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typically inadequately characterized, risk to the watershed. The group's cleanup <br />initiatives may or may not have any true impact on the environment, yet the group <br />marches ahead regardless and without a clearly defined path (such as the risk-ranked <br />approach described above). <br />The Lake Fork Watershed Group includes Federal agency employees, moreover, who are <br />able to sequester public funds to pay for the group's activities whether or not the <br />activities truly qualify as an environmental benefit. Through this process the group is <br />perceived as a benefit to the environment, by a public that is never given the scientific <br />rationale behind the group's initiatives or intentions. At the same time, by focusing its <br />efforts on relatively benign mine features, such as Deadman Gulch and the Golden <br />Wonder Mine, the group both wastes public money and unnecessarily imperils valuable <br />sources of tax revenue to the community. <br />To me, there clearly are three problems with the Lake Fork Watershed Group's approach: <br />1. The community is given the impression that the group's cleanup initiatives <br />are in response to a real risk, when in fact they typically are not. <br />2, The group's efforts are not founded on a solid, scientific approach and are <br />unjustified by hard water quality data. <br />3. The group's initiatives are a needless and wasteful expenditure of time and <br />public money. <br />As an aquatic toxicologist with over eighteen years of experience working on projects <br />ranging from the EXXON. Valdez oil spill, Pearl Harbor, Rocky Flats Environmental <br />Technology Site (BEETS) etc., I am very accustomed to having to sort out perceived vs. <br />real risk issues for industrial and natural resources settings. For years I have designed <br />environmental cleanup efforts for a diversity of contaminant types. The mine-related <br />conditions I have observed in Hinsdale County do not cause me concern. Having a good <br />grasp of aquatic chemistry and toxicology, I know (and have scientifically measured) the <br />watershed within the area as having a tremendous resource value and excellent water <br />quality. I absolutely do not understand the Lake Fork Watershed Group's concerns <br />regarding the watershed, or the basis of the group's approach to targeting mine features <br />within the watershed for cleanups. At best, I discern an unrestrained desire to clean up as <br />many mine features as possible within the watershed, without due regard to the true risks <br />(ornon-risks) of the mine features and in the absence of a scientifically grounded method <br />of assessing risk. <br />What truly disturbs me is the fact that the community is led to believe that the Lake Fork <br />Watershed Group is pursuing real environmental concerns, whereas in reality, it is simply <br />tackling anything mine-related without scientific substantiation of its concerns. <br />I have critically watched the Lake Fork Watershed Group's field efforts and reviewed its <br />methods of data interpretation. I have serious concerns with all of the group's <br />