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I IQI III UI UaI l layc LU WII UI I IC JFJM M. al lU I IaUa LLI II 1000 II Iy UUL I IUL IIIIIILC C C U LU IIIU I UCI,C R a I , l lu Uly-1 lul I I AI ICCF/ <br /> and their migration corridors and production areas. <br /> 7.Section 2.8 Exhibit H:Wildlife Information:This Section states that the historic mine openings in the vicinity of <br /> the Dawson site were surveyed for Townsend big-eared bats,but neglects to report whether other bat species <br /> are using the openings. If so,those openings should be gated to protect the bat roosting sites. <br /> Historic and Archaeologic Resources <br /> 8.Section 3 subheading 6.4.21(3)should include a State Preservation Office clearance and a baseline survey <br /> of cultural, historic, palaeontologic and archaeological resources. <br /> Conclusions <br /> In regard to comment 1.,please be reminded that Colorado has been significantly damaged by acidic and toxic <br /> mine effluents from both historic and modern, regulated mines such as the Summitville mine on Wightman Fork <br /> of the Alamosa River and the Sunnyside mine in the upper Animas River watershed. Because Zephyr Gold's <br /> sampling and characterization of the risk of acidic and toxic effluents was so poorly done and as provided in 2 <br /> CCR 407-1 Section 1.4.3(2), DRMS should retain and Zephyr Gold should pay the costs of an independent <br /> third-party expert to oversee a professional description of the ore body, location and selection of representative <br /> geochemical samples,sample composites if deemed appropriate,geochemical testing and analysis of the <br /> samples,and careful assessment of the acidic and toxic mine drainage risks.Acidic and toxic mine effluents <br /> probably are the greatest environmental damage of mining in Colorado. Exceptional care must be taken in <br /> assessing the risk of this hazard to the State's natural resources <br /> There are two deficiencies in the reclamation plan,see comments 2.and 3. First, recall that every metal mining <br /> district in the State has failed mine tailings landfills that have left behind denuded surfaces,streams choked with <br /> fine tailings that inhibit macro-invertebrate life and fish habitat,and many of those landfills also seep acidic and <br /> toxic effluents.These forever structures must be designed with more than just the minimum safety factors. <br /> Please insist on a landfill design that will be durable for hundreds of years.Second,all roads on the site should <br /> be reclaimed.These roads can become pathways for significant water erosion,and a red-flag for further <br /> damage by 4-wheelers. <br /> A field survey of site vegetation(comments 4.and 5.)was not performed as required by the regulations. CNHP <br /> reported that rare and imperiled plants and wildlife and plant communities exist in the area,and so there is the <br /> possibility of their existence on the Dawson site.There is no excuse for not performing a field survey and <br /> preparing a map of the site vegetation. It is required for mining permit applications.Similarly,CNHP also <br /> reported the possible existence in the area of Botta's pocket gopher.This gopher and other small mammals <br /> must be inventoried on the Dawson site and appropriate actions planned before approving a mining permit. <br /> The Dawson permit does not address how wildlife and rare plants/communities will be protected from the <br /> mining operations and surface disturbances,comments 6.And 7.These natural resources can be protected as <br /> applicable by fencing,exclusion areas,and so on.The permit should be denied. <br /> A clearance for the existence of various cultural resources also is missing from the Dawson mine permit,see <br /> comment 8,and again the permit should be denied. <br /> The preceding comments provide ample justification for rejecting the Dawson mine permit application.Only a <br /> first-rate permit application will give a measure of confidence in the mine operators and their commitment to <br /> protect the local Colorado natural resources. <br /> Robert H. Robinson, P.E. <br /> 4 Hillside Drive <br /> Wheat Ridge, CO 80215 <br /> 303-907-0487 <br /> gymnerdl@mac.com <br /> Relevant Experience, Robert H. Robinson, P.E.: <br /> My first degrees were bachelors and master's degrees in mining engineering. First half of career, I worked in <br /> mine production and engineering for several mining companies and mine engineering consulting companies. <br /> Mid-career I made a change with a second master's degree in environmental policy and management.This <br /> chanqe led to a job with the Bureau of Land Manaqement coordinatinq the cleanup of abandoned mines on <br />