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amount. Finally,there is no provision for environmental remediation escrow funds to deal with abrupt acid runoff <br /> such as that which occurred from the Gold King mine on the Las Animas, 92 years after mine closure.The <br /> permit should be denied for inadequate remediation funding. <br /> Lack of adequate flood protection for tailings pile(to include impermeable membrane).The riparian <br /> environment surrounding the site is fragile.The Front Range in this area, because of orographic effects and <br /> prevailing upper air conditions, has experienced frequent devastating floods from near stationary thunderstorms <br /> that cause massive rainfall over relatively small areas.The Great Pueblo Flood of 1921 is a perfect example, <br /> when more than 6 inches of rain fell in the area.Zephyr proposes a minimal channel around the tailings pile to <br /> divert small amounts of surface water, but does not consider such massive events.The current plan for tailings <br /> pile protection(including a lack of permeable membrane)is unsatisfactory,and given the potential impact on <br /> the water supplies of hundreds of thousands,the permit should be disapproved until a design is provided that <br /> meets at least the impact of a 500 year rainfall event. <br /> Agricultural irrigation and municipal water supply and water rights impacts.Continuing severe drought, likely <br /> caused by climate change impacts, is reducing mountain snow and rain. Irrigation water sources are already <br /> stressed,and agricultural impacts are significant.Any additional demand,whether from reduction of ground <br /> water flows through the riparian system or limitations of surface/river water usages caused by contamination or <br /> routine mine use will be significant. No provision in the permit process addresses this,especially for the <br /> immediate area downstream where Canon City municipal and several irrigation ditches collect water.The <br /> permit should be disapproved until the impact of water usage by the mine is quantified,and water rights issues <br /> resolved with ditch corporations. <br /> Risk of wildfire. Potassium amyl xanthate poses several significant fire-related risks. It is capable of <br /> spontaneous ignition and explosion,and when it decomposes, produces carbon disulphide,a highly flammable <br /> gas. Numerous industrial incidents of explosion and fire have been reported globally where these chemicals are <br /> used.The flora and terrain surrounding the proposed site are extremely susceptible to wildfire,and the Dawson <br /> Ranch development is downwind of the prevailing westerly winds in the area. No provision is made in the <br /> Zephyr application to deal with fire protection beyond the worker protections required by OSHA.The permit <br /> should be denied until a comprehensive plan for a mining operation in a wildfire-prone area is provided. <br /> Permit Number* <br /> Enter valid letter and then numbers,for example M122112211 or C123456789. <br /> M2021046 <br /> Permitting Action Type <br /> Select revision type or leave blank if comment pertains to a new permit application or NOI <br /> Permit Type <br /> Reclamation Permit <br /> County* <br /> Fremont <br /> Enter one county only <br /> Site Name <br /> Dawson Gold Mine <br /> Perm ittee/Operator Name <br /> Zephyr Gold USA Limited <br /> ADDITIONAL INFORMATION <br /> Are there supporting photos, maps, or documents you wish to upload? <br /> Yes No <br /> By submitting this form electronically you agree to receive any/all follow up correspondence from the Division of <br /> Reclamation, Mining,and Safety at the email address you have provided. <br />