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DRMS Comment Objection Intake 9/1/2021 6:57:46 PM
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Comment Objection 46142 9/1/2021 (2)
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DRMS Comment Objection Intake 9/1/2021 6:57:46 PM
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12/28/2024 1:59:54 PM
Creation date
9/1/2021 7:00:31 PM
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DRMS Permit Index
Permit No
M2021046
IBM Index Class Name
Application Correspondence
Doc Date
9/1/2021
Doc Name
Comment/Objection
From
Jamison Valdez
To
DRMS
Email Name
TC1
TC1
Media Type
D
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Rep. Diana DeGette's Colorado Wilderness Act legislation.Although 1 these areas are <br /> excluded from Zephyr's permit application,the company continues to actively promote <br /> their future development to investors and has specific exploration plans for these public <br /> lands,as reported in corporate securities filings,with additional exploration plans and <br /> identified drill targets in the areas known as Windy Gulch,Windy Point,Sentinel and the <br /> El Plomo section.2 The development of a metal mine on these public lands would <br /> irreparably degrade their quality and render any wilderness designation impossible,to <br /> the great detriment of Coloradans in particular and all Americans in general.A great <br /> opportunity for future conservation is put at risk from the Dawson Gold Mine,despite <br /> decades of planning and cooperation among regional and national stakeholders working <br /> to preserve the entire neighborhood of public lands for future generations. <br /> The BLM Grape Creek Area of Critical Environmental Concern provides high <br /> quality pinon-juniper habitat overall,as well as especially valuable occurrences of mixed <br /> narrowleaf cottonwood and Douglas fir woodlands.The Bureau of Land Management <br /> has identified this area as worthy of protection for its unique high desert riparian <br /> resources,scenic and visual qualities, riparian species,and the habitat it provides for <br /> Arkansas Canyon stickleaf,golden columbine and gold blazingstar.The ACEC and <br /> surrounding lands provide critical habitat for bighorn,mule deer,pronghorn,elk, lion, <br /> black bear,ringtail, bobcat,coyote, Merriam's turkey, Brazilian free-tailed bat, <br /> Townsend's big-eared bat,Alberts squirrel, Mexican spotted owl,scaled quail,great blue <br /> heron,golden eagle and waterfowl,and is a documented nesting area for peregrine <br /> falcon. Mining activities on these lands will impact the habitat connectivity and migration <br /> corridors these species rely on and threaten the overall value of these prized public <br /> lands.The operator must be held to the strict standard of minimizing all harm to wildlife <br /> during and after mining operations.3 <br /> 3 Mineral Rules and Regulations for Hard Rock, Metal,and Designated Mining Operations: Rule 6.4.21(18) <br /> 2 See disclosures and discussion,pp 3-4, in Zephyr Minerals, Management's Discussion&Analysis For the <br /> Period Ended June 30,2021.(enclosed) <br /> 1 Colorado Wilderness Act of 2020: https://www.congress.gov/bill/l16th-congress/house-bill/2546 <br /> Temple Canyon Park is a conservation park providing primitive recreation <br /> opportunities that is owned by the City of Canon City and is adjacent to the state <br /> stewardship trust parcel. Haul traffic from the mine will create conflicts with users of <br /> Temple Canyon Park(as well as the South Canyon Trails),in addition to degrading the <br /> scenic quality and soundscape.Temple Canyon Park is so named because of the <br /> presence of a unique natural ampitheater that is a significant historic site for Ute Tribes <br /> and Indigenous Peoples and was likely used for traditional ceremonies,despite its lack <br /> of formal protections or recognition of its cultural importance.The Grape Creek canyon <br /> provides rich archeological resources that should be preserved and 4 are put at risk by <br /> any mining in the area.These potential impacts should be carefully documented and <br /> considered so that degradation of these cultural and historic values does not occur and <br /> traditional uses are protected. <br /> The Dawson Gold Mine requires an approved BLM Plan of Operations,despite <br /> the fact that the Bureau of Land Management has thus far failed to require one.The <br /> application currently before the Division does not address the need for permitted areas <br /> to accommodate future powerline development and access road easements,which will <br /> require rights-of-way over public lands.The necessity of improving existing roadways <br /> and constructing new roads to allow for ore trucks and other mine-related transit requires <br /> cooperation and consultation with BLM and initiates the need for a formal plan of <br /> operations for the mine.5 Previously, BLM's Canon City authorized exploratory drilling by <br /> Zephyr inside the Lower Grape Creek Wilderness Study Area and unlawfully decided not <br /> to require a plan of operations. However,the future expansion plans of Zephyr as <br /> continuously and repeatedly publicly stated to investors will clearly cause significant and <br /> cumulative impacts to public lands that must be analyzed under the National <br /> Environmental Policy Act.6 By failing to include these public lands in the initial permit <br /> application,Zephyr appears to be attempting to evade these important legal <br /> requirements.These reviews should not be left to some undetermined point in the future <br /> waiting for such an application to come forth in order to avoid public disclosure and <br /> involvement now.The Division should require that a comprehensive mining plan and <br /> permit application be considered now,work cooperatively with BLM to ensure that a plan <br /> of operations be submitted for public review so that all impacts are analyzed and <br /> addressed,and should expressly forbid the initiation of any mining activities on private <br />
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