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APR-20-2000 THU 04 48 PM FAX N0. P, 03 "1'hc requirements imposed as a result of TR-23 will control the very nature of the site, including BMRI's reclamation responsibilities. The fact that previous technical revisions were not classified by the DMG as amendments but rather as technical revisions does not mean that such a practice complies with htI-RI3 Rules. Amendments require public notice and hearings -- essential aspects of public review of such critical permit utodificalions. 13MR1 admits that TR-2S will control the long-term management and arvironmcntal protection conditions at the site. Its review, coupled with the still-unapproved (in its cutircty) TR-2G, should be before the citizens of San Luis and other interested panics -- uotsimply a matter between the Dl~1G and BMRI with limited input from the public. The MLRB required that the interested parties to the procccdingover TR-2G be served by BMRI with all relevant documents. Instead of complying with this Order, BMRI circumvented public review by labeling these new changes as TR-28, rather than proposals related to TR-2b. it appears that the DMG approves of dtis tactic. Such a ntancuver does not foster the trust of the citizens of San Luis and clouds the entire perntitting process. We have previously and specifically complained about rho inadeyuacy of the BMRi's/llMG's continued reliance on TRs instead of tnnendments -- apparently to little avail. Iu addition, TR-28 is under consideration at the same time that BMRI is reviewing the UMG's requested finazicial assurance/bottdtncrease as noted in DMG's Mazclt 10, 2000, totter to BMRI. 'lltis bond decision by DMG was done witltottt any real significant public notice or review. Overall, critical decisions regardins the long-term financial and envirottn,antal soundness of tl,e San Lttis Mine have been made without seriously involving the very local ci~tizetts that will be most affected by DMG'sfBMR}'s actions. We request that the DMG deem TR-28, along wilt other outstanding issues al the site (financial assuranee/hond review), to be an amendment of the permit and n:quire the public notice and other reviews tnandatcd by the MLRB Rules. TR-28 Rcpresettts a Significant Relaxation of Environmental Responsibilities and Should Not Bc Approved. Regardless oFwhether 1'R-28 is considered an amcndn,ent or technical revision, it seriously erodes water quality protections anti catutot be approved. Selected specific comments follow: The Points of Con,pliancc Should Not Be Moved Downstream/Downeradicnt I~Mit1 proposes to move points of compliance far downstream or dowttgradi~ent from the West Pit window. For cxatttple, it proposes to assure ground water protection in the Ri[o Seco alhivial aquifer by measuring the !curls at M-34, well over 2,000 feet dowttstrcarrt/dbwngradicnt