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CITY OF <br /> �& <br /> Err:nA!_=® <br /> UTILITIES DEPARTMENT DEC <br /> FACSIMILE: 720-898-7603 ♦ TDD: 720-898-7869 <br /> PHONE: 720-898-7760 DIVISION OF RECIAMATION <br /> MININ - ` <br /> December 5, 2017 <br /> Mr. Michael A. Cunningham <br /> Environmental Protection Specialist <br /> Division of Reclamation, Mining and Safety <br /> Colorado Department of Natural Resources <br /> 1313 Sherman Street, Room 215 <br /> Denver, CO 80203 <br /> RE: Succession of Operators— Schwartzwalder Mine (M-1977-300), Jefferson County, <br /> CO <br /> Dear Mr. Cunningham: <br /> The City of Arvada has recently become aware of an application by the Cotter Corporations to <br /> transfer and succession Permit M-1977-300 (Schwartzwalder Mine) to Colorado Legacy Land, <br /> LLC. We understand that Denver Water has provided a detailed letter reiterating the status of <br /> uranium contamination in water sources and storage facilities that serve Denver Water <br /> customers, the source of which is a facility owned and operated by Cotter. The City of Arvada <br /> re-affirms Arvada remains concerned about the proposed application submitted by Cotter to <br /> transfer the Permit to Colorado Legacy Land, LLC for the purpose of managing the long-term <br /> operations of the Schwartzwalder Mine. <br /> The City supplies water for its 116,000 residents from Ralston Reservoir and Arvada Reservoir, <br /> which are on Ralston Creek and approximately 3 miles downstream from the Schwartzwalder <br /> Mine. Actual uranium mining at the Schwartzwalder Mine ended over a decade ago and the site <br /> has been in a reclamation status since that time. The location of the mine adjacent to Ralston <br /> Creek results in a continuous flow of ground water through and out of the mine system into <br /> Ralston Creek. This outflow water does not meet stream standards and active treatment systems <br /> are necessary to prevent pollution of Ralston Creek. The indications are that active treatment <br /> systems will be needed indefinitely. <br /> The record is bereft of evidence that the requested transfer will further the requirements of <br /> Permit No. M-1977-300. To the contrary, Colorado Legacy Land LLC is a recently formed <br /> Delaware corporation with no record of performance, or demonstration of financial or technical <br /> ability to comply with the requirements of the Permit. Arvada submits that no public purpose is <br /> served by the transfer, and no public benefit has been demonstrated by Cotter that would justify <br /> the transfer at this time. Arvada submits the transfer merely serves to cloud the chain of <br /> responsibility and can only be construed as serving to narrow the financial and legal interests of <br /> Cotter in fulfilling its obligations under the Permit. <br /> Arvada concurs with the conclusions made by Denver Water and fully endorses their <br /> recommendation. Specifically, Arvada submits that consideration of the transfer request be <br /> 8101 RALSTON ROAD A ARVADA, COLORADO A 80002 <br />