What’s Going On With the Well-Monitoring Program? (8/21/14)
As many of you know, water quality monitoring under the Baseline Groundwater Monitoring Program was halted by the San Juan Mining Corporation (SJMC), as per their instructions to Cranmer Engineering in late March. Over 100 community wells are enrolled in the program, which was designed to establish baseline conditions for the Environmental Impact Report (EIR) for the proposed re-opening of the San Juan Ridge Mine. However, suspension of water quality tests does not mean the mining corporation has given up its efforts to reopen the mine. The application is still very much in play and Cranmer continues to collect well water level data, as recently as July 2014.
San Juan Mining Corporation’s Letter to the County
In a letter dated June 25, 2014, SJMC’s CEO communicated to the county his concerns regarding the well monitoring requirements laid out by the county. He questions the validity, usefulness and cost of requiring 12 consecutive months of water quality tests. He states “SJMC believes that all sampling necessary to establish baseline groundwater quality for EIR purposes has been completed,” and that his understanding is that data collected would be included in an appendix to the EIR (rather than forming the basis for analysis in the EIR.)
SJRTA’s Attorney’s Letter to the County
After several weeks of no response from the county, SJRTA had our attorney write a letter dated August 4, stating that it was our understanding that all of the data being collected as part of the Baseline Groundwater Monitoring Program was going to be used to determine pre-project baseline conditions. We encouraged well owners to sign up for the program based on our understanding that the data would be used in the EIR. We also reiterated our stance that we feel that two years of data collection is the minimum amount of time necessary in order to make this determination.
County response to San Juan Mining Corporation
The county responded to the mine operator in a letter dated August 5. It states, in part, “For the preparation of the EIR, the County had requested one full year of baseline water quality and groundwater level data, to encompass potential natural changes experienced during all four seasons…Our goal is to have empirical data for each month rather than relying upon statistical assumptions; this would strengthen the analysis in the EIR,” and “this program establishes the baseline environmental conditions for use in the CEQA process.”
SJRTA Letter to County
In a letter dated August 19 SJRTA seeks clarification from the County as to whether they will require a minimum of 12 consecutive months of pre-EIR water quality monitoring of the mine operator, as the County’s letter to SJMC states the county “had requested.”
Our position
SJRTA believes the county letter is consistent with our understanding of the Baseline Groundwater Monitoring Program and how the program was to be implemented. We believe the mining corporation needs to fulfill its requirement to sample water quality on a monthly basis during all four seasons.
As monthly water quality testing has now been interrupted for several months, we believe the county should require that this process start over again in order to collect one year of continuous water quality and quantity monitoring data.
What next?
The county now awaits a meeting with the mine operator to determine how to move forward with the EIR. To our knowledge this meeting has not yet taken place. There are no guarantees that the county will insist on the above requirements but SJRTA will continue to push for uninterrupted data that can be used to determine baseline conditions of the environment surrounding the San Juan Ridge Mine, as required by the California Environmental Quality Act (CEQA.)