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RPR-20-2000 THU 0448 Ph • FAX N0~ P, 02 <br />WESTERN MINING AC-PION PRO,)T?(°C <br />2260 Baseline Rd., Sttite IOlA <br />Boulder, CO 80302 <br />(303) 473-9618 <br />Pax (303) 786-8054 <br />wmapCigc.org <br />Via Fax --liardcopy to Follow iiy Mail <br />April 20, 2000 <br />Mr. Michael Long, Director <br />c(o lantcs Dillie <br />Coloreulo nivision of Minerals and Geology <br />1313 Sherman Sl., Room 215 <br />Denver, CO 80203 <br />Re: TR-28, $attle Mountain Resources 1ttc., Sart ).uis Project, M-88-112 <br />Dear Mikc :utd 1itn: <br />This letter is submitted ott behalf of tltc Peoples Alternative Energy Services (PASS), ;aud <br />the Costilla County Conservancy District (CCCD), by and through their tntdcrsia ed alloreys, <br />and represents comments on TR-28 and rclatcd issues now pending before the DMG. Overtll, <br />TR-28 would seriously undermine the DMG's duty to protect surface and wound water azid <br />should not be approved. in addition, the subrttittal of yet attothcr technical revision, this time to <br />establish long-teen environmental compliance standards and pcrfomtance criteria continues a <br />pattern of lintilittg public review artd comment and also should not be allowed, Our specific <br />comments follow. These comments may he supplemented with additional comments as <br />information is obtained and analysis completed. <br />BMRI's Ncw Water Quality Proposals Mttst Be Processed as an Amendment, not a TR <br />ht TR-2S, BMRI proposes to substantially chutge its environmental perfonuancc <br />requirements and rclatcd monitoring and compliance conditions. This is yet another TR that has <br />been proposed without the public notice, review and comment procedures required by state law, <br />According to the Mined Land Reclamation Board's (NLRB's) Minerals Rules, such a propoea) <br />cnn be considered a technical revision if the change "does not have more than a minor effect <br />upon the approved or proposed Reclamation or Environmental Protection Plan." Rulc l.l(54). <br />In this case, TR-28 will substantially affect the approved Reclamation Plan and <br />Environmental Protection Plan and thus cannot be processed as a'fR. Sce attached comments by <br />Rocky Mountain Consultants. As noted in the DhIG's April 11, 2000, adequacy letter to BMRI, <br />TR-28 directly affects the water treatment and other requirements associated with the Wcst Pit, <br />