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(mil {` V'~ ~ "~ ~1- (4~"1- 3/ to ~ ~nergy Minerals Law Center M - l9~?- 306 1911 Main Avenue, Suite 238, Durango, Colorado 81301 Phone: (970) 375 9231 Fax: (970) 382 0316 Email: emlc@frontier.net l~- ~ ~$~-~~~ L~ ~oc` Byr ~e Humphries +~Division of Minerals and Geology Department of Natural Resources 1313 Sherman St., Room 215 Denver, Colorado 80202 RECEIVEp ~N 3 0 2006 Uiuision ofMine~als and Oeolopy RE: Designated Mining Operation Status of Cotter Corporation JD-6, JD-8, JD-9 and SM-18 Mines Deaz Mr. Humphries, January 27, 2006 This letter is written on behalf of the San Juan Citizens Alliance, Information Network for Responsible Mining (INFORM), and the Colorado Environmental Coalition and concerns the Colorado Division of Minerals and Geology ("DMG") regulation of the Cotter Corporation's JD- 6, JD-8, JD-9, and SM-18 mines. We appreciate the DMG's work in updating its regulatory efforts over re-opening mine sites in response to the latest boom in mining activity in Colorado. We look forward to participating in the emerging efforts to bring old mines, permits, and plans into compliance with the post-Summiriille mining and reclamation standards. The Energy Minerals Law Center (EMLC) is a project of the Western Mining Action Project that provides legal services to communities, grass-roots groups, and Native American Tribes fighting the destructive and harmful impacts of energy mineral mining. EMLC looks forward to working with the DMG staff and the Mined Land Reclamation Board ("NLRB") and especially those opportunities to include informed public participation in your regulatory program. This letter specifically addresses the requests by Cotter Corporation to restart four uranium and vanadium facilities - JD-6, JD-8, JD-9, and SM-18 mines. DMG records indicate that these four facilities were issued permits in 1979. The files indicate that the DMG considers three of these mines -- JD-6, JD-8, JD-9 -geologically similar for purposes of determining DMO status. Although the four DMO determinations are being addressed in this letter, please consider each statement in support of DMG's DMO determinations and each objection to Cotter Corporation's DMO appeaUapplication as it applies to these mines individually and cumulative. DMG Properly Determined These Four Mines are Designated Mining Operations The DMG's July I5, 2005 and July 22, 2005 "SPLP results review" found toxic contaminants leaching from mine facilities and therefore properly determined that the JD-6, JD-8, JD-9, and SM-18 uranium/vandium mines satisfy the criteria for Designated Mining Operations. ("DMOs"). The subsequent July 25, 2005 DMO Notice of Determination also properly states that these mines are DMOs. Cotter must therefore comply with regulations applicable to a DMO, including the submission of an Environmental Protection Plan ("EPP") as specified in HRMM Rule 6.4.19.