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Comment/Objection Narrative* <br /> The following are my primary concerns related to this permit: <br /> •Transparency:There has been a consistent lack of transparency and communication to the public and <br /> affected communities. <br /> o Example:The BOCC substate water proposal states that the Division engineer will be notified of the proposed <br /> drilling sites and creek diversion sites. How will the public/residents be notified of these plans? <br /> o Example(from County Commissioners'response):As this project continues to move forward La Plata County <br /> requests that a resource be made available,or if one already exists that it be shared as part of future outreach, <br /> to provide clarification, project tracking,and progress to the citizens who may be directly impacted by the future <br /> of these actions or citizens who have an invested interest in the project. <br /> •Accountability:There are commitments and contingencies outlined in the DRMS permit application, but it's not <br /> clear how and when those will be monitored and enforced. <br /> o Example(verbatim from permit): However, it[sic]an unanticipated small fracture hosting water is encountered <br /> it can easily be contained through cementing of the interval (as described in the NOI)and by approved and <br /> mandated hole plugging methods when the hole is completed. <br /> •Water Supply: Metallic Minerals and its contractors propose a water diversion and reclamation plan that lacks <br /> detail, but threatens to impact water supply and quality downstream for homeowners,farmers, businesses,etc. <br /> If water augmentation occurs at the junction of La Plata River and Highway 160, how will Metallic Minerals and <br /> its contractors address depletion between the drilling sites and the Highway 160/La Plata Riverjunction <br /> (Mayday,residents of the canyon,etc.)?The permit also states that water will be diverted from"the creeks' <br /> respective confluence with the La Plata River along County Road 124(exact diversion locations are yet to be <br /> determined)."This presents a highly undesirable scenario for the residents and visitors to La Plata Canyon if <br /> trucks are pulling water from random points along County Road 124. <br /> •Water Contamination:As the County Commission points out, it is likely that any surface contamination from <br /> the exploration will migrate into surface waters and impact down gradient users and resources.This could have <br /> public health impacts on children and underserved communities that use drinking water and irrigation <br /> downstream. How will Metallic Minerals mitigate these occurrences?Likewise,where is the plan requested by <br /> the Commissioners to manage drainage and migration of toxic metals and contaminants both during and after <br /> exploratory activities to protect the surrounding environment and down gradient users? <br /> •Environmental Impact:The USFS approved Metallic Minerals'permit without the required environmental <br /> assessment or environmental impact statement because"the project is short-term...the timeframe of 12 months <br /> will apply."However, Metallic Minerals'own permit application and related materials repeatedly cite a five-year <br /> timeframe. <br /> •Traffic, Noise Pollution,and Disruption:The impact of heavy equipment and increased traffic could result in <br /> damage to county roads and safety concerns, as the Commissioners point out.Where is the maintenance, <br /> traffic control and safety plans requested by the Commissioners?The canyon is a pristine environment,and the <br /> impact of noise pollution on wildlife, recreational visitors,and residents is also a major concern. <br /> •Economic:Tourism is a major economic driver in the Durango area,and La Plata Canyon has many historical <br /> and environmental assets, including Kennebec Pass,waterfalls, La Plata City, Mayday,etc.The canyon is also <br /> a popular destination for summer and winter recreational activities—from camping and hiking to backcountry <br /> skiing and snowmobiling. Exploratory mining operations could have a significant negative impact on these <br /> revenue streams. <br /> Permit Number* <br /> Enter valid letter and then numbers,for example M1977999, M1999777UG or C1981201. <br /> P2023012 <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 /> County* <br /> La Plata County <br /> Enter one county only <br /> Site Name <br /> Allard Claim,Copper Hill Claim, <br />