DRMS Comment Objection Intake 8/19/2021 8:42:44 AM

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depending on the evaluation method.Additional test work will be needed to characterize the geochemistry of the tailings." (After many reassurances from Zephyr that the tailings produced from the proposed mine will not produce acid mine waste,the applicant hires a consulting firm which states that the tailings have uncertain potential for acid generation.) 2.13 Exhibit M:Other Application Submissions "Zephyr USA will be submitting and application for a CUP for mining from Fremont County Department of Planning and Zoning(FCPZ).This application will provide information pertaining to compatibility with area land use,traffic analysis,driveway access permit, lighting plan and fire prevention plan. Colorado Department of Public Health and Environment(CDPHE)will receive two applications: (1)An Air Pollution Emissions Notice(APEN)will be submitted to the Air Pollution Control Division(APCD)for construction and operation of the mine and (2)A mine discharge application will be submitted to the Water Quality Control Division(WQCD). The Colorado Department of Natural Resources, State Engineers Office(SEO)will also receive applications as follows: (1)Additional monitoring well permit applications will be submitted for construction of the proposed monitoring wells. (2)Mine dewatering will be necessary;thus, an application will be submitted for anticipated dewatering as well as addressing mill needs.This application will likely be amended as the mine develops. Zephyr respects Colorado's effort to be protective and fair regarding water consumption and will maintain an open dialogue with SEO throughout LOM." (It is good that"Zephyr respects Colorado's effort to be protective and fair regarding water consumption...," especially when the western states,due to Climate Change,are now experiencing the worst droughts in history. This is no time for the state and county to be considering authorizing a mine whose annual water consumption is estimated to be approximately 65 million gallons) (As stated previously,zephyr will be required to apply with the BLM for an easement modification if they plan to reroute any portion of Temple Canyon Road on BLM lands. In addition,a R/W application will be required for any proposed power line, use of existing trail on BLM and for any phone line construction where it crosses BLM land.) Climate Information Missing DRMS regulations relative to applications for a Mine Plan state that the applicant will,"Provide the following information regarding climatic factors,above six thousand five hundred(6500)feet of elevation, (with the approval of the Office,data may be provided from existing stations within the vicinity of the Permit area)": (ii)the average direction and velocity of the prevailing winds" In Appendix i,Zephyr states that"wind experienced at any given location is highly dependent on local topography and other factors, and instantaneous wind speed and direction vary more widely than hourly averages.The average hourly wind speed in Carson City experiences significant seasonal variation over the course of the year.The windier part of the year lasts for 7.5 months,from October 27 to June 11,with average wind speeds of more than 8.0 miles per hour.The windiest day of the year is April 4,with an average hourly wind speed of 9.8 miles per hour.The calmer time of year lasts for 4.5 months,from June 11 to October 27.The calmest day of the year is August 12,with an average hourly wind speed of 6.2 miles per hour." While this is great information relative to Canon City, it has no bearing on conditions at the mine site and how it might affect areas off site. Zephyr's wind commentary comes from the perspective of a Chamber of Commerce ad.Wind velocities at the mine site and at Dawson Ranch have reportedly reached velocities of forty to sixty knots and inevitably blow in a west to easterly direction,directly through their CUP area,across their planned tailings site and into Canon City through the Dawson Ranch and Wolf Park communities.