After attending the first meeting of the Commonwealth's work group meeting yesterday (02/25/22), I offer the following comment:
Focus the Commonwealth's efforts to fill in the gaps not addressed by the NASEM whose work is peer-reviewed.
According to the NASEM website. the scope of their effort is:
"To evaluate the impacts of gold mining in Virginia, with an emphasis on potential impacts of gold mining on public health, safety, and welfare. The committee’s final report will include conclusions and recommendations based on the study.
The study will:
1) Briefly describe the geologic and mineralogical characteristics of the main gold deposits in Virginia, and the types of modern gold mining operations used with comparable deposits in other domestic or international locations.
2) Summarize the Commonwealth of Virginia’s existing regulatory framework for gold mining and processing sites (for example, bonding, reclamation, closure, and long-term monitoring) and compare to other states with current or recently closed gold mining operations. This summary will include a discussion of relevant air and water quality regulations, as well as Chesapeake Bay watershed protections.
3) Evaluate the impacts of potential gold mining and processing operations on public health, safety, and welfare in the Commonwealth of Virginia.
This evaluation will include:
a. Discussion of current gold mining operations at sites with comparable geologic, mineralogical, hydrologic, and climatic characteristics to those found in the Commonwealth,
b. Potential impacts of different leaching and tailings management techniques on downstream communities in the Commonwealth,
c. Whether existing air and water quality regulations in the Commonwealth are sufficient to protect air and water quality, and
d. Whether existing bonding, reclamation, closure, and long-term monitoring of sites for potential gold mining are sufficient to protect air and water quality."
What is missing from the NASEM scope? From the VA Energy website: "The local equity and environmental justice issues, and environmental and human health concerns of the local community."
I urge the work group to not duplicate the efforts of the NASEM. I recommend that the work group consider adding an education component to inform the public (and work group members) of how gold mining processes occur.
Dear Virginia Regulatory Town Hall,
My name is Indira Fayson, and I am writing to inform others on the impacts of gold mining and how the process has impacted the public health, safety, and welfare of the Commonwealth. I also hope to spread light on how the EPA hopes to decrease the amount of waste and emissions that is produced each year from gold mining.
Gold mining is one of the most destructive industries in the world. It displaces communities, it can contaminate drinking water due to mercury and cyanide, and it endangers the people and ecosystems. According to “Earthworks,” producing enough gold for only one wedding ring results in over 20 tons of waste. When you think of how much waste we produce from one small ring, imagine how much waste gold mines are producing a year. Gold mining has also created toxic waste and has displaced our environment. There are different types of gold mining that are known for their “dirty” practices. These practices are called open-pit mining and cyanide heaping. Within these practices, when they produce waste, it produces a thick gray sludge that is full of toxic chemicals such as cyanide. When these run into our oceans, it destroys many oceans life, especially the coral. Many gold mines create dams to “prevent” the toxic chemicals from spreading, but these chemicals can still seep into the ground and into groundwater and cause spills. According to ‘Brilliant Earth,’ “the world’s estimated 3,500 dams are built to hold mine waste, one or two major spills occur per year.” A major spill can cause up to 25 million cubic meters of waste with high levels of cyanide. Finally, gold mining is dangerous for the workers. Today, there isn’t a newer and more modern way to effectively gold mine. A lot of these practices have been the same since 1947. From 1947 to now we have evolved more, and our environment has grown a lot more since then as well. With these old practices being used, it can cause injuries to these workers and the toxic chemicals and poor working conditions can also poison these workers as well.
While researching, I wanted to see if there are any ways that could help reduce the amount of toxic waste and emissions from gold mining. According to the EPA, on February 17, 2011, the EPA promulgated National Emissions Standards for Hazardous Pollutants for gold ore processing and production facilities. From this impact, the EPA estimates that over 1460 pounds of mercury emissions will be reduced per year. This would be a 77% reduction from the previous 2007 levels. While this is a great step into helping our environment, it’s still a very minuscule amount when looking at the grand scheme of things. With the existing air and water quality that we already have regulated and set in place; gold mining would still put these regulations at risk. There would have to be a better and safer way to continue gold mining to continue to protect air and water quality. I believe that we have long ways to go to make gold mining something that doesn’t impact our environment too negatively. Although we are making small steps, there is still going to need to be a lot stricter regulations to keep the people and their health and our environment safe.
Dear Virginia Department of Energy,
My name is Ariq Abdullah, and I am a student at Montgomery College in Maryland conducting an Environmental Biology project where I must submit a public comment. I want to start by saying I believe many issues need to be evaluated by the state for safety and public health. I want to recommend that the state needs a better understanding of modern methods of gold mining. Virginia does not have the experience to run a gold mine. Treating it like any other mine may result in disaster because of the outdated regulations and methods that will contaminate the people of Virginia’s air they breathe and the water they drink. According to the Department of Mines, Virginia’s last gold mining recorded was 75 years ago, in 1947. We have seen the damage unregulated gold mines with outdated methods have done in the U.S and around the world. In February, just last month, there was an explosion in Burkina Faso at an unregulated gold mine where 60 plus people were killed.
Additionally, if these gold mines do not work out in Virginia and end up abandoned, this will also cause immense harm to the environment affecting Virginia and its downstream communities. Abandoned mines, in general, are known to contaminate ground and surface water through acid mine drainage discharges. For example, in 2015, at the abandoned Gold King Mine in Silverton, Colorado, an estimated 3 million gallons of toxic tailings were accidentally released into a branch of the Animas River by workers with EPA and contractors. A tremendous amount of lethal damage was done to Colorado and three other states, too, due to this strategic and easily preventable disaster. Environmental disasters due to mining result from negligence and outdated methods and regulations. In conclusion, I am glad that a workgroup has been established, and I hope the state considers my recommendations during their evaluations.
