Comstock Mining Inc

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Statements contained in this blog, which are not historical facts, including statements about plans, goals and expectations regarding businesses and opportunities, new or existing business strategies, capital resources and future financial results are "forward looking" as contemplated by the Private Securities Litigation Reform Act of 1995. Such forward-looking statements are subject to risks and uncertainties, including, but not limited to, changes in government regulation, generally accepted accounting principles, taxation, competition, general economic conditions and geopolitical conditions. Accordingly, actual results may differ materially from those projected or implied in the forward-looking statements.

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CEO Blog - September 28, 2012
Friday, September 28 2012 15:41
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We are very pleased to report that we have loaded our first two full batches of precipitate material into the retort furnace, commencing the final processes for pouring gold and silver!  The first pour is imminent and will commence today and will likely continue through the weekend.

We also have two heap pads currently under leach and that new process has continued quite smoothly, with the leaching cycle proceeding slightly faster than expected.

These pictures were taken Thursday evening showing us loading the precipitate tray and Cliff Nelson and team loading the retort furnace.

Loading precipitate in tray


Loading the retort furnace

We couldn’t be prouder that we are mining, hauling, crushing, leaching, processing and almost ready to start pouring silver and gold on The Comstock again!!  We expect to pour today and most all of this weekend.  

It’s a truly historic achievement and we are all honored to be part of the return of real, responsible mining to The Comstock.  

We look forward to celebrating the first pour right here on the Comstock with all of our stakeholders and the Community at large, later next month. Invitations to follow!!

Best Regards from The Comstock,

Corrado De Gasperis

President & CEO

CEO Blog - September 13, 2012
Thursday, September 13 2012 03:00
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We are very pleased to report that we have begun the leaching process for gold and silver recovery. We have two cells currently under the drip lines and the new process has commenced quite smoothly. The crusher is also fully operational and we have crushed, agglomerated and stacked in excess of 70,000 tons of mineralized material on the heap pad.   

The leaching process adds cyanide solution to the heap through a network of drip lines. This solution runs continuously, leaching gold and silver from the material stacked on the heap pads, soon to be recovered through the Company's processing facilities!

We have already amassed over 1,750 ounces of recoverable gold and over 15,000 ounces of recoverable silver on the leach pads and we very much look forward to announcing our first pour and revenue in the coming weeks.

The following video captures the current process from delivery at the crusher to irrigation on the heap pad:


Leaching Begins - Sept 12, 2012 - MP4 version for download or iPhone / iPad viewing


These two pictures were taken yesterday and show the irrigation pattern on the heap and the drip system operating:

Drip lines over heap pad


Close-up showing drip line operation

We couldn’t be prouder that we are mining, hauling, crushing and leaching on The Comstock. It’s a truly historic opportunity and we are all honored to be part of the return of real, responsible mining to The Comstock.

We look forward to celebrating the first pour in the upcoming weeks!


Kindest regards,

Corrado De Gasperis

President & CEO

CEO Blog - August 13, 2012
Monday, August 13 2012 22:43
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Q: What is happening with the start-up of operation?  How is it going?

A: In a word, excellent.

As we announced last week, we have commenced mining and we have been hauling ore from the Lucerne mine to the process area in American Flat since last Tuesday afternoon.  We also commenced crushing last Friday and we have stacked the first agglomerated ore onto the heap pad.  We will continue to stack for about two more weeks before adding solution and beginning the recovery of ore through the Merrill Crowe process. As soon as a sufficient quantity of extracted material has built up, we will proceed with our first pour, expected sometime in September. We are truly proud to be Nevada’s Newest Gold and Silver Miner!!!

Ore Stacking
Stacking Ore Commences - Aug 10, 2012

I hope you enjoy the following video and photographs that will demonstrate in pictures the recent progress we have made in our March to Production.

Click link:






As you can see, the hauling of ore is currently utilizing street-legal trucks. We have already scheduled the process to optimize the cycling of vehicles to ensure safe and efficient haulage. A portion of the route will travel over approximately one mile of State Route 342. Local Storey County officials again acknowledged that the Company is fully authorized to use the road under normal Nevada Department of Transportation regulations. This type of hauling will continue until the Bureau of Land Management (BLM) issues a new Right of Way that allows access back to our original haul road.  We are working diligently with the BLM toward a permanent solution that will further optimize the mining operation.


