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High water demand associated with the milling operation also threatens to reduce water availability in the <br /> Leadville area,where water supplies are already constrained and fully allocated. Existing residential, <br /> agricultural,and environmental water users should not bear increased risk or reduced reliability to <br /> accommodate this proposal. <br /> Inadequate Groundwater Characterization and Spill Planning <br /> The application does not adequately identify groundwater depth,flow direction,or preferential flow pathways <br /> across the site.Without detailed groundwater mapping and modeling, it is impossible to assess spill risks, <br /> contaminant migration rates,or effective emergency response measures. In the event of a spill or liner failure, <br /> timely mitigation would depend entirely on knowing how contaminants would move through the subsurface— <br /> information that is currently insufficient or absent. <br /> This deficiency alone represents a significant risk to drinking water supplies, private wells,and downstream <br /> users and should preclude approval until fully addressed. <br /> Disturbance of Historic Waste Piles and Airborne Risks <br /> The proposal involves disturbing long-stabilized waste piles on the east side of Leadville.These materials have <br /> remained in place for decades,and disturbing them will increase the risk of releasing toxic substances into the <br /> air,surface water,and groundwater. Freshly exposed materials are far more susceptible to erosion by wind and <br /> water,increasing the likelihood of fugitive dust and contaminant transport. <br /> Airborne toxic particulates present direct health risks to residents and visitors and undermine decades of <br /> progress in reducing the environmental legacy of historic mining in Lake County. <br /> Threats to the Arkansas River and Prior Restoration Investments <br /> Over the past several decades,millions of dollars and countless hours of work have been invested by federal, <br /> state, local,and nonprofit partners to remediate historic mining damage in the California Gulch watershed and <br /> throughout the Upper Arkansas River basin.These efforts transformed the Upper Arkansas into the longest <br /> continuous stretch of Gold Medal water in the nation—an achievement of statewide and national significance. <br /> This proposal risks undoing that progress. Even low-probability failures could have high-consequence <br /> outcomes for water quality,fisheries,recreation,agriculture,and tourism throughout Lake County and <br /> downstream communities. <br /> Impacts to Historic Character and Community <br /> Leadville is not only a place of residence but a nationally recognized historic community whose character and <br /> economy are deeply tied to its history and landscape. Industrial milling operations,ongoing waste transport, <br /> long-term tailings disposal,and perpetual environmental risk are incompatible with the preservation and <br /> revitalization of this historic area. <br /> The long-term costs—environmental,economic,and social—would be borne by the community long after any <br /> short-term benefits of the project have passed. <br /> Conclusion <br /> I respectfully ask DRMS to consider whether the risks posed by this project—to water resources, public health, <br /> historic preservation,and decades of environmental restoration—are justified by its proposed benefits.Given <br /> the deficiencies in groundwater characterization,waste management planning,and long-term risk mitigation, I <br /> believe this permit should not be approved. <br /> Thank you for considering this objection and the long-term interests of the Leadville community and the Upper <br /> Arkansas River basin. <br /> Permitting Action Comment/Objection is Regarding <br /> - New Permit Change to Existing Permit <br />