CEA Foundation, Grass Valley CA – May 16, 2021 

In an effort to gain approval for reopening the Idaho-Maryland Mine in Grass Valley, Rise Gold Corporation and Rise CEO Ben Mossman have followed a pattern of making false, incomplete, or misleading statements to investors and the general public.

On Environmental Impacts

Ben Mossman: “… we’ve designed it to have no impact on the environment.” [1]

Facts: The mine project has major environmental impacts. The list of impacts is long, including habitat destruction, air pollution, traffic, noise, greenhouse gas emissions, wells, aesthetics, and more. One simple example: just to accommodate the 1000 tons of mine waste per day being dumped locally, 75 acres of woodlands and chaparral will be completely removed, including all the surface soil down to rock-solid base, and then built up with mine waste rock and tailings up to 90 feet high using dump trucks, compactors, and graders.

On Water Treatment

Ben Mossman claims that water discharged from the mine would be “drinking water quality standards.” And on the Rise Gold Corp website, their promotional document states: “Treated water to drinking water quality.” [2] [3]

Facts: The water will not be treated to “drinking water quality.” According to the mine application documents on file with Nevada County, mine water discharge would be treated to remove Manganese, Iron, and Arsenic, bringing the quality up to what is referred to as “Secondary Drinking Water Standards.” [4] Treatment to Secondary Standards generally only removes certain water quality contaminants identified on a list of about 15 items. This meets standards for discharging into the creek, but it is not drinking water quality. To bring the water up to “Primary Drinking Water Standards,” bacteria and dozens of additional contaminants need to be removed. [5]

On Wells and Ground Water

 Ben Mossman at a Rise Gold Presentation: “Zero domestic water wells dewatered / drained”

“Assurance throughout mining to prove no impact to wells.” [6]

Facts: The Hydrologic studies show predicted lowering of ground water levels of 1-10 feet on 152 wells. This reduction of ground water levels at private wells is clearly an “impact to wells.” Furthermore, the results of the computer modeling for the study were based on limited data that only account for 1/3 of the planned mining permit duration. And the study depends on the assumption that mine tunneling will not ever encounter fractures, tunnels, or more permeable rock of significant impact. These are major assumptions. Even Rise Gold realizes that the wells along East Bennett Road show significant risk, which is why Rise is already planning to pay for a new water main and provide water hookups for a portion of the well owners within the mineral rights region. The number of wells and scope of mitigations for regional well owners is controversial. [7]

On the Environmental Impact Report (EIR) Timeline

Mr. Mossman has repeatedly made unrealistic statements about how long the environmental report will take.

Aug 14, 2020: “…the County is doing their Environmental Impact Report which is in progress and will be out in the fall [2020], but that will be the final judgement, really, what the actual impacts are.”[8]

Aug 24, 2020: “…the answer to the comments becomes the Final EIR, which should be out by the end of the year.” [9]

Jan 31, 2021: Rise Gold Quarterly Report: “The Company’s estimate of the remaining timeline to approval is approximately May 2021. Ancillary construction and operational permits would follow as needed.”[10]

As of April 23, 2021, Ben Mossman estimates the Draft EIR “will be complete in a month or two.” [2]

Facts: The documents are still being revised. The Use Permit application has not yet even been deemed complete by the Nevada County Planning Department. If the Draft EIR is out by June, allowing for the normal time between the Draft and Final EIRs, comment periods and Planning Commission hearings (6-24 months), the Nevada County Supervisors likely won’t vote on whether to accept the Final EIR until next year, which is a prerequisite for voting on the actual project Use Permit.

On Centennial Cleanup Project

Rise Gold has repeatedly understated or failed to disclose the full scope and nature of the mandatory cleanup project on Centennial Drive and Idaho-Maryland Road.