On Friday, August 10th, the first ore was placed on the heap. The following photograph documents the very first bit of agglomerated ore coming off the Super Stacker. Before we know it, this small pile will grow to a heap stacked to the height of 105 feet.


Photo by Derek Norred of Comstock Mining


Lastly, we enjoy spectacular skies in Nevada.  Look at this double rainbow over our facility on the Comstock.


Photo by Thomas Chandler of Comstock Mining


Kindest regards,

Corrado De Gasperis

President & CEO

CEO Blog - August 6, 2012
Monday, August 06 2012 16:26
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Oxford University Students on the Comstock

Interview by Julie Draksler

What does Oxford University have in common with the Comstock?  Other than the Comstock’s own Mark Twain receiving an honorary doctorate from Oxford in 1907. The Comstock recently became the destination for three of Oxford’s bright and motivated 3rd year geology students.  Benjamin Conibear (Ben), James Samuel Hirst (Sam) and Charles Miller (Charlie) were tasked with completing a mapping project as part of their geology curriculum as required for graduation.  They could have opted to accept the same European areas that students before them typically go, even though their predecessors have mapped those areas repeatedly.  Instead, they made their way to Nevada’s robust Comstock Lode.

Well, here is the connection – Ben Conibear’s father, Andy Conibear, lives and works near the Comstock, in Carson City, Nevada.  He conversed with his friend, Geologist and Professional Engineer, Dennis Anderson, a consultant at Comstock Mining Inc. (the Company) about the possibility of a geologic study project in the historic Comstock Mining District that would meet Oxford's required geologic mapping unit for graduation.   Mr. Anderson reached out to Larry Martin, Comstock’s V.P. of Exploration and Mine Development and discussed the basic concepts of the graduation requirement and if the Company would be interested in the program.   Mr. Martin thought it would be an excellent opportunity for the Company and to utilize the Oxford's students to map specific portions of the Company’s over 6,000 acres of land.   A mapping proposal was presented via Ben Conibear to geology professors that are committee members over graduation requirements for Oxford University.   The Company welcomed the finalized Oxford requirements for the geologic mapping campaign and the mine agreed to reimburse expenses, provided the students mapped specific regions selected within Comstock's land holdings including but not limited to the historic Occidental, Dayton and Oest Mine locations.

Conibear, Hirst and Miller had expressed their excitement to Mr. Martin during the final planning of the mapping project.   Prior to traveling to the Comstock and further detailed discussions with Mr. Martin, the students realized that this was a rare opportunity to map and participate in the evaluation of exploration targets in an area hosting geologically complex ore deposit targets within a historically world renowned precious metal mining district. Once the students had the approval and confirmation from their Oxford professors for their project and mapping task, they began to review their collegiate knowledge of igneous and metamorphic rocks.  This included reading geologic publications focused upon volcanic systems located in the western United States to give them a cursory baseline for their project. After the paperwork, logistics completed and visa in hand, the students arrived on the Comstock in mid-June.


Oxford University geology students (Photo by Bill Mitchell, July 2012)
Sam Hirst, Ben Conibear, and Charlie Miller above the Comstock's Gold Canyon.


One of the Company's geologists, Ken Coleman, was the team’s Field Coordinator and is a seasoned geologic field mapper, currently completing his degree in geology at the University of Nevada, Reno. The Oxford mapping team and Ken Coleman were under the direction of Larry Martin, a 35-year mining industry veteran, Certified Professional Geologist and a graduate of Colorado School of Mines.  Jason Merchent, UNR graduate, is the Company's GIS specialist and provided base map support.

Field Coordinator Coleman explained the mapping process begins by determining the mapping goal and land area target. Mapping can be for general geology or more detailed to determine alteration and mineralization patterns. Once the goal is set, a series of traverses are done across the project area. Rock types, structure or fracture patterns, alteration and mineralization are determined at each location along the traverse. Observations are then plotted on the field map, and large-scale geological relationships become more apparent. Where warranted, rock chip samples are taken of mineralized outcrops to determine gold and silver content.

