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4\I <br /> r, RE6avve; <br /> ® TC03 <br /> .— M-1977-307 <br /> Ca►rite,r ✓ Complied! AUG 0 2 Z017 <br /> DMC DMSION OF REC <br /> July 31, 2017 GRM MINING AND S <br /> LA�T1ON <br /> AFETY <br /> Mr. G. Russell Means <br /> Senior Environmental Protection Specialist <br /> Colorado Division of Reclamation, Mining and Safety <br /> 1313 Sherman Street, Room 215 <br /> Denver, CO 80203 <br /> Re: CM-25 Mine, Permit No. M-1977-307,Notice of Temporary Cessation <br /> Dear Mr. Means: <br /> Thank you for your letter dated June 29, 2017, addressing the status of the C-LP-21, CM-25, <br /> and SR-13A Mines. Cotter Corporation (N.S.L.) ("Cotter") here responds to your letter <br /> insofar as it covers the CM-25 Mine. Further, consistent with your letters to Cotter dated <br /> June 29, 2017, regarding the SM-18 and Mineral Joe Mines, Cotter requests a change in <br /> permit status of the CM-25 Mine from intermittent activity to temporary cessation effective <br /> December 15, 2012. <br /> Your letter addressing the CM-25 Mine reports initially that, on May 7, 2013,the Mined <br /> Land Reclamation Board ("Board") signed an order approving Cotter's request to put the <br /> permit for the CM-25 Mine into temporary cessation, effective December 15, 2012, with the <br /> temporary cessation period ending on December 15, 2017. Cotter respectfully submits that it <br /> did not make such request, as none was required under the letter dated November 9, 2012, <br /> from the Division of Reclamation, Mining and Safety ("Division")to Cotter, and that the <br /> Board's May 7, 2013 order therefore did not cover the CM-25 Mine. Accordingly, the CM- <br /> 25 Mine has not been in temporary cessation since December 15, 2012 but, instead, has been <br /> in intermittent status. <br /> Cotter also respectfully disagrees that the CM-25 Mine has reached its permit conclusion and <br /> that Cotter must therefore request a release of its permit and associated financial warranties. <br /> Substantial economic reserves continue to exist in the CM-25 Mine, and these reserves can <br /> be mined in the future. This fact was acknowledged in the Division's inspection report for <br /> the CM-25 Mine, signed July 30, 2010: "The mine was reclaimed due to economic reasons <br /> and not ore reserve depletion. Should favorable economic conditions evolve Cotter could <br /> reactivate the mine once an approved Environmental Protection Plan Amendment is <br /> approved." Cotter intends to mine the CM-25 Mine's reserves when market conditions <br /> recover, and has submitted a plan to the Division for doing so. See Cotter's 110d Application <br /> Amendment("Application Amendment") for the CM-25 Mine, Exh. C. The Division has <br /> also approved Cotter's Environmental Protection Plan ("EPP") Amendment for the CM-25 <br /> Mine, as explained in the Division's letter to Cotter dated May 7, 2013. The life of the CM- <br /> 25 Mine is projected to be between 15 and 20 years. Application Amendment, Exh. C. For <br /> these reasons, Cotter's reclamation permit should not be terminated, and the CM-25 site <br /> should not be inspected for final release. <br /> 1 <br />