2024-03-16_REVISION - M1990057 (10)

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Comment/Objection Narrative* I am writing to express my strong objection to the proposed Leadville Mill project in our community.Approving this project will result in significant negative environmental,economic,and cultural impacts to Leadville,the Arkansas River,and downstream communities. A decision to approve the Mill project would be a sad reversal of the multi-decade efforts by Leadville residents, the state,and EPA that has resulted in the cleanup of the Arkansas River and entire Superfund site.Today,the Arkansas river runs clean and Leadville surface waters are largely free of contamination. The citizens of Leadville fought hard to keep many of the East side tailing piles intact during the SuperFund cleanup process.Their intent was to maintain evidence of the mining legacy in respect to prior generations of miners and to serve as a critical attribute supporting a tourist based economy that has backfilled mining as a principal economic driver of the county today. CJK's premise of environmental cleanup is predicated upon the claim there is mine waste drainage polluting surface and groundwaters including the Arkansas River as demonstrated by the monitoring at Otero Pump Station.The existing acid drainage emanating from their properties has not been quantified nor has the possible contamination contribution to surface and groundwater been determined or quantified. Is there a problem to mitigate? Moreover,the mining waste from CJK properties represent a very small proportion of the largely mitigated and stable tailings surrounding Leadville. I am astonished that their claim of environmental cleanup can sustain governmental and public review. Underscoring my objection to the project is my concern about CJK's integrity based on their representation that the project is an innovative environmental cleanup project and they are helping the Leadville community. I see no innovation whatsoever,as the practices for mining,trucking, milling,cyanide extraction,and storing of the waste are all conventional. Amplifying concerns over CJK integrity is their statement that safety is their#1 priority. However their DRMS Mill application states their cyanide plan will give"consideration of the principles and standards of practice of the International Cyanide Management Code".CJK should be a signatory of the Code.That would obligate them to comply with Cyanide Code practices including practices selectively omitted from their application. Omitted include: Minimize cyanide use,thereby limiting concentrations in the mill tailings; Establish a financial assurance mechanism capable of full funding cyanide-related decommissioning activities; Require that cyanide is safely managed through the entire transportation and delivery process from the production facility to the mine by use of certified transport;and' Conduct certification audits conducted by independent third-party auditors every three years to evaluate how the mill is operating with regards to cyanide related best practices. I have thoroughly reviewed the CJK application documents and find numerous inadequacies that are discussed in the attached document. I urge DRMS to deny the Leadville Mill Project as the risks are too high,and the long-term consequences potentially disastrous for the upper Arkansas River basin. Permit Number* Enter valid letter and then numbers,for example M1977999, M1999777UG or C1981201. M1990057 Permitting Action Type Select revision type or leave blank if comment pertains to a new permit application or NOI Permit Type 518 Harrison Ave County Lake Enter one county only