Conibear had visited the area prior to the mapping proposal with his father, however Hirst and Miller knew only of the basin and range tectonics of Nevada and they learned of the enormous historic wealth that makes the Comstock so unique.  Hirst remarked on the Occidental area of the Comstock, “It is quite complex.  We mapped it with a higher scale than generally is required by Oxford and it was a good project.”

What makes mapping here so complex? Hirst claims, “Many students do their projects in Europe which may be faster and easier because the (geologic) variations are more gradual. Variations on the Comstock are more subtle.”  This requires more study and high level of detail on the map.

Miller added that European geology contains mostly metamorphic and intrusive rocks as opposed to the Comstock’s combination of volcanic flows and domal features, intrusive igneous rocks and metamorphic rocks. They all agreed that the Comstock holds a very unique geologic environment for them and is unequaled in northern Europe.

It was a fascinating project or the students and they were very appreciative for the opportunity.  Larry Martin stated, "The Company was extremely satisfied with the students’ geologic mapping as it matched very well with the Company's prior mapping that was conducted over the past few years by Comstock Mining staff geologists.  The Oxford team did identify several structures (faults) that will be further studied. The students were initially shown some of the previous geologic maps to illustrate the detail and quality that the Company expected from the students.  The Oxford team was not privy to the Company's prior geologic information for the areas mapped."  Mr. Martin added, "This was a means for the Company to evaluate the students’ observations. The quality of mapping and professionalism of the Oxford team was exemplary."


Oxford students discussing their mapping project on the Comstock

Did anything surprise them about the Comstock?  Conibear remarked on the mountainous terrain and the elevation here.  Miller was surprised at how easy it was to feel at home, with the mine geology team’s support and the welcome atmosphere of the Company’s entire team.  They all agreed it was a fantastic project and believe their professor will be pleased with novelty of mapping a portion of such profound geology, in a completely different area of the world.

Although the project kept them very busy, the students were able to take short trips, enjoying Virginia City and Lake Tahoe and observing Slide Mountain.  They were also able to witness Comstock Mining’s first material fragmentation and start of actual mine production.

Hirst and Miller come from the London area and Conibear comes from an area in the Southern U.K. known for ancient tin mining. While mining is still a great career industry in the U.K, professionals travel out of the U.K. more often, to gain practical experience in mining projects around the world.

Corrado De Gasperis, President and CEO of Comstock Mining, was very pleased with the Oxford team’s work. “Our geology team reported these gentlemen did a fine job on their mapping task and showed us some interesting features in the Occidental area.  We hope Ben, Sam, and Charlie come back to the Comstock when gold and silver production is fully operational.”

Kind regards,

Corrado De Gasperis

President and CEO

CEO Blog - July 30, 2012
Monday, July 30 2012 17:41
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Comstock Establishes Strategic, Industry Leading Alliances

Today we announced two positive financing transactions totaling $10 million.  Our business plan has always contemplated some form of equipment financing and/or working capital facility and, although the market has been and remains very difficult for accessing this type of capital, we are thrilled to have consummated attractive equipment financing with Caterpillar Financial Services Corporation. Caterpillar is the world’s leading manufacturer of construction, mining and other industrial equipment and is also a leading services provider through Caterpillar Financial Services.

We are also proud to have established a $5 million revolving credit facility through Auramet Trading LLC, and funding working capital needs.  Both of these companies represent, outstanding, reputable, industry-leading, sustaining production partners who are enabling and supporting our growth and the development of the Comstock. Considering the difficulty our industry sector has had accessing the capital markets efficiently, we couldn’t be more pleased with the timing of this funding and the strength of our balance sheet as we commence production.







We have already begun mining operations in the mine and we have commissioned our new Crushing facility.  We will commence commissioning the Merrill-Crowe facility this week and plan on hauling ore on or before the first full week of August.  After crushing and stacking this ore to sufficient quantity, we will then commence leaching and recovering the contained precious metals through the Merrill-Crowe zinc precipitation process.


Kindest regards,

Corrado De Gasperis

President and CEO


CEO Blog - July 23, 2012
Monday, July 23 2012 22:14
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Question: Do you have an update on production - are we stacking ore yet?

