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I IIIIIIICUla MlY aUJal.UllL LU IL. Z-F:,PIIyl UlalliiJ IIU y1UUIIU vvaLcl WILIIIII I.I IIIIIl7J UI LIIl7 IIIIIIl7 Will LM allt IUMU kVIapU <br /> Creek is 1.3 miles), but also states"As indicated above,Grape Creek will be identified as a point of depletion <br /> for augmentation purposes, but actual impacts are unlikely due the fractured rock geology at the site.The mine <br /> operator will implement the augmentation plan, including the acquisition and dedication of any necessary water <br /> rights to operate the plan.The augmentation plan will protect senior water rights from injury resulting from <br /> depletions to the surface water system."What is the actual augmentation plan?How will Grape Creek be <br /> monitored for depletion and by whom?What water sources will be acquired to augment?Are there senior water <br /> rights that can protect the stream?Has Zephyr been in contact with the DeWeese-Dye ditch company to <br /> discuss this issue prior to application? <br /> Although Windy and Dawson Gulches do not directly enter Grape Creek,they terminate in sedimentary rock <br /> and the identified Dakota Formation aquifer and connect to the drainage to Grape Creek.An above ground <br /> disposal of mine/mill tailings(FTSF)has been proposed with channels to divert ground water during <br /> precipitation events and buttresses to prevent tailings from moving down-slope at the beginning of the disposal <br /> process.Any breach of the FTSF would result in movement of tailings toward Grape Creek and possible <br /> contamination of the aquifer.Are these channels designed for a 100-yr event,a 500-yr event?A 1000-yr event? <br /> Zephyr states they anticipate a 50%infiltration rate—this appears unlikely given the Precambrian geology and <br /> steep topography of the mine site.Will these channels be maintained or improved after mining is completed? <br /> What is the consequence of the"dry"tailings becoming saturated? <br /> The entire proposed budget for reclamation is$261,813.This seems unrealistically low and doesn't appear to <br /> factor in inflation and continual monitoring of ground and surface water,or condition of the FTSF after mining is <br /> completed.The Pueblo TU Chapter is addressing several spots of erosion on the tailwater below Pueblo Dam <br /> and the projected cost may be greater than Zephyr's total proposed reclamation budget for an underground <br /> mine with above ground mill operations and tailings,affecting 80+acres. <br /> With a projected LOM of only five-years,we are also concerned that Zephyr could abandon the project mid- <br /> stream if the multiple factors needed to make these"potential reserves"viable failed to materialize.The whole <br /> project appears speculative in nature,with unproven reserves as stated in their Gold in Colorado presentation <br /> dated August 17,2021 -"It should be noted that the Dawson Property PEA is preliminary in nature and includes <br /> inferred mineral resources that are considered too speculative geologically to have the economic considerations <br /> applied to them that would enable them to be categorized as mineral reserves.There is no certainty that the <br /> PEA forecast will be realized or that any of the resources will ever be upgraded to reserves. Mineral Resources <br /> that are not Mineral Reserves do not have demonstrated economic viability." <br /> This last statement seems to contradict the standard reason for applying for a mining permit.Combining all <br /> these factors,we are strongly opposed to the mining permit as submitted by Zephyr Minerals. <br /> Respectfully, <br /> David Nickum, Executive Director <br /> Colorado Trout Unlimited <br /> Steve Wolfe, President <br /> Southern Colorado Greenback Chapter of Trout Unlimited (Pueblo) <br /> Allyn Kratz, President <br /> Pikes Peak Chapter of Trout Unlimited(Colorado Springs) <br /> Rick Helmick,Vice-President <br /> Collegiate Peaks Chapter of Trout Unlimited(Salida) <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 />