Dear Virginia Regulatory Town Hall,
Gold mining is one of the greatest threats to our societies and environment, however its industry has a great prevalence nevertheless. The mining of gold is proven to contaminate ground and surface water, displace communities who reside downstream from mines, as well as devastate habitats; despite these effects, Virginia continues to open new mines. Harvesting gold is an incredibly wasteful process, however the industry is so prolific in our society that it continues growing. According to "Earthworks," a process known as heap leaching is performed. This process drips cyanide into heads of gold ore, stripping away the gold so that it can be collected in a pond. This operation is heavily wasteful, with almost 99.99% of the heap becoming waste. Measures to prevent the excess cyanide from entering bodies of water are taken, however they are not full-proof. This results in ocean habitats, namely coral, to be negatively impacted.
As well as entering above ground bodies of water, cyanide and mercury are entering groundwater and aquifers. The leaching of these chemicals causes workers to be impacted as well, making working the mines very dangerous and at times life threatening. In 200, a fatal fire broke out in Aracoma Alma Mine #1, killing two workers. This fire proved to be fatal because the mines were not easily escapable, and the workers were trapped inside; this proves how dangerous this industry is for its workers.
In addition to impacting workers and ocean organisms, humans living on reserves and other rural communities are being affected. Rural communities typically aren't owned by those living on the land, so when untapped gold deposits are detected, their homes are displaced to open mines. This causes these communities to be placed in sudden homelessness, which often cannot be recovered from. Abandoned mines leak acid drainage into downstream communities, contaminating their drinking water. With no clean drinking water, these communities grow sick and weak, and can even cause death.
Regulations are necessary to ensure the safety of mine workers, and the preservation of our natural habitats and environment. It is crucial that we continue taking steps towards improvement, and I hope that these points are considered during evaluation.
My name is Thuta Maung. I am a current student at Montgomery College in Maryland. I am writing this comment with the hope that my comment will somehow someway help the community. I believe Virginia should not focus on mining gold. As with any mining industry, gold mining comes with great environmental risks. Regulations in Virginia are not ready for gold mining. Gold mining should be strictly regulated to minimize environmental damage.
Chemical runoff from unregulated gold mining affects the communities negatively. Those cannot be easily cleaned or reversed. I believe it is better to stop the risk than to allow it. We can make money somewhere else. We cannot undo the environmental damage.
Dear Virginia Department of Energy,
My name is Abbie Zuravsky, and I am commenting on the current conditions our environment faces today from the effects of our gold mines. An article from the Bay Journal recently conducted a study on the land around the Rapidan River in Orange County, Virginia. In many places, such as Orange County, traditional and small-scale gold mining uses mercury in a process known as amalgamation. For those that do not know, amalgamation is a method used to bind gold nuggets together using mercury. The mercury is then burned off in an industrial boiler, causing some particles to be released into the air and water. If ingested, mercury is toxic to humans. If one is to consume a small amount of mercury every day, it could build up in your body until it causes headaches, tremors, and even kidney damage. The term "Mad Hatter" was coined in the 18th century to describe the insane-like symptoms caused by mercury poisoning in many men who worked in the hat industry.
There have been no indications of any type of clean-up in the past 30 years. In 1988 there were talks of resuming mining operations but they never went into effect. Even then, streams around the river were found to have mercury tailings in the riverbed. That was proven to be from a previous mining operation; but in 2010, Mercury in fish tissue was found in a nearly 10-mile stretch of the River, which declared that stretch impaired- meaning the water quality is not safe. This is an issue that may turn up again so I propose the Rapidan river should be routinely tested for any carcinogens. I'm glad to know there is an effort to solve these problems left by the mines and can't wait for the action to be taken.
To the Virginia Department of Energy and Virginia Regulatory Town Hall,
My name is Jamie Montoya and I’m a Criminal Justice student at Montgomery College in the neighboring state of Maryland. In my studies at MC, I have had the opportunity to receive a course in Environmental Science per requirements of my degree. In this class, I have come to learn the importance and the gravity that humanity’s influence has on our environment, especially regarding ecological studies, environmentalism, and how our actions can have drastic impacts on the ecosystems around us.
Gold mining is certainly one of many destructive examples of how human activity has the potential of destroying habitats, contaminating life-sustaining water sources with toxic substances, and displacing communities of people who live in surrounding areas where gold mining is prevalent. I write this comment urging you to reconsider the idea of gold mining in the Commonwealth state of Virginia.
According to Clean Earth Technologies, gold mining has been identified as one of the human activities that may negatively impact the quality of the environment. As a process that removes soil and vegetation and produces burial beneath waste disposal sites, mining destroys natural ecosystems. Mining sites where the extraction of gold occurs is contaminated with all sorts of chemicals and heavy metals, if not extracted properly, which is what happens in the majority of these sites, these “heavy metals can be released into the environmental media, especially water, sediment and soil.” They also go on to say that tandem with changes in the physical and chemical properties in the Lithosphere, heavy metals in tailings can be transported to, dispersed to, and accumulated in plants and animals. They can also be passed up the food chain to human beings as the final consumers. If you were to believe that the mining of gold would not affect people, that would be a grave and erroneous conclusion. As this not only affects the food chain and the environment, but the gathering of miners and people willing to work in such conditions of those in the gold mines would mean risking their lives as well. There have been countless accounts of miners in the nation and out of the nation that have died while working in these mines, either from respiratory illnesses from breathing in the toxic air in these mines or from mines collapsing above them while they work for the gold they are pushed to find. Along with the repercussions to people, the environment is ultimately paying the price for the effects of gold mining. As we are all interconnected with the planet and the environment, what affects one affects all. Gold mining should have never existed nor should it continue to go on for the sake of the planet and those whom inhabit in it.