Answer: Thank you for your question.  We are making straight and steady progress on our March to Production.  July has been an incredibly active month. Early in the month, we announced that we completed the expansion of our Heap Leach from three cells to five, published a video on the expanded Merrill Crowe processing facility, initiated the commissioning of the new Crusher and posted a $4.67 million surety bond.  We have also hired most of the staff required for processing, leaving just 8 remaining positions that we are actively filling.  We will begin commissioning the Merrill Crowe facility shortly.  The commissioning will finish the first week of August and we will commence hauling the ore. Once the ore is at American Flat we will begin crushing and stacking the ore for processing.

We also recently conducted our first Lucerne Mine production shot, one of the tasks scheduled on our March to Production project plan.  We have partnered with Cal-Nevada Precision Blasting, Carson City Nevada, and worked in tandem with Storey County and our own Safety, Security, and Operational teams to ensure a well-executed and targeted fragmentation of material in the Lucerne Mine. With all teams synchronized, 57 charges were spaced inside the target zone and were detonated at 11:00am.  

On July 18, 2012, the State Route (SR-342) was temporarily closed for about 10 minutes, until cleared by our experts at Cal-Nevada. The operation was executed as planned, safely and professionally.   We have included some photos of the event; see below.


Square area with berm around it is the target zone


Fragmentation and loosening of material and lateral out flow


Close up of target area cleared for re-entry by Cal-Nevada, confirming all 57 holes detonated


Seismograph testing any movement

As a side note, we experienced some rain Sunday night on the Comstock.  I was still at the office when I saw this double rainbow. All in all, it’s pretty amazing on the Comstock.


Photo taken from American Flat, by me with an iPhone, Sunday, July 22, 2012.

Kindest regards,

Corrado De Gasperis

President and CEO

CEO Blog - June 14, 2012
Thursday, June 14 2012 16:18
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Question: Does Comstock Mining also need to have Standard Operating Procedures (SOPs) and other controls in place to manage processing?  NOTE: This inquiry came with the following background question through our contact page: “When we (in the pharmaceutical industry) run processes we need to have stringent guidelines, safety measures, and documentation to prove the safety and efficacy of our drugs. We must show the FDA that we have the proper quality controls in place to catch a problem which in turn helps put the public into a more comfortable state knowing everything is in place.” The question continued by emphasizing the value of using company metrics (e.g. accident-free work hours) to motivate the workforce to keep “precision in the forefront of their mind.”

Answer:  Our answer is an emphatic YES! Since early 2010, our transformational efforts have moved us toward a systemic organizational design built for reliability (and hence predictability), stability and speed.  This is how we define Quality and it is a relentless effort of continuous improvement.

Although not regulated by the FDA, mining may be one of the most regulated operations on this planet, answering to County, State, and Federal regulators.  Frankly, we have not only designed a system to handle these complexities but something capable of much, much more than that.  We consider compliance with minimum standards as “necessary but not sufficient” for our organizational objectives and the goals we have established.  Instead, we expect to perform at levels well in excess of legal requirements. Philosophically, we aspire to achieve sustainable wealth by maximizing speed and reliability in the most ethical and socially responsible manner.  We endeavor to generate this wealth through a self-sustaining network of geological, historical, environmental and, of course always, economic activities.

We operate as a sustainable system


Everything we do at Comstock Mining is informed and inspired by a sustainable and systemic approach to managing. Our operating methodology, The DecalogueTM, leads us to see ourselves as part of a system (or network) of interdependent people and processes. This system includes not only our suppliers and customers, but also our community and our environment.  Therefore, whatever we do must benefit not only the company shareholders, but also all of our stakeholders, including our covenant with the territory. Our goal is not just to be safe, but also to be an active contributor to the wealth and wellbeing of the entire Comstock community. In order to do this, we must understand the interdependencies in our system and the impact of our daily actions.

