2016-03-15_PERMIT FILE - M1980244

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lift mineshaft hoisting equipment. As such, Mollie Kathleen's tour operation offers a rare glimpse into Colorado mining history, and, as a deep shaft tour operation is both rare, and, particularly vulnerable to ventilation and other issues. Our tour level is an underground museum of Colorado mining history, mechanics and tools. The Mollie Kathleen Mine discovered in 1891, is an original discovery mine of Poverty Gulch, the birth site of the Cripple Creek Gold Camp, a commonly defined region referred to by history as "The Cradle of The Cripple Creek District", the same location being defined in the Newmont Mining Company application to expand its Cresson Mine Project activities into Poverty Gulch, and, abutting the Mollie Kathleen properties. As to the issue of Newmont operations advancing physically close to the Mollie Kathleen operations, both Newmont and Dewey-Dwight should conclude that both operations will fall quickly within the view of the public and media radar. During several, recent, past years, Mollie Kathleen mining tour operations have been subjected to a series of mine safety threats affecting its employee and the public touring the Mollie Kathleen subsurface mine workings. These safety infractions occurred during the operations of a prior owner (then) lessee on adjacent and interconnected properties. That prior lessee was ultimately ejected by Anglo American, and Anglo regained possession of the properties. We will refer to the prior operator as "Providence".We in no way attribute these violations to Newmont. Newmont now has title to the adjacent properties. However, the concerns created by that prior operator are emblematic of the unique vulnerability of underground tour operations, and, members of the public who are our guests. At times, we have several tour groups underground on the 1000 foot level ("10 level"). As the Division is aware, the Cripple Creek district is notoriously vulnerable to ventilation issues related to carbon dioxide at times of weather related pressure changes. That vulnerability also exists with regard to underground gases emanating from the use of explosives in interconnected workings, or on nearby grounds. As the Division may or may not know, it was once possible for knowledgeable miners to traverse the entire district from Cripple Creek to the Victor area by traversing multiple underground workings and interconnections. Although it is unknown whether this is still physically possible, the underground connections of District operations are still multiple, and, many. We cite the prior complications as an example of the risks that our guests and employees potentially face. These included, in the recent past, forced emergency evacuations and closure of mining tour operation. The prior operator, without warning, would detonate explosives, then invert underground airflow by use of mechanical force spewing explosive and underground equipment exhaust directly into Mollie Kathleen and Queen Bess touring levels. Countless Dewey-Dwight complaints fell on deaf ears, creating conditions that Dewey-Dwight will never allow to be repeated. Evacuating tour groups of inexperienced civilians from deep levels of our tour operation is part of all of our contingency plans; however,such experiences are risky, and not to be favored, for many reasons. As but one example of the risks of airflow inversion, during the mine touring off-season of 2011, a Providence intentional act to invert natural underground airflow, reversed airflow of the Mollie Kathleen shaft from natural updraft to forced downdraft conditions icing the upper 200 feet of the Mollie Kathleen shaft causing non reparable timber damage to the