A recent statement about the Centennial cleanup project is included online in their March investor presentation, which in total says: “Berm and some mineralized material to be cleaned up.” [11]

None of the Rise Gold Quarterly Reports in the last year have mentioned the cleanup. In Rise’s last Annual Report of July 31, 2020, only partial information is provided, mentioning the Preliminary Endangerment Assessment (PEA) that was approved in June 2020, and that a draft Remedial Action Plan (RAP) was prepared and accepted by the “Cal EPA”. Information is provided about a 5.6 acre mine waste consolidation area, which will have deed restrictions. [12]

In the Rise Gold Prospectus Amendment, SEC Form 424 B3, Jan 15, 2021 there is no mention of the cleanup.[13]

Facts: The Centennial site was conditionally deferred from being classified as a Federal EPA Superfund Site in September 2019 on condition that Rise Gold makes satisfactory progress cleaning up legacy toxic tailings on the 56 acre site. [14] Scope of work and cost estimates, though known and included in the Draft and draft Final RAP, have not yet been disclosed.

The Department of Toxic Substances Control (DTSC) is the lead agency for this project and the cleanup needs to be completed, even if the mine project is not approved. However, the 56 acre site is also where Rise Gold plans to dump 1000 tons/day of mine waste rock and tailings during the first 5 years of mining operations.

According to the PEA, contaminated mine waste from the historic operations contains elevated levels of arsenic, mercury, lead, and nickel. [15] These must be safely moved and capped to protect against release into the environment. In addition, approximately 270,000 cubic yards of surface materials covering 44 acres on the site are not structurally adequate for use as a base layer for the mine waste piles and will need to be removed and gradually mixed in with the mine waste as the dumping takes place.

While it is conceivable that this cleanup project could be completed before mining operations begin, the costs of the project will run into millions and it could drag on for many more years.

On Permits

Mr. Mossman has made numerous false claims about how straightforward it will be to get permits. He has mostly made these statements when presenting before investment groups.

Ben Mossman: “The only discretionary permits, or people that can say yes or no – it has nothing to do with the State of California – it’s all Nevada County.” [16]

Ben Mossman: “No permitting through US BLM or US Forest Service” [17]

Rise Gold Annual Report 2019: “The Project area is private land and no permits or consultations with the US Bureau of Land Management (BLM) or the US Forest Service (USFS) are required.” [18]

Facts: There’s a bit of obfuscation here, since the BLM is not involved in this project. If a Use Permit is granted, Rise will still need to obtain numerous State and Federal permits and overcome many hurdles before mining could start. Permits are required for everything from preliminary grading to reclamation plans. These include permits from the U.S. Army Corp of Engineers, Forest Service, Department of Fish and Wildlife, Water Quality Control Board, Air Resources Board, State Mining Board, and Nevada County Planning. Obtaining these permits would take from one to many years if the project is granted a Use Permit by Nevada County.

Ben Mossman again: “We’ve done water sampling. The water’s quite clean. And we know exactly how we would treat it. We know exactly where the water would go, into Wolf Creek. Already the permit’s done for that creek.” [19]

Facts: As of May 2021, no permits are “done” for any creek. There are a number of permits needed in order to discharge water into the creek. If the Use Permit is granted by Nevada County, then the applications for de-watering can be submitted to the Water Quality Control Board, U.S. Army Corp of Engineers, Fish and Wildlife, etc. Also, to be accurate, the plans on file with the County show de-watering discharge would go into South Fork Wolf Creek, not Wolf Creek.

Regarding “the water’s quite clean,” iron concentrations in the mine water range from 1600 μg/L to 4,800 μg/L, well over 5 times the “Maximum Contaminant Level” (MCL) of 300 μg/L. Manganese concentrations range from 200 to 310 μg/L, over 4 times the MCL of 50 μg/L.  Arsenic concentrations range from 37 to 59 μg/L, over 3 times the MCL of 10. [20]

In Summary

Due to the potential for serious impacts on the environment and on the health of our community, CEA Foundation feels it is critical that we have accurate information. Our hope is that the community, the various agencies, and the Board of Supervisors will be able to make accurate and well informed decisions regarding what is best for all of us.