2019-06-28_PERMIT FILE - M2019031 (2)

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Colorado Division of Reclamation, Mining and Safety JUN 2 0 evto ATTN: Lucas West, Environmental Protection Specialist ONISION OF REC 1313 Sherman Street, Room 215 MININGMD TM� Denver, CO 80203 RE: Von Doose(Atlas) Mine Application M-2019-031 I, Dhana Broser, owner of the Nella M Lode claim located directly adjacent to the proposed Von Doose mine(M-2019-031), having reviewed the construction and reclamation plans included in the application, am writing this letter to the Department of Reclamation, Mining& Safety(hereafter referred to as "DRMS"),to express objection to Permit Application M-2019-031,the Von Doose Mile Hard Rock Reclamation Permit Application (hereafter referred to as "the application"): 1) I object to the application on the basis that there is no environmental protection plan included therein, as is specified by subsection 6.4.21 of the DRMS's Hard Rock and Designated Mining Operation rules, and required by rule 7.1.3 and 7.1.4 of the same. This is especially concerning to me as the main drainage from the mountain flows directly across the southwest aspect of my property, and periods of precipitation often cause run off to breach its regular flow-routes and move unpredictably across the road.Therefore I have serious concerns about contaminated runoff affecting my property. 2) I object to the application on the basis that in addition to lacking an environmental protection plan, there is no environmental impact study in the application. Red Mountain has an extensive history of mining operations, from which the local ecosystem is slowly recovering. Numerous species of wildlife including mule deer(Odocoileus hemionus), black bear(Ursus americanus), mountain lion (Puma concolor), wild turkey(Meleagris gallopavo), wild honey bees(Apis mellifera), marmot(Marmota monax)and big horn sheep(Ovis canadensis), have slowly made their way back to the mountain, and would likely be displaced again by the presence of such a significant mining complex. Furthermore, the additional factor of climate change makes the eventual return of these species after mining operations cease in 2040, less certain than it has historically been, posing a significant and potentially insurmountable challenge to any meaningful reclamation plans. 3) 1 object to the application on the basis that there is no fire protection plan in therein. This is especially concerning as the machinery roster on page 45 of the application states that the applicant intends to store 1,500 gallons of diesel fuel on site, which is alarming as this region has been under drought conditions for several years; conditions severe enough to warrant stage Il fire restriction, and conditions only recently lifted on account of a single season's heavy snow pack, a factor which is not at all certain to persist in coming years. Furthermore, increase in tree death from the emerald ash borer (Agrilus planipennis)or"bark beetle" infestation over the last several years has left much of the San Juan mountain range more susceptible to wild fire. 4) I object to the application on the basis that the applicant does not demonstrate, pursuant to Subsection 6.5(4) under the Geotechnical Stability Exhibit,that off site areas such as my adjacent property, will not be adversely affected by blasting during mining or reclamation operations. 5) I object to the application on the basis that the application does not outline and label the adit that exists from previous mining activity on my adjacent property,which could be re-disturbed by the mining and blasting proposed under this application and thus is required by rule 6.3.5(f)of the