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Hernandez. We will try to be as cooperative as possible with you; we hope that can be a <br />two way street. <br />We have already stated our views about TR -25 in our letter of November 16, 2015, a <br />copy of which is attached. <br />The most important issue in our opinion is that a series of related Technical Revisions <br />are being used to advance a variety of changes in the permit which really should go <br />forward as a Permit Revision. We also add: <br />1. There is still no local land use permit. <br />Apparently, the company has been in the local land use permitting process since at least <br />August 5, 2010, without ever getting a local permit. <br />2. There has been no further federal review. <br />The 2001 Environmental Assessment is a sketchy basis for approval of a project this size <br />with this scale of impacts. It was, frankly, a very weak effort. <br />But the deficiencies of this analysis are magnified by the fact that there has been no <br />subsequent federal permitting or analysis in the last fourteen years, while the mine <br />production level has increased over 400%.1 <br />The Division Has Been Headed Down the Wrong Path <br />DRMS should not consider TR -25 separately, but together with the other pending TRS, <br />and should process all of this together as a Permit Revision. <br />• The changes in the permit have been divided up piecemeal and considered <br />separately; and <br />• They have been improperly treated as Technical Revisions rather than Permit <br />Amendments, thus allowing them to proceed without the public being aware, <br />and without adequate public participation. <br />TR 23, TR 24, TR 25 and TR 26 are all part of the same process of expansion; there is no <br />justification for treating them separately. <br />There is also no justification for treating these matters as Technical Revisions, whether <br />considered separately or together. The only reason for doing that is to truncate and <br />avoid public awareness and public participation; the company knows the depth of public <br />1 There is another EA in the works, but no date or deadline for that process. <br />2 <br />