Hello, I am a concerned citizen and Community College student at Montgomery College just across the border in Maryland, I am writing today In regards to Resolution HB 2213 discussing the allowance of Gold mining in the Commonwealth of Virginia. Gold mining is an activity that is highly destructive to the environment, it can lead to severe water contamination, destroy habitats and displace communities. For this reason, the commonwealth of Virginia should not allow gold mining in the state. While the bill will have to pass inspections from the Virginia Council on Environmental Justice and will include input from Native American communities who depend on the land the drilling will take place on, it's still an unjustifiable risk for little to no reward. The existing regulations for air and water pollution aren’t enough to protect the environment from the degradation caused by gold mining. Three-quarters of the world's gold overlap with regions of high conservation value often destroying these areas and causing a great deal of harm to the environment.
The environmental impacts of gold mining greatly outweigh the economic benefit, especially since it’s a Canadian company that’s interested in the drilling so the profits of the activity wouldn’t even benefit the local economy rather it’d benefit Canadian corporations. Most of the revenue made from the operation would be pumped into the Canadian economy as that is where this corporation is based and therefore it’ll mostly be the Canadian government collecting the money from such a large operation. Additionally, the jobs it will bring to the local area will have a minimal effect on boosting the economy when compared to the damage it’ll cause to the surrounding infrastructure and the health of the general population.
One gold ring produces 20 tons of waste, in fact, mining produces tons of chemical waste as it results in the dumping of arsenic, lead, mercury, and cyanide into rivers and streams at dangerously high rates. 180 tonnes of chemical waste is dumped into the water annually as a result of gold mining this is lethal to marine ecosystems that depend on clean energy to survive. Many of these ecosystems are already at risk of being wiped out and gold mining would practically finish the job. Additionally, marine and other wildlife ecosystems are one of the biggest tools we have to combat pollution and climate change so gold mining would not only hinder the use of this tool but actually make pollution worse.
The residents of the state of Virginia also be compromised as gold mining releases tons of airborne elemental mercury every year this airborne mercury could very easily find its way into the air Virginians breathe causing long-term health effects. Additionally, gold mining produces sulfuric acid that can find its way into drainage systems. The environmental impact of this activity is obviously tremendous, and the risk it poses to human life can not be ignored.
While supporters of the resolution might state that gold mining will bring jobs to the commonwealth we must ask ourselves, at what cost? Is sacrificing the beautiful wildlife of Virginia worth doing for dirty money? Is risking the health of thousands of citizens of this great state worth doing for mere minerals? It is the job of the government in our society to protect its constituents from threats to their inalienable rights and to look out for their well-being, allowing for such a dangerous practice to occur would be a flagrant violation of the responsibilities entrusted to those in charge of governing. Only when the last tree has died and the last river has been poisoned and the last fish been caught will we realize we cannot eat money. -Native Cree Proverb
Earthworks, No Dirty Gold, March 10, 2022
Blake, J. (2021, December 2). Metal mining in Virginia risks public and environmental health. The Piedmont Environmental Council. Retrieved March 31, 2022
Alastair Bland, The Environmental Disaster that is the Gold Industry, Smithsonian Magazine, February 14, 2014
I read the comments on this proposal and am not surprised the assumptions commenters make in reference to small-scale mining. Firstly, nobody uses mercury for these small-scale operations, nobody. What happens is the small-scale miner, in the activity of mining a creek scoops up gravels and run them through a sluice box and it traps the heavy items like gold, mercury, discarded trash and lead weights from fishing. The very act of this process removes pollutants from the water ways. It does not "add" anything as some commenters are stating. To compare the small-scale mining in Virginia to the Gold King Mine in Colorado is like comparing an apple to a coffee cup. Nobody is proposing tunneling into a mountain or using toxic chemicals. The mining is on an extremely small-scale using mostly hand carried tools. I would be willing to bet those who oppose the act of small-scale mining have little to no knowledge of how it is performed and the benefits to the environment from the activity. We oppose restricting or prohibiting this activity which science proves it is a benefit to the environment. We'd be happy to educate anyone interested in obtaining the truth about small-scale mining.
Placer mining specifically removes toxic metals from our Waters of the state like lead and Mercury. There is no other industry out there that does this without compensation. There is evidence that shows the fish are actually attracted to suction dredges and feed on the tailings and suspended sediments that exist around the discharge. This industry has been impacted by over-regulation and misunderstanding. We must seek to remain independent from the worlds need for precious metals and resources and in the meantime. Thank you.
Small scale mining is a right not a hobby. Its cleans the waterways by removing heavy toxic metals and other trash. It also takes the gravel beds and renews them allowing countless species to spawn and aquatic plants to thrive. Small scale mining uses no chemicals or toxics to mine or process the material. It is entirely 100% done by water. Nothing is added to the water column and only heavy metals and trash are taken out of the water and stream beds. There are no toxic spills, there are no negative impacts to the enviroment. California has tried to ban this process and now is forced to pay private companies millions of dollars a year to go and dredge creeks and rivers using giant excavators and other contruction equipment in krder to make gravel beds for aquatic life. The dirt and mud that is turned up in the water all year is less than that from one storm that happens naturally.
Wow, I’m blown away by the complete ignorance towards small scale mining. There is no comparison to a small scale miner and a commercially operated mine. If your so concerned about the environment where is the outcry for mining of lithium and other rare earth elements used in electric cars? Come on people!! Have common sense and do your own unbiased research on the subject. California banned gold dredging over 10 years ago……mercury levels in riparian insects has actuallY increased since then. The best thing you can do for your waterways is dredge them, looking for gold or not, dredging cleans the stream bead and removes trash debris and lead. Sierra Club fought to ban dredging in California, then they get a grant to operate one of the only dredges in the state on Lake Comby. How does that work? Please people swinging a metal detector or running a sluice box on public land should NOT be illegal.
