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<br /> <br /> <br />3 <br />subsequent summaries by parties to the hearing. That <br />transcript, the summaries, and Commission deliberation well <br />reflect the quality of the standards against which your <br />determinations must be made. <br />The Mined Land Reclamation Division must establish the <br />.credibility of the stream standards before it can, in good <br />scientific conscience, impose monitoring requirements beyond <br />''those specified by tike NPDES permit. Thus far, the MLRD has <br />been notably silent in the Colorado address to classification <br />of streams. The Water Quality Control Commission remains <br />uninformed of the MLRD needs for adherence to scientific <br />principles to derive enforceable standards. So long as that <br />vacuum exists, confusion will prevail and communications will <br />frequently break down over issues that derive directly from <br />measurement systems employed. Until the MLRD has satisfied <br />itself the data it requiures from operators is comparable to <br />the data base on which the WQCC promulgates standards, no <br />rational conclusions can be drawn about the operator's <br />compliance with standards. The only rational base left for <br />comparison is the operator's baseline and how it is impacted <br />locally by comparative data collected by the operator. <br />CF&I has received the draft findings documents since I <br />talked to you. I have not yet had an opportunity to review <br />them, but suspect much of my problem with them is rooted as <br />expressed above. Your timely response to these comments will <br />assist us in our meaningful address to environmental concerns. <br />Again, I appreciate your time and effort in helping me <br />address your concerns and eagerly await your reply. <br />Sincerely, <br />~~i/~~ - <br />ac. D. Gillesp'e <br />District Geologist <br />JDG/as <br />OoWQHa <br /> <br />