation Plan

AGCπs transportation is too incomplete to permit adequate public assessment and comment. While the plan addresses the movement of diesel fuel, cyanide, and other bulk materials, mine operations will result in significant traffic that is not specifically accounted for or addressed by the transportation plan. In addition, the Transportation Plan does not address transportation needs during periods when the Middle Fork Road is closed, as it is currently.

Residential waste, septic tank waste, food supplies, and supplies of parts for equipment are not accounted for in AGCπs transportation plan. These items could result in dozens of hundreds of additional trips by trucks of various sizes and would have to continue throughout the year. While AGC attempts to give the impression that hazardous materials would not be moved during winter months, waste materials would necessarily be moved year-round. Neither the transportation plan nor the SPOO address what would occur during extended closures of the primary and secondary transportation routes, such as the closure occurring as of the date of these comments. Until all of these items are addressed the transportation plan is incomplete. Drafting of an EIS should be delayed until AGC submits a transportation plan that is sufficiently complete to allow public assessment and comment.

C. Roadway Erosion and Siltation of Waters Must be Eliminated

Running significant commercial traffic along the primary and secondary transportation results will greatly increase roadway breakdown, erosion and siltation of the North and Middle Forks of the Boise River as well as numerous other tributary streams, many of which provide habitat for threatened bull trout as well as native redband trout.

Alternatives to minimize or eliminate siltation of streams should be considered in the Draft EIS. These include hardening of the entirety of the primary and secondary transportation routes by paving and installation of appropriate drainage structures leading to settling locations to remove sediment and silt before stormwaters reach waterways. To the extent roadways are hardened they may increase run-off and stormwater pollution, which should also be addressed in alternatives considered in the EIS.

Dust control measures should also be addressed. The volume of traffic proposed by AGC along dirt roads will result in substantial dust. Dust will coat roadside and riparian plant material with a variety of impacts. Loss or reduction of riparian vegetation could impact water quality as a result of temperature gain due to reduced shading, and increased erosion of banks. Reduction or reduced quality of vegetation could also impact non-aquatic wildlife by reducing available browze. Alternatives to consider to reduce or eliminate such impacts include hardening or treatment of roads. As with erosion control, the environmental impacts of any proposed mitigative or remedial measures must also be addressed.

D. Long Term Contamination and Reclamation Must Be Fully Funded

Long after mine operations cease, risks of water contamination from erosion and reaction leading to release of toxins will persist. AGCπs SPOO does not address funding of long-term reclamation beyond a vague statement that it is looking into whether a reclamation annuity to provide treatment in perpetuity can be established. Without a long-term treatment plan the SPOO is incomplete and to ambiguous to permit public assessment and comment. A Draft EIS should not be prepared until long-term reclamation and treatment funding sources are fully addressed in an additional SPOO by AGC.

IV. Conclusion

Before proceeding to a Draft EIS, BNF should require AGC to submit a SPOO that is sufficiently complete to permit meaningful assessment and comment by the public and interested parties, including TU. The proposed operation puts waters, fisheries and wildlife at risk. In addition, it risks destroying the positive effects of numerous conservation and restoration projects undertaken by TU, BNF and numerous other agencies and non-governmental organizations. Given the risks not only to the environment but to the prior efforts and work a complete SPOO is necessary before the NEPA process continues.

In the event BNF decides to proceed to a Draft EIS all of the concerns and alternatives addressed herein should be reviewed. Ultimately, AGC should not receive permits to commence operations unless and until safeguards adequate to comply with 36 CFR 228.8 are in place, and the BNF is satisfied that risks to the cultural, social and economic environments (including to the City of Boise and the greater Treasure Valley) are eliminated.

Sincerely,

James Piotrowski