Small scale mining (dredging, highbanking, sluicing, panning, etc..) cannot even be compared to the effects of large mining operations. They are 2 completely different animals. To group these together is a completely unreasonable accusation.
For example, dredging does not leach harmful chemicals, or ruin waterways. If anything, it actually helps remove heavy metals such as lead and mercury from the areas worked. And in my years of dredging experience, I've seen fish flock to recently dredged areas for feeding and spawning. I've also removed countless lead fishing weights, bullets, miscellaneous metal objects, mercury, etc, all found by dredging.
Most of the residual mercury found in waterways is from old mining operations before there were as many regulations put into place, not from present day small scall mining and hobby prospectors. To try to pinpoint pollution and contaminated water to such activities is a completely invalid argument seeing as how the problem doesn't even correlate to the situation.
May 16, 2022
Virginia Department of Energy
1100 Bank Street, 8th Floor
Richmond, VA 23219
Dear M. Skiffington:
Thank you for accepting public comments to the State Agency Component of Virginia’s Gold Mining Study. I am a Virginia resident in Fauquier County VA. I am concerned about the possibility of gold mining in VA. Since I have a summer home for 30 years in Cooke City/Silver Gate area of Montana, I know first hand the damage and danger to the public of mining gold.
The result of gold mining in the early 1900’s had plagued our area and remained unresolved until President Clinton heard our concerns when the Canadian Gold Mining Company, Noranda, planned to open the old mines and begin mining again. We live within one mile of Yellowstone National Park, and understood the damage already done and the possibility of the environmental danger to our drinking water and public health. But imagine the danger to Yellowstone. Is Virginia any less valuable?
Let me explain: left from old gold mining, also were enormous tailings that became an early Superfund site, but it was not handled correctly. The tailings, located just yards above Cooke City, were spread over an entire valley behind an earthen dam that leaked acid and chemicals down our local stream. No fish could live near that valley. The mines themselves were still leaking chemicals and a different stream was orange with poison. President Clinton and Congress bought out the Noranda Mine for $30 million with the caveat that they must clean up the old mine with the $30 million. Forest Service oversaw the cleanup with a local conservation organization, the Beartooth Alliance, leading the resistance to start with, and then monitoring the mine clean up until finished.
Then later Congress passed the Hard Rock Mining law that financed the EPA cleanup of the tailings in the following years. We now live safely downstream; the fish have returned, and it is now one of the pristine wild refuges for native cutthroat trout. The cost to our government was in the millions upon millions in this two- stage cleanup effort over 20 years. Please do not let this damage start in Virginia. It is not worth it! If this gold mining cannot be stopped, which is the best solution, then strict and thorough regulations to protect communities and the environment along with financial assurances that cover cleanup and full restoration and on-going maintenance are essential.
Yellowstone is worth more than gold! So is Virginia!
Marcia W. Woolman
The State Agency workgroup heard two excellent presentations on May 16. https://covaconf.webex.com/recordingservice/sites/covaconf/recording/9e0033e6b74e103a9fff00505681e464/playback
The National Academy of Science is holding a listening session in Buckingham and virtually https://www.nationalacademies.org/event/05-25-2022/potential-impacts-of-gold-mining-in-virginia-in-person-listening-session
Moving to Arvonia in northern Buckingham with our young family @ 35 years ago, we did not fully appreciate the mineral rights clauses associated with our deed. We certainly DO today, as we fight to protect our water sources and STRONGLY REJECT the plans to conduct gold mining exploration in our County!
Nancy & Mike McCaig
The National Academy of Sciences did an excellent job of interacting with some in the impacted communities. We await the recording of the May 25 event and will share that link here. We hope the VA DMME/ VA Energy will respond appropriately with effective public access to all meetings.
Gold mining in Virgina will set up a disaster waiting to happen. The process for extracting gold will involve harmful chemicals and there will be toxic residue left behind. If stored in a retention pond there will be likely risk of contaminating large areas of land and water when heavy downpours and forceful winds cause overflows that will come with our frequent storms. Thousands of people depend on clean water for drinking. I have three grandchildren who live in VA Beach and their drinking water comes from Lake Gaston.
Gold mining is too risky for Virginia. Our environment and our future generations are too precious. Too many storms and too great a risk of contaminating our waterways.
Highly respected, well-vetted experts in the field of gold mining were not included in the presentations to the NAS. The NAS committee members have suggested that they will be watching the presentations made to the State Agency Gold Study committee found here:
May 16 (PASSWORD: Xk7yfPpq ) Dr. Steven Emerman and Dr. David Pellow at the 30 minute and one hour time stamps.
June 23 9 am-noon will include three more presentations by internationally recognized authorities on gold mining.
March 25 featured Dr. Erica Schoenberger at one hour and 8 minute time stamp (PASSWORD: VAEnergy1 ) not on our original list but who we met when she was invited to present to the NAS.
I strongly oppose gold mining in Virginia. The risks of permanent damage to our environment far outweigh any potential benefits. Gold mining entails harmful chemicals & leaves behind toxic tailings that will be held in retention ponds & will be a long-term hazard to clean water in an area with high rainfall & potential for flooding. The potential long-term harm to drinking water sources is too large to offset the potential profits to industry. People & clean water should take priority in this decision.
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.
This begins with Del. Guzman and continues for 2 hours of excellent comments opposing gold mining in the Commonwealth.
Dept. of Energy Work Group,
As a resident of Scottsville, VA, I am deeply concerned about the impact of industrial gold mining in Buckingham County on the water quality of the James River. The James River, recently designated a "Scenic River" by the Commonwealth of Virginia, is a major economic and natural resource in the region and for the Town of Scottsville. Chemical runoff from gold mining will have a negative impact on the river's water quality, which will have long-term consequences for not only the ecological health of the river but for recreation and tourism as well.
