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HRMM 1.13.9, C.R.S. § 34-32-103(6)(a)(III)("In no case shall temporary cessation of <br />production be continued for more than ten years ... " Id.). These inactive mines were noticed <br />for temporary cessation in 1980, and the permits should have lapsed no later than 1990, over <br />fifteen years ago. Our review of the permit file, particulazly the annual reports, reveals no <br />mining activity that would allow the permits "to continue in effect " C.R.S. § 34-32-103(ti)(a). <br />The annual reports also reveal little, ifany progress towazd reclamation. The MLRA provision <br />on temporary cessation was adopted to avoid the situation where mines languish for decades <br />without production and without full compliance with reclamation and EPP requirements. <br />Based on our understanding, we request DMG to undertake the necessary inquiry and actions to <br />determine whether or not the permits for the JD-6, JD-8, JD-9 and SM-18 Mines aze in fact <br />extant, whether they have lapsed or otherwise become invalid, and/or whether other action is <br />necessary to properly regulate what DMG has properly determined aze DMOs. <br />Conclusion <br />The Colorado Environmental Coalition, San Juan Citizens Alliance, INFORM and the general <br />public have considerable interest in the Dolores River Basin that will be affected by the current <br />uranium boom in general and the regulation of the JD-6, JD-8, JD-9 and SM-18 Mines in <br />particular. We look forward to participating in transpazent and effective efforts to protect land, <br />water, air, wildlife, human health, and the public interest. For these and the reasons stated above, <br />we request that DMG and MLRB confirm DMO status for the JD-6, JD-8, JD-9 and SM-18 <br />Mines and avoid further delay in ensuring that these four mines meet all regulatory standards <br />applied to Designated Mining Operations. <br />Should you have any questions or would like to discuss this further, please do not hesitate to <br />contact us. <br />Since y; - <br />~- <br />s~is Stills <br />Travis Stills <br />Attorney <br />Energy Minerals Law Center <br />On behalfof: <br />Colorado Environmental Coalition <br />San Juan Citizens Alliance <br />Information Network for Responsible Mining (INFORM) <br />Cc: Western Mining Action Project <br />Cheryl Linden, Colorado AG's Office <br />