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Other Voices: City should analyze economics of Ceramext process

Half of all the waste rock and tailings from the Idaho-Maryland mine is planned to become feedstock for a large on-site ceramics plant, using Golden Bear Ceramics’ new Ceramext manufacturing process. The draft environmental impact review for the project only considers one scenario of ceramics plant production and sales levels.

The Ceramext process has never been used on a commercial scale anywhere, even now, two years after Golden Bear’s statement of intent to do so elsewhere first, and a year and a half after Emgold’s restructuring to decouple Golden Bear from the mine project in order to attract more investors. As a result, there is a strong likelihood that the one scenario of ceramics production and sales levels analyzed in the draft EIR will not happen.

What happens with the extra tailings and rock (and the city’s income, and the jobs) if the ceramics plant is not operating and selling as planned? A revised project description must be provided by the applicant, detailing the possible scenarios of local ceramics plant production, and a new draft EIR must be written and recirculated.

If the plan is to go with the one scenario already put forward, then the following key mitigation measure, along with others already on file, must be enforced to provide some assurance that the environmental impacts will not deviate from those analyzed in the draft EIR:

“Golden Bear Ceramics must have a plant operating elsewhere, using 200 tons per day of feedstock geologically similar to what would be extracted from the ground in this project, using the Ceramext process, and operating at a profit for at least six months (two quarters), before any construction is allowed to begin locally.”

We’ve established that the ceramics plant success or failure affects the environmental review of the entire project. The mine corporation has already acknowledged that if the local ceramics production does not ramp up as scheduled, then the local gold processing will not be allowed to ramp up either.

Analyzing the project economics in the draft EIR Appendix H, Tables 12 and A6, for the unwritten scenario of no local ceramics production, there is a distinct possibility that Grass Valley could never make one dime over the entire life of this project.

As a result, the entire scope of this project could be limited to nothing more than removing ore from the ground and shipping it out of the area ” likely employing far fewer than the 200 total workers anticipated.

Many residents feel that the benefit of new jobs from this project is the highest possible priority. Understandable, given that not everyone has the time to read the 640-page report. It turns out that they are being taken for a ride, for all of the reasons just mentioned, and by the incessant and unfounded repetition of the number “400.”

The city and the applicant must enforce the requirement for an off-site ceramics plant before the start of local operations, both in the scope of the report, and provide some form of assurance to those seeking jobs and income that their hopes are not unfounded.

It is especially ironic that the 600-plus pages of environmental review, consuming years of effort and expense on all sides, can ultimately be thrown out by the lead agency with a simple “Statement of Overriding Considerations.” But it is DEIR Appendix H, a small economic analysis document, slipped under the radar and technically not part of the required review process, that is really running the whole show.

And while the developers would like this application process to go much more quickly, as we all would, it’s ironic that the city could have advised the applicant years ago to wait until Ceramext had been proven elsewhere before beginning the review process.

This would have saved the mine corporation huge amounts of money and time, and would have allowed them to present a more legitimate business plan from the beginning.

Even venture capitalism has some chance of success. This project, as written, may well turn out to be an almost-sure economic loser. The city owes it to everyone involved to perform a rigorous economic analysis using scenarios that are actually possible and probable.

Tom Grundy lives in Nevada City.