The James River Association has rated the James River a "B-" for water quality in its 2021 State of the James Report. The report recommends careful planning for the long-term viability of the river. The river is already impacted by runoff from both urban and rural land use, and industrial gold mining in the watershed will not positively contribute to its overall health.
Thank you for your consideration.
I want to register my serious concerns related to the impacts of gold mining on nearby residents who rely on private drinking water wells. Gold mining poses the combined risks of dewatering of aquifers supplying drinking water wells as well as contaminating these aquifers such that they would be unsafe as a drinking water supply. The loss of potable water for residential and common agricultural uses in these rural areas would seriously degrade quality of life and the property values in these communities. Noting that many of these communities are low income with significant minority populations adds the concern of disproportionate impact on environmental justice communities.
My grandparents have lived and farmed in Buckingham for over 25 years, using groundwater as their main source of water. Virginians do not want to sacrifice our drinking water and agricultural lands for an unstable and transitory industry with a devastating track record around the globe. The risks to our water, land, and air far outweigh any possible benefit of industrial-scale gold mining. And if they say it's safe? Prove it first!
Gold mining is very harmful to the surroundings--depletion and then poisoning of water supply, not only near the mine, but way downstream as well. Nearby air is polluted as well. The enormous amount of tailings becomes a permanent hazard. Dams may fail. We just noted the anniversary of Hurricane Agnes, which caused heavy flooding all over the state. A tailing dam has to hold forever, which is unlikely, given the way hurricanes pass over Virginia.
It is not right for a company to come in, take its profit, and leave a poisonous mess for the rest of us!
Mercury is toxic. Super fund sites are significantly contaminated.
These two problems should never be disturbed for temporary and limited gain.
Please think of future generations and protect the environment!!
I live in Buckingham County and have been a resident for more than 40 years. I am extremely concerned about the potential impact of industrial gold mining in my county. I sincerely request that the Commonwealth undertake a serious study and all the necessary research to determine the impact of gold mining in our region. There are so many aspects to consider with proposed gold mining projects and particularly environmental and health impacts that I’m deeply concerned about.
I moved to this beautiful area of the country because of the beauty, rural nature, and the health benefits! To have clean air and water in this day and age is not easy to come by! I’ve done my research and listened to experts and looked at the studies on the dangers of gold mining and have concluded they pose a very near and serious threat to our environment and health here. This is the reason I'm posting my comments in the hope to add my voice to my other neighbors who share my concerns. We want to ensure that the research is done that our local and state government can consider and put into place the common sense protections from the enduring toxic trespass I know would come with this industry. Thank you for receiving my comments and helping myself and all the residents of our beautiful and pristine county make our concerns known.
Dr. Prem Anjali
Buckingham, VA 23921
Potential Impacts of Gold Mining in Virginia
Creating strong rights-based law to protect localities and Virginia
from the devastating impacts of gold and metallic mining
The Virginia Department of Energy
Public Comment Forum for Gold Mining Study
July 20, 2022
Heidi Dhivya Berthoud
On behalf of the Virginia Community Rights Network
the Friends of Buckingham
Virginia Community Rights Network (VACRN) has partnered with the Friends of Buckingham (FoB) to promote awareness and take action to stop new industrial gold mining, and all metallic mining from entering Buckingham County at the local level. We ask you to take a closer look at what we are doing. We ask the State Agencies to consider the importance of supporting and strengthening local community measures to protect their health and ecosystems. The local communities are the first gateway to the permitting process. The state can choose to support the localities to protect themselves OR support polluting industry at the expense of localities’ health, safety, and general welfare. And what happens in Buckingham impacts the entire state, especially those downstream and downwind.
We ask you to check out the FoB website to see the extensive information collected there, to help our communities understand the devastating impacts industrial metallic mining is having around the world and would bring to our community. We do not want to repeat these mistakes.
For an in depth, studied report of our grave concerns, please note that VACRN and FoB have signed a letter of support for the reports submitted by the Southern Environmental Law Center and the Chesapeake Bay Foundation, SELC, CBF, and Dr Ann Maest. Also, please see this ‘short list’ of concerns that FoB and VACRN have made available for the public to encourage them to express their concerns to you.
For this record, we include a very ‘short list’ of concerns that we have for metallic mining:
1) Dewatering of mines, impacting the water table for miles around
2) Airborne toxins impacting the local area
3) Leaching of toxins into groundwater
4) Acid Mine Drainage
5) Catastrophic mine waste (tailings) dam failures
6) Virginia has no regulations on the use of cyanide
7) Forever-toxic sites, leaving the forever-burden to the taxpayers
8) Virginia’s rainfall is a huge problem – let alone the climate crisis with increasingly devastating storms
9) Local governments are enticed by tax revenue that will never cover the true costs
10) Negligible number of local jobs – most are specialized, imported from elsewhere
Who we are, our niche in this campaign to stop industrial gold mining
Our mission: Virginia Community Rights Network (VACRN) guides, supports, and encourages local efforts to recognize and legally secure the Rights of Nature and Communities to a healthy environment through self-government at the city, county, and state level. VACRN is dedicated to challenging the injustice of corporate rights that impede local and direct democracy.
This project is the primary focus of VACRN, with the strong support of Friends of Buckingham (FoB).
Our focus is at the local level. The county and municipalities have the power to issue or deny the first (special use) permit in a long list of required permits for any applying metallic mining company. Our job is to help our communities assert our rights:
The right and responsibility to make decisions locally to protect our communities.
The right and responsibility to protect ourselves and our water, air and land from the toxic trespass of industrial metallic mining.
Our national and state constitutions provide the foundation for supporting these rights. We are taking responsibility by asserting those rights.
