2023-08-17_REVISION - P2022019 - Laserfiche WebLink

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Off-site damages from stormwater events and waste disposal must be seriously considered in the permit conditions. Long Park includes mixed habitat zones and soils that are easily disturbed and eroded. Strict erosion and sediment controls should be utilized in order to prevent the release of any contaminants into the San Miguel River,where all stormwater runoff from this region in Long Park reports. The permittee should be required to provide sediment fencing around drill pads,mud pits, and any disturbed areas during the drill. At a minimum,provisions for a monitoring plan,lined mud pits, and off-site disposal of cuttings and other waste,which could potentially include radioactive contaminants or materials with acid-generating potential, should be required. Hazardous substances used for mining activities—such as diesel— should be stored onsite only when secondary containment structures are also in place,in order to prevent damage to the surface from spills and leaks. We encourage you to require the best management practices that are appropriate for the drill sites in order to minimize any impacts to the watershed and to restore the area once exploration is completed. It is unclear why such extensive road development needs to occur, and under no circumstances should new or existing roads be left in an improved condition beyond their current state. Continued road development in the Long Park area will have a negative impact on the public's ability to enjoy the lands and will further degrade the already disturbed environments. The permittee should also be prohibited from disturbing or destroying any long-lived woody species, as their restoration after the fact would be difficult or impossible to achieve, considering the long-term drought conditions the region is experiencing.Any degradation of existing pinyon juniper woodlands would be unfortunate, and during reclamation,the permittee should be required to re-seed with sage,pinyon and juniper in addition to (and not instead of) other native flora species. There is also abundant biological soil crust in this region of Long Park. Biological soil crusts are essential to and Southwest environments as they aid ecosystems to soil retention and nutrient density. This biological soil crust is highly sensitive to road development and human disturbance and should be avoided during operations. In addition,before any surface disturbances occur, it would be prudent to inventory any cultural or historic resources that may be present in the project area, since archeological resources are widely dispersed in the West End,petroglyph sites and camps are nearby, and Long Park itself was likely utilized by historic peoples. Lastly,the specific mines and exploration areas included in this Notice,including the Sunbeam and 45-90 Mine, show signs of significant damage from historic mining activities. Although it is apparent that some reclamation work was attempted in the 1980s at the site,it has not held up to time and there are visible signs of erosion from pocked slopes, subsidence, and reopened portals, as well as industrial debris left behind. It is imperative that the Division require a robust remediation plan for the entire mining area that will be more effective than past efforts and can withstand the changing climate conditions in the watershed as well as future increases in recreational activities and public visitation. Because the establishment of native vegetation is especially difficult and the amount of topsoil retained during operations will be inadequate to ensure reclamation success,the Division should consider a requirement that the operator amend soil on site in order to increase the amount of topsoil available and nurture effective growing conditions for native species. The proposed financial warranty of$19,500 is likely inadequate to ensure proper reclamation of new disturbance should the operator fail and the job becomes the public's burden.