Our Quality system

How do we practically do that? It starts with our ‘Playbook.’ The Playbook is a ‘map’ (think flowcharts) that describes our processes, how they are linked, who does what when, and the expected measureable outcomes of all these activities. The Playbook allows us to permeate the organization with Quality so that we can operate reliably, predictably and responsibly. It is the foundational document for the daily decisions and actions that occur in our system. In addition to this ‘map,’ we also need a mechanism to measure whether our decisions and actions are reliably taking us towards the company goal. We do this by understanding, with statistical tools, the variation that affects our processes. Managing Quality at Comstock Mining means using Statistical Process Control, as defined by W. Edwards Deming, to measure, monitor and improve the processes we have mapped. Our Quality system, based on the DecalogueTM, provides us the ongoing mechanism to design, validate and test all of our improvement activities.

Results of our Quality system

We expect our Quality system to generate an ethical, transparent, environmentally enhancing, safe and sustainable chain of efforts.  We believe that the only meaningful way for any organization to prosper is to become an active channel for the development and distribution of products and services that help people to live better. This is the only truly sustainable role for any organization in today’s interconnected world. As we transition, as stated in the question, “from explorer, to engineer to producer” we expect responsible mining to be a powerful economic engine for improving the quality of life in the historic Comstock district.

We are simultaneously achieving a self-sustaining, predictable, quality system capable of delivering geological, historical and environmental achievements while positioning our Company for maximum sustainable wealth from the richness of our Comstock properties.  This isn’t our fathers’ mining venture.  We’re modern, we’re Nevadan and we’re proud of it.

 Kindest regards,

 Corrado De Gasperis

President and CEO





CEO Blog - June 7, 2012
Thursday, June 07 2012 20:45
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Questions: Are there any new developments regarding the BLM Notice that you can share with us?

Answer: Yes, thank you for your question.  There are a number of items to report regarding the BLM Notice. On Monday, May 21st, we received a Notice from the local Field Office of the Bureau of Land Management (BLM) requiring us to cease using certain land. The Notice did not include any specific allegations regarding our conduct, and we strongly affirmed that the “generic” allegations in the Notice are not supported by the facts. We quickly responded with a letter outlining our position accompanied by over one hundred pages of evidence supporting those positions.

Subsequently, Cindi Byrns and I met with Leon Thomas, Field Manager of the local BLM Office and we affirmed our mutual understanding that these actions would not stop mining operations.  He restated his position from the Notice and indicated that a specific list of alleged infractions would be forthcoming, including exactly how we could immediately cure those allegations.  We received that letter today, and have already taken all necessary actions to cure the allegations by:

1)  Removing certain signage and obstructions from LOT 51 (despite still contending it is our own private land)

2)  Removing certain signage and obstructions from other designated public lands (despite still contending the validity of the existing right-of-way);

3)  Posting a reclamation bond for $35,868, while awaiting final resolutions; and

4)  Initiating a field work authorization for a cultural review.

We understand from the BLM that these actions cure the Notice.

We also confirmed, with Storey County, the validity and availability of alternative routes affirming that our mining activity WILL NOT be interrupted during the period of time required to develop a more reasonable solution.

The Company will also file a new, exclusive use Right of Way (ROW) application for the haul road portion of the ROW. In addition to cooperating with the BLM Local Field Office and submitting the requested paperwork, we are proceeding with a number of additional actions supported by the preponderance of evidence proving our position, including the immediate filing of a Class 1 Color of Title application for Lot 51 and filing an assignment application for the existing Haul Road ROW.

During these parallel actions, we remain compliant with all BLM regulations and we continue to mine using a combination of our own 50-ton haul trucks and 18-wheel, 20-ton semi-trucks.

We are also working expeditiously and cooperatively with the BLM for an enhanced, long-term solution that resolves disputed land-ownership claims and right of way issues in a manner that optimizes our logistics and mining operations and minimizes costs and disruptions.

Overall, we are pleased with the direct collaboration and recent responsiveness of the BLM and to have cured the Notice so quickly. While we are disappointed at some of their inflexibility in light of the facts, we are also encouraged by the ability to continue all our mining activity, and look forward to reaching a more optimal solution in the near future. Until a final resolution is implemented, this will remain one of our team’s highest priorities, second only to pouring gold and silver later this year. In that regard, our construction activities and production plans remain on schedule.