We have assisted Buckingham residents to write a Community Bill of Rights for the county that would protect us from the toxic trespass we know would come with new metallic mining:
An Ordinance To Protect The Health, Safety, And General Welfare Of The Residents And Natural Environment Of The County Of Buckingham By Exercising The Right Of Local Self-Governance, And By Recognizing The Fundamental Rights Of Residents And Ecosystems Of The County To Be Free From Toxic Trespass, And By Applying A Common-Sense Burden Of Proof Of Safety And Environmental Justice To Corporations Seeking To Engage In Metallic Mining Within The County
This rights-based ordinance would be a strong protective measure to prevent an applying metallic mining company from getting that first essential permit. It is our goal to demonstrate this. We have presented and proposed this bill to the County Administrator and some supervisors. Thus, we are happy that on July 11, 2022, the Buckingham Board of Supervisors voted unanimously to permit the County Administrator and Attorney to begin “developing a gold mining ordinance”. We are dedicated to this success and will work hard to get our proposed bill passed.
This has been a great educational and organizing tool to help us clarify what we want for our community. We talked to people across Buckingham while collecting signatures [over 800 so far] for a petition in support of this local bill. Many people knew nothing about the potential industrial gold mining in Buckingham, and were quite alarmed. Also we found that most were not aware of the 70-some abandoned gold mines in Buckingham from the 1800s that are full of mercury. If we can’t get those cleaned up, why would we invite more industrial pollution?
The proposed ordinance we are bringing to the table was modeled after existing law adopted unanimously by the Town Council of Halifax in 2008 to protect them against possible uranium mining upstream in Pittsylvania County.
We know, and expect the state study will confirm, that the laws we have now do not protect us. We are inspired by this innovative, protective, rights-based approach. There are over 200 communities across America that have adopted a Community Bill of Rights. In addition to Halifax, for example, the Pittsburgh City Council passed one to stop fracked gas wells from drilling in the city. We too can do this here in Buckingham, and across the state.
Essential details of the Ordinance
This rights based bill requires a shift in perspective and priorities.
We understand the state has the authority to regulate industry. What we are concerned with is the state, or local government permitting industries that violate our right not to be poisoned. We want to enshrine a law that steps forward and says: We have rights and they come first - before corporate rights.
Our inalienable right not to be poisoned and our right to life is not something that can be set aside. To not protect the people and their communities from poisoning would be to deny the people a republican form of government. Our elected officials must represent and protect us or risk violating their constitutional duty to do so.
The 14th amendment of the US constitution forbids states from enacting laws that violate rights. So if the state creates laws that violate rights, it would be a civil rights violation. It would be a violation of our 14th amendment rights. We know that would not be in the best interest of the county, the state, or its people and environs.
The following are key points in the proposed bill.
Definition of toxic trespass
Section 7.2. Toxic Trespass. (AKA “Poisoning”) The deposition of toxic substances or potentially toxic substances used in or resulting from metallic mining within the body of any resident of the County of Buckingham or into any ecosystem in the County’s jurisdiction, including but not limited to the James River watershed, is declared a form of trespass, and is hereby prohibited.
Prove it First
The common sense law “Prove it First” - first created in Wisconsin, and in process in Minnesota is included in the local ordinance. We want our county and state to adopt this. This law gets us out ahead of all problems related to metallic mining. Before any permits are granted, the applying mining company would first have to prove that there is at least one other comparable mine project that caused no harm to the community. These ideas are written into the Buckingham ordinance in Section 7.1.1. We have asked you, NAS and State Agencies, to look at this and please recommend this to the General Assembly.
Section 7.1. Required Documentation Prior to Issuance of Permits for Metallic Mining
7.1.1 It shall be unlawful for any corporation to engage in metallic mining activities within the County of Buckingham prior to the submission of all reports from all state and federal environmental and health agencies as well as judicial findings in court cases related to at least one metallic mine that is similar in scope and purpose to what is proposed for Buckingham County, and which had operated in the United States for at least ten years and has subsequently not been operational for at least ten years. Any information contained in these reports indicating that toxic trespass, as defined by this ordinance, has resulted from that mining activity shall disqualify an applicant from receiving a metallic mining permit.
Proactive Environmental Justice requirements
7.1.2 Applications for metallic mining permits shall not be reviewed or acted upon until a full and complete Environmental Justice review (guided by NEPA and Article 12, the Virginia Environmental Justice Act) is submitted to Buckingham County. The results of these assessments shall show definitively that no disadvantaged, poor, minority or marginalized community, municipality or neighborhood in Buckingham County would suffer toxic trespass, as defined by this ordinance. Failure to supply this or any of the required reports shall disqualify an applicant from receiving a permit that would allow metallic mining.
We hope you see the simple brilliance of this rights-based approach. It essentially gives power and assurance to the local government and the state so we all can happily rest, knowing that common sense law is taking care of our health and well being in a very good, reasonable, responsible and just way. Thank you.
Katie Whitehead email@example.com
August 21, 2022
Submitted to https://www.townhall.virginia.gov/L/entercomment.cfm?generalnoticeid=2368 and to firstname.lastname@example.org
Questions and Comments Regarding
“ 2. Summarize the Commonwealth of Virginia’s existing regulatory framework for gold mining and processing sites (for example, bonding, reclamation, closure, and long-term monitoring) and compare to other states with current or recently closed gold mining operations. This summary will include a discussion of relevant air and water quality regulations, as well as Chesapeake Bay watershed protections.” https://www.nationalacademies.org/our-work/potential-impacts-of-gold-mining-in-virginia
(“Before a mine license and permit are issued, applicants must provide suitable operations plans, drainage and sediment control plans, groundwater impact assessments, and reclamation plans for the proposed mine operation.
