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Mr. J. David Holm <br />Water Quality Control Division <br />Page 2 <br />This response to comment package includes a separate technical memorandum which <br />provides detailed, point-by-point responses to written comments submitted by the U.S. <br />Environmental Protection Agency ("EPA") and by the Costilla County Conservancy <br />District ("CCCD") and Peoples Alternative Energy Services ("PAES"). in addition, this <br />letter includes responses and proposals intended to address key issues framed in both <br />written and oral comments regazding the draft permit. <br />Administrative Considerations <br />Battle Mountain believes that the public comments deserve a thorough response and that <br />the best way to accomplish this goal is the prepazation of a revised draft permit with a <br />rationale which is responsive to the concerns raised in the comments. We would also <br />encourage your office to schedule another public meeting in San Luis in an effort to more <br />fully explain the terms of the permit and the approach followed by your office to respond <br />to the issues framed in the comments. In scheduling that meeting, we would suggest that <br />it be held in the evening to allow participation by the full spectrum of the working <br />residents of San Luis. That said, it remains critical to BMG that the permit process be <br />expedited in order to bring the current response activities within the terms of a final <br />CDPS permit. Therefore, we believe it is essential that the revised draft permit be <br />completed no later than July 31, 2000 and published shortly thereafter. We would also <br />suggest that your office commence the process now to schedule a public meeting that <br />could be held during the public comment period or shortly thereafter. <br />A number of the comments asserted that both Battle Mountain Gold as well as Battle <br />Mountain Resources Inc. ("BMRI") be identified as the permittee on the final permit. In <br />strict accordance with your regulations Rule 61.4(1), the original permit application for <br />the facility identified BMRI as the applicant because BMRI owned the land, BMRI <br />employees operated the facility and BMRI is the permittee on virtually all other permits <br />which have been in place for the facility since its initial construction. However, as we <br />have discussed throughout this process, Battle Mountain is committed to a satisfactory <br />