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Colorado Environmental Coalition (CEC) is a Colorado-based environmental advocacy organization with three field offices in western Colorado and a main office in Denver. CEC has approximately 3,500 individual members and over 90 affiliated organizations. CEC campaigns engage citizens in the protection of Colorado's wild places, open spaces, wildlife and quality of life. CEC is a known and active participant in public land management in Colorado, with a demonstrated interest in energy development on Colorado's BLM lands. CEC members are concerned with protecting wildlife, scenery, water quality, quality of life, and other values. Information Network for Responsible Mining (INFORM) is a nonprofit organization with the mission of educating the public about the dangers that exist when unsafe and irresponsible mining practices are permitted. Through the dissemination of information and education, INFORM helps organize residents in local communities most threatened by these practices to protect water quality, quality of life and the local economy. The San Juan Citizens Alliance was founded in 1986 as a voice for environmental, social, and economic justice in the San Juan Basin of southwest Colorado and northwest New Mexico. San Juan Citizens Alliance works toward the protection of the wild lands, greater corporate and governmental responsibility in the development of natural resources, and for the protection of the waters in the Basin and includes more than 500 members who live in and who caze about the natural and human resources of the basin. Please consider this letter as both a written statement of these groups' support for the DMG's DMO determination and as their written objection to the August 25, 2005 non-DMO appeal and/or DMO-exempt status sought by Cotter in response to the DMG's well-founded DMO determination. C.R.S. § 34-32-114. Further, please include EMLC and the undersigned groups in any official notice of hearing or applications that may flow from the DMG regulation of these four mines. Md, in the spirit of cooperation, proactive regulation, and full public participation, EMLC requests and would greatly appreciate informal notice of any action that the DMG or the MLRB may consider taking regazding these four mining operations. The Twenty-Five Year Cessation May Have Voided the Permits Last, based on our review of the file, these permits aze likely invalid by operation of law. C.R.S.§ 34-32-103(6)(a). It appears that the permits for these four mines may not be valid by virtue of the temporary cessation rules at HRMM Rule 1.14. It is our understanding that the DMG review assumes these mines have remained on active status since the initial permits were issued in 1979. Our review suggests that the mines likely fall within the indicators for temporary cessation at HRMM Rule 1.13.2. Further, the permit file indicates that these mines were noticed for temporary cessation status in 1980 and have remained inactive for the ensuing 25 years. The regulations, like the MLRA, states, In no case shall Temporary Cessation be continued for more than ten (I O) years without terminating the mining operation and fully complying with the Reclamation and Environmental Protection Plan requirements of the Act and these Rules."