“Operations plans must describe how the mineral will be mined and processed, and how waste will be disposed of while minimizing the effect on the surrounding environment. Regulations require the operations plan to facilitate integration of reclamation with mining operations according to the special requirements of individual mineral types. Operators are required to conduct mining such that the amount of disturbed acres are minimized, and reclamation is to be conducted simultaneously with mining to the extent feasible. Regulations further require that mining activities must minimize the impact on water quality and quantity.”)
On June 18, the Southern Environmental Law Center (SELC) and the Chesapeake Bay Foundation (CBF) submitted comments to the National Academy of Sciences, Engineering, and Medicine (NASEM) on the potential impacts of industrial gold mining in the Commonwealth and current deficiencies in Virginia’s mineral mining regulations. These comments were informed by a report submitted by Dr. Ann Maest regarding the potential environmental and public health impacts of gold mining.
SELC’s and CBF’s comments submitted to NASEM, Dr. Ann Maest’s report, and a map of drinking water intakes downstream from Virginia’s gold-pyrite belt can be found under “Resources” on this webpage. [https://www.southernenvironment.org/campaign/gold-mining-in-virginia/]
Virginia has no experience with modern, industrial-scale gold mining, and the Commonwealth’s current regulatory regime does not adequately protect communities and the environment from the risks associated with this industry. These regulatory gaps—both substantive and procedural—include:
No comprehensive, state-level environmental review for mineral mining operations;
No regulatory framework to implement environmental justice requirements;
Lack of regulations for exploratory drilling activities;
Deficiencies in water protections, including lack of regulation of cyanide and other chemicals used in gold mining, inadequate standards and practices to protect drinking water, lack of baseline sampling and monitoring requirements, issues with mixing zones, and potential noncompliance with sulfate groundwater criteria;
Failure to account for naturally occurring radioactive materials in gold ore;
Inadequate regulation of mineral mine impoundments;
Sparse closure and reclamation planning requirements;
Insufficient financial assurances;
Failure to account for climate change; and
Failure to consider indirect effects on communities.
In light of this, we urged NASEM to consider whether Virginia is prepared to undertake this new industry given the significant risks associated with gold mining in the Commonwealth.
Again, you can find those materials here. [https://www.southernenvironment.org/campaign/gold-mining-in-virginia/]
I am a Virginia resident who lives in near the James River, just across the Buckingham County line. I use the James River for recreation and fishing. My drinking water comes from a well, and I am deeply concerned about my groundwater being so close to a proposed gold mine. Mining's impacts on water quality are well documented, but both state and federal laws have done a poor job of protecting impacted communities. I am opposed to any project that could have an adverse health impact on Virginia residents, and we should make sure we are carefully analyzing any impacts from gold mining as well as making sure we have the strictest possible regulations on any proposed mining activity before even considering a project like this for permits. Furthermore, Buckingham County has 2 census tracts that are defined as disadvantaged by the Justice40 criteria, so siting this mine there would have serious environmental justice concerns:
I oppose gold mining
It destroys our environment
I am very concerned about the lack of existing regulations and bonding requirements for large-scale metals mining, and in particular, the impact it could have on communities dependent on the James River as a drinking source. Large-scale gold mining is a notoriously toxic process, as are the related waste materials. As the Commonwealth is already blighted with unreclaimed gold mines, attention should be focused on making those sites safe and preventing contamination into Virginia waterways, rather than increasing risk.
Additionally, Virginia’s lack of regulatory oversight makes it especially susceptible to bad actors and polluters. We can see this play out in other extractive industries in the Commonwealth. An industry that could potentially damage the drinking water resources for millions - the James River - is unacceptable. Please conclude that this industry would harm Virginia’s people and places, and do not allow this industry.
It's unlikely that existing regulations are sufficient to keep quality of life across the board stable or even better than what it is now. I'm sure the Canadian company Aston Bay Holdings is working very hard and spending lots of money to make it possible for them to form a commercial mine in VA. They're only coming here to take advantage of the fact that they can get it done cheaper because less laws are in their way. Regulations are paved with blood and shouldn't be taken so lightly . Allowing commercial extraction will harm current and future generations of VA.
(PS hobbyists aren't impacted by this)
I am writing in about my thoughts on the gold mines that are poised to be open soon.
I have seen based on past mining operations in Virginia that these mines can be toxic and are therefor dangerous to the public. When people become ill en masse after a mine, factory, power plant, dumping ground is opened nearby, lawsuits against the state ensue.
At a time when safe drinking water is being contaminated by a similar lack of care in Michigan and Missouri, this is a terrible time to be tampering with the drinking water Virginians rely directly upon.
It simply seems unwise to endanger the James River and its watershed, which provides drinking water for 2.7 million people, brings millions of dollars into Virginia’s economy from commercial fishing, and attracts over 6 million visitors annually.
this could endanger not just the lives of Virginians, but the economy long term.
We all know the environment has not been doing well due to human innovation for a while now. We know it’s coming to a head. When we could so easily maintain the health of our watersheds and rivers and drinking water to millions of people, why not just do so? Why not avoid even more environmental damage that is so much harder to fix once the leaching of chemicals and toxins into the water has already begun?
Sometimes, saving the environment can feel hard, like a big job. This is an opportunity to help save the planet by simply not allowing something to happen: not opening the mine.
Please help to save our beautiful Virginia watersheds and rivers as well as our residents who depend on this water for survival.
Easy, affordable, and direct access to natural, clean drinking water is a human right.
Thank you for your consideration,
Any kind of large scale mining has never been good for a region in the long run - the employees, the neighbors, businesses, anyone. Especially here in our beautiful commonwealth. The variety and beauty of our natural resources prove that they are one of our agates greatest assets. When those are exploited or endangered (as we have all seen happen in the past) we all suffer. And the middle- and lower- classes suffer the most. We should not allow large-scale gold mining in Virginia.
No gold mining in Virginia. There are too many polluting mine sites in the Commonwealth already. The world doesn't need more gold.
