I am very concerned about the possible impacts of any significant gold mining on the water quality in the rivers and in the Chesapeake Bay.  

In the review for this study, the potential for impacts to water quality from gold mining operations must be evaluated.  Sodium cyanide solution is commonly used to leach gold from mined ore because it is a cost effective process.  But cyanide spills have resulted in major fish kills, contaminated drinking water supplies and harmed agricultural lands.  Mine tailings contaminated with cyanide are then stored in retention areas; heavy rains can cause the dams of these retention areas to fail spilling the contamination downstream.   Examples of the impact of failures can be found at https://earthworks.org/issues/cyanide/

Virginia is known for massive rain events related to tropical storms and hurricanes.  The frequency of these events is steadily increasing and can easily result in large flood events.  Any regulations developed must consider Virginia’s the impact of these heavy rains, especially considering the underlying karst geology.   Also, unlike mining in the desert West, any contamination will be washed down to the Bay with our economically import commercial and recreational fishing. 

Also the potential for contamination from a mine can continue long after the mine is closed.  Mine tailings will sit nearly forever.  Any bonding of mine operators should be on an individual mine basis.  Each mine must set aside significant funds to clean up the site after the company goes away.   Unfortunately, when things go bad and there are large financial consequences, the corporation that caused the issue may end up bankrupt leaving the taxpayers on the hook for dealing with the problem.

The impact on large scale gold mining should also look at environmental justice aspects so that mines, and the supporting infrastructure, don't negatively impact poorer communities.  

Large scale gold mining would be something very different for Virginia and we need to be very careful that the benefits for the mining operation do not become a long-term liability for the Commonwealth and its citizens.   The most stringent protections are needed to assure the long term safety of our waterways, the Bay, and all the wildlife and people who depend on and use these waters.

Thank you for considering my comments.

Sincerely,

Rogard Ross