Kindest Regards,

Corrado De Gasperis
President and CEO

CEO Blog - June 6, 2012
Wednesday, June 06 2012 03:00
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Storey County recently hosted a ribbon cutting ceremony for its new Visitors Welcome Center ornamented with historical artifacts from the town’s rich mining legacy.  The most prominent feature greeting visitors is the towering Historic Keystone Head Frame.  Comstock Mining coordinated its donation last fall and a team of Storey County, State of Nevada and local contractors collaborated to reinforce the century-old frame and relocate it from the southern end of the Lode to the northern end of Virginia City.


Comstock Mining’s Scott Jolcover in the center holding the ribbon for cutting.

Our team is pleased to contribute this historic relic for the interested public, including researching relevant information (with the great help of John Bennetts of Silver City, whose father Harry Bennetts worked in the Keystone Mine with E.A. (Bob) Montogomery).  We believe this mine produced the last great bonanza of its day, before it was shut down in the mid 1940’s.


1930’s Montgomery Shaft located at the Keystone Mine.

Photo courtesy of UNR Special Collections

The Comstock Keystone Mine shafts located in Gold Hill, on the Silver City branch of the Comstock Lode, used two shafts on either side of SR-342, then SR-341.  It was common to recycle head frames from one shaft to another and we believe the head frame, stamped 1929, was used in operations prior to its location on the Comstock Keystone Mine, which halted operations around 1943.  The ore from the Keystone Mine was milled at the Dayton Consolidated Mining Company just south and west of Silver City on SR-341 and sent to the Carson City Mint.


Keystone Mine head frame on Route 341 in Gold Hill, NV, to be donated by Comstock Mining Inc.

The donated Keystone head frame is a wooden, tandem sheave head frame for a two-compartment shaft. Sheaves are the grooved, cast iron spoke wheels at the top of the head frame that carry the rope, and the sheaves are in tandem because one is right behind the other.

Comstock Keystone Mine had a recorded (State) production of 15,074 tons yielding $146,414 between 1933 and 1939. In modern pricing*, this equates to about $67,978,500 in Gold and $7,343,375 in Silver.  Dayton Consolidated Mining Company took control of the property around 1936, reopened the Keystone Shaft, and resumed production.

The shaft was used by Dayton Consolidated in conjunction with the New York Shaft, which they acquired in 1939, to produce $1,616,000 from 164,735 tons of ore from the Keystone Mine and $555,799 from 60,567 tons of ore in the Justice: this production spanned the years 1936 to 1942.

For further research, the Dayton Consolidated Mining Company records appear in Couch and Carpenter’s “Nevada’s Metal and Mineral Production (1943).”

See below for some photos of the delicate move of the head frame by the professional team put together by Storey County.

We very much appreciate participating in plans that visibly protects, preserves, restores, enhances and celebrates the value of the historical Comstock landscape.  We hope that this highly visible project will be celebrated for a long, long time.

Kindest Regards,

Corrado De Gasperis
President and CEO

*2012 pricing $1500/troy oz gold and $25/troy oz silver, with doré mix of 10% gold and 90% silver


CEO Blog - June 5, 2012
Wednesday, June 06 2012 01:10
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Question: I noticed a new approval from NDEP on the results from the Lucerne Mine. What does this mean?

Answer: Thank you for the question.  We did get good news on Friday, June 1st, when Comstock Mining received written confirmation that the Nevada Division of Environmental Protection, Bureau of Corrective Actions (NDEP-BCA) had approved the Environmental Findings Report for the Lucerne Mine Area. With the approval of this report, all currently planned mining activities can proceed without the need to mitigate for any contaminants.

The report presents and summarizes the data from 246 soil samples taken in the Lucerne Area. Since January 2012, McGinley & Associates, Inc., a Nevada based Environmental Sciences firm, and a Certified Environmental Manager approved by the State of Nevada, has been completing the required fieldwork using the protocols of the Sampling and Analysis Plan (SAP). The SAP is used to identify and quantify concentrations of mercury, lead and arsenic in areas that could potentially reside in NDEP-BCA designated risk areas of the Carson River Mercury Superfund (CRMS). The SAP was approved and is overseen by the NDEP-BCA. NDEP-BCA was granted oversight of the superfund by the U.S. Environmental Protection Agency (EPA).