STOP this bull. STOP it RIGHT the NOW. This helps NO one and is a disaster WAITING to happen. STOP this foolishness. STOP this madness. It's insane and beyond STUPID. It's NOT needed in Virginia at all. DON'T do it. It's a bad idea that will have IMMENSE consequences for the state and everyone in it. It will destroy the environment and ruin water.
Western states have terrible problems with gold mines that have polluted waterways with arsenic and other chemicals. These costs are almost always paid by the government, meaning my taxes. I do not want more of my taxes to go to helping polluting industries.
In the past, having guidelines, rules, and regulations to control these industries has not worked reliably. I would only agree to gold mining in Virginia if each company involved in extraction put up as much money as the cost of mitigation of the largest gold mining disaster in the US. That money would be given to the state of Virginia to cover the potential cost of cleanup before any mining is done. Of course, no industry would ever agree to this, but this is what should be done. Otherwise, the companies just go bankrupt and taxpayers foot the bill.
Dear Virginia Government:
Please do not permit large-scale gold mining in our Commonwealth. Too much earth must be displace and overturned for what gold is to be gained, creating large scars on the landscape and thedisrupting the soil ecosystem thus killing soil microflora and fauna that supports larger life forms. This kind of resource extraction doesn't benefit the majority of citizens but only enriches the few; allowing large-scale gold mining is not good for the commonweal.
Michael Bentley, EdD
In consideration of the fact that Virginia does not have any experience of industrialized gold mining I am grateful for this much needed study into the impacts it would have on the places we live. In particular I am concerned with the impacts it would have on the quality of our water, air and the numerous ecosystems that we live and interact with. We currently do not have any regulations or protections in place that would protect our health or guarantee that our valuable life giving water and air would be unharmed. Unfortunately I do not see that any amount of regulation would protect us from gold mining.
Industrialized gold mining is widely know as an extremely toxic industry. There are numerous reports of accidents, spills, acid mine drainage impacting waterways, and air borne pollutants. There is without a doubt overwhelming evidence of significant risk to life anywhere a gold mine is located. This committee is charged with looking at impacts and I see this as an extremely critical responsibility. It is my hope that your findings reflect the severity of the impacts which would truly inform any subsequent decision to ensure that life is protected in Virginia. In this day of rapidly dwindling resources, due to our enormous human footprint, we must do all we can do to protect what we still have. When the life giving properties of water and air are polluted it is too late as reclamation is challenging and often impossible. Simply enough, industrial gold mining should not be allowed to locate in the state of Virginia.
Further I see that there would be an environmental justice impact that must be considered. In Buckingham, where I live, there are numerous of gold mining sites and there has already been recent exploratory drilling here. The site that we are aware of is near to two environmental justice communities. Actually a large area of the county would qualify as we fall into a low income classification. ( see EPA, EPA’s Environmental Justice Screening and Mapping Tool https://ejscreen.epa.gov/mapper/ ) There is nothing in place in the current regulations that ensures any meaningful protection of these communities. Environmental justice communities have already seen more than their share of polluting industries located near their homes. But no one should have to bear the impacts of a gold mine. Gold mining does not belong in Virginia. It should not be merely regulated as that does nothing to really protect us. The history of modern gold mining has clearly reflected that there is not a gold mine anywhere that is free from devastating impacts and that any level of exposure would cause irreparable harm to human health, our ecosystems, and in particular our air and the water. It is my great hope that your findings will reflect this.
Thank you for your consideration of my comments.
The marginal benefits to a few people are not worth the enormous costs to many Virginians that a gold mine would impose. There is no way to do this safely on the massive scale proposed.
Please deny a permit.
Bill Lankford, PhD
I see no reason other than the hope of big profits to mine for gold in Virginia. Modern mining techniques cause massive damage to the land and the cyanide used threatens the lives and well-being of the people in in the area surrounding the mine. Others can speak more effectively than I can about the specific environmental health consequences of gold mining, I want to focus on the justification for mining. The people of Buckingham County, many of whom are minorities without the money or access to power to fight against the mine, have only recently had to live through the threats posed by the proposed Atlantic Coast Pipeline. No sooner was that threat removed that the possibility of gold mining came along. From what I've read, no compelling reason for the proposed mining has been offered. In contrast, the promoters of the pipeline at least tried to claim they were serving important national needs. Who needs more gold, and why should mining it override the environmental and social damages it is likely to cause?
Virginia's lack of a comprehensive regulatory framework and insufficient bonding requirements lay a dangerous foundation for an industrial scale extractive industry to put public health and drinking water at risk. The Canadian metal mining prospecting company pulled water in Buckingham from Sycamore Creek, a tributary to the James River, without any county oversight. Industrial metals mining, including gold mining, is notorious for polluting water resources.
You need only watch tonight's NBC news to see the results of large scale surface gold mining in Peru. The world does not need more gold- it needs more protection for our dwindling natural resources and equilibrium.
We need virgin lands-- wilderness-- more than we need a small share of come corporation's profits from mining and selling gold. It's time to save the future for our grand-children.
As a mom and pediatric health researcher, I urge you to oppose large scale gold mining in Virginia.
Should this proposal go ahead, the health of our children and communities will be put in jeopardy. Previous mines have left a legacy of mercury pollution along the Gold-Pyrite belt and the lack of updated regulations would prevent similar and even more harmful exposures with new mines. Further, access to clean water is a primary concern for many and much money, effort, and resources have been spent to clean our rivers from past environmental disasters. The potential health and environmental hazards this proposal would bring cannot justify its approval.
For multiple reasons, gold mining should not be allowed in Virginia. The potential pollution of the James River is a huge factor. Please don't allow our state to be polluted with hazardous wastes from unnecessary mining. Thank you.
We need to clean our water from long term degraders, not add to them.