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Further, it appears that the DMG has erroneously analyzed the JD mine complex under the less stringent regulations of Rule 110. However, the MLRB's June, 2006 notice of hearing and the permit file indicates that JD-8 and 3D-9 mines operate under 112 permits. Further, there is some question as to the propriety of permitting these mines separately. These mines are viewed as a single lease complex by the owner of the federal estate encompassed by the mine permits and is known as the "Paradox Valley lease tracts." The JD-6, JD-8, and JD-9 mines ("JD Mine Complex") are part of afederally-leased uranium mine complex operated by Cotter Corporation. Federal agency records indicate that the Paradox lease tract is part of Department of Energy ("DOE") tract leased to Cotter Corporation on or about 1995 for a term of 10 years that either has expired or is set to expire in the near future. Publicly available federal and state records indicate that intermittent exploration and mining have taken place on these federally leased uranium deposits for nearly forty years. Public records indicate that buildings and structures, mine-waste rock piles, adits/inclines, vents, drill roads, drill holes, petroleum tanks, dewatering equipment, and retention ponds are found on site. Currently available Mine Safety Health Administration ("MSHA") records list these operations as "non-producing" with only one employee on site in the ls` quarter of 2006. In addition to state regulation under the Mined Land Reclamation Act ("MLRA") and the terms contained in the federal lease, activities that take place on the JD Mine Complex aze subject to federal laws, including the National Environmental Policy Act and are subject to the oversight responsibilities of the Depaztment of Energy and the Bureau of Land Management. Activities regarding JD Mine Complex may also implicate the Endangered Species Act due to federal records indicating the presence of protected species, including the listed southwestern willow flycatchers, on the actual lease tracts. Public records also indicate that the JD Mine Complex is located in important mule-deer winter habitat and that Bald Eagles are located in the area. Several species of protected bats are also likely found on, in, or near the JD uranium mines. Public records recognize that human health of both workers and the general public may be impacted by exposure to both radiological and nonradiological hazards on the lease tracts. These mines are located on federal public lands that, although leased, remain open to multiple use by the public. These mines have been operating sporadically since first obtaining MLRB permits in 1970s and early 1980s. The DMG files indicate that for much of that time, approximately 25 years, these mines has been idle and involuntary cessation status. Agency records, including those of MSHA, have identified multiple health and worker exposure violations at the JD mines. DMG inspections have also documented concerns and problems at these mines. The DMG report and analysis dated April 5, 2005 indicates that "contamination build up of surface materials from prolonged use of an azea may be an issue of concern" at all these mines. As a single example of the impacts, "major erosion has occurred" at the 3D-6 Mine and the associated Mineral Joe Claims. During a recent, but brief period of active mining in 2005, "approximately 50 tons of materials was observed stockpiled" at the JD-6 mine to maximize haulage efficiency. At the JD-9 mine, "60 to 80 tons of ore [were] noted stockpiled" and ponds were "beginning to show their age."