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In no case shall Temporary Cessation be continued for more than ten (10) years <br />without terminating the mining operation and fully complying with the <br />Reclamation and Environmental Protection Plan requirements of the Act and <br />these Rules. <br />We believe there has been a violation of temporary cessation limitations in this case as <br />"...the (iJrantah Decline) mine was closed in September 1981. The mine was later <br />acquired by Cotter Corporation, but remained idle until it was reclaimed in the fall of <br />2002." <br />Additionally, "the Packrat mine operated until 1990 when the mine was placed on <br />standby in response to depressed uranium prices. Umetco reclaimed the mine surface <br />area in 2002." <br />Here is a case where both mine sites were idle for more than 10 years, without initiation <br />of reclamation activities. <br />Conclusion: <br />Overall, we ask that the Division apply the most conservative assumptions in assessing <br />and designing operational controls and reclamation activities for this site. As has been <br />demonstrated at countless uranium mines in the region, successful reclamation is often <br />difficult, and the costs associated with that reclamation often vastly under-estimated. <br />Colorado citizens expect to never be in the position again that tax-payers must step into <br />cover reclamation costs. The Division can ensure this result in this case by applying the <br />strictest scrutiny to the operation and reclamation plan for the Whirlwind Mine. <br />We look forward to additional opportunities to comment on the proposed reclamation <br />plan, and ask that the Division make such plans fully open for such comment and <br />technical review by the public and other federal, state, and local governmental agencies. <br />If you have any questions at all please feel free to contact me directly by phone, email or <br />mail at your convenience. <br />Sincerely, <br />Brian Farnsworth, Executive Director <br />INFORM ("Information Network for Responsible Mining") <br />10 <br />