The very good news is that no actionable levels of mercury or lead were identified in the Lucerne Mine Area. Arsenic was identified above threshold concentrations in one location, but it is located at depth under a haul road that will not be mined, so no mitigation is required at this time.

This is the first report to be approved by NDEP-BCA. Not only does the result provide a positive outcome for Comstock Mining, it highlights the excellent working relationship we have with NDEP-BCA and the EPA. Recent newspaper articles have erroneously stated otherwise, and I hope this approval demonstrates the real nature of our relationship with both agencies: cooperative, collaboratively working together for public safety and health, and focused on providing fact-based information to the public.

The news articles I am referring to reported that the EPA was “taking legal action” against Comstock Mining. The EPA HAS NOT taken any legal action against Comstock Mining. Rather, some time ago, the EPA sent Comstock an information request letter under procedures established by a provision in the law referred to as 104(e).  The 104(e) letter was a standard request for information regarding ownership status, current and predecessor operations, etc., within a superfund area. Comstock had voluntarily provided much of the requested information to EPA prior to our receipt of the 104(e) letter.  We provided the remainder of the requested information in February of this year, though we are required to update the EPA with any pertinent new information on an on-going basis.

More importantly, we have been one of the most substantive proponents of the Comstock territory and environment.  We have invested unprecedented time and money, restoring historic mills, stabilizing and expanding the Gold Hill Hotel operations and, most profoundly, sampling the soils and ensuring clean, safe operations.  For over a year now we have been working closely with the NDEP-BCA and the EPA regarding those aspects of our operations near historic mills or tailings areas in the CRMS. This collaborative effort has resulted in one of the most comprehensive and robust SAPs ever developed for the CRMS site – and this approval of the Environmental Findings Report for the Lucerne Pit Area is a major validation of this effort.

Under the SAP, both EPA and NDEP-BCA receive advance notice of our sampling so that they can observe or take their own samples.  Comstock has taken nearly 2,000 samples.  Neither agency has participated by taking additional sampling with Comstock to-date. To-date we have spent over $1,250,000, sampling areas on our property. We are testing to the highest environmental standards with the goal of not just operating safely but ultimately, to remove the superfund designation from our community.

Through Comstock’s sampling effort under the SAP, we have documented that our processing area does not contain elevated mercury levels.  Our sampling program included sampling outside of areas believed by NDEP-BCA to present potential mercury exposure risks.  Those sampling data also show that land outside of the NDEP-BCA designated risk areas is generally unaffected by historic mill operations or tailings and has very low levels of mercury.

Documentation relating to our environmental permits, including the letter approving the Environmental Findings Report for Lucerne Pit Area and the report itself, may be accessed by interested parties via the NDEP website:

We have a plan that visibly protects, preserves, restores, enhances and celebrates the value of the historical Comstock landscape and this is a critical step forward in implementing that plan.

Kindest Regards,

Corrado De Gasperis
President and CEO

CEO Blog - May 23, 2012
Wednesday, May 23 2012 18:05
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Question: What can you tell me about the recent BLM Notice and how Comstock Mining is responding?

Answer: Thank you for your question.  I understand your concern and I am happy to address.

Notice was received from the local Field Office of the Bureau of Land Management (BLM) requiring the Company to cease using certain land. The Notice does not include any specific allegations regarding our conduct, and we strongly affirm that the “generic” allegations in the Notice are not supported by the facts. In addition, we do not know of any specific circumstances that would warrant a Notice. We have recently delivered our written response to the Notice to Leon Thomas, Field Manager of the local BLM Office.

Our complete response letter can be found here: CMI Response to BLM Notice 2012.05.23 (PDF - 807 KB)

Included with the submission is all the supporting material that provides clear evidence of our rights to use all the land questioned for mining activity including hauling of ore from the mine to the process area. The supporting material represents over a hundred pages of documentation.

In summary, we are enabling responsible mining of historic significance to our State. We have already set new, higher standards of environmental responsibility in the State and on the Comstock.  We have already partnered with the local, state and federal agencies in unprecedented ways, including Storey County, NDEP, the BLM and the EPA.  I believe we represent the most socially responsible partner the territory has seen and we couldn’t be more proud of our team and how they conduct themselves.

Kindest Regards,

Corrado De Gasperis
President and CEO

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