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<br />A third item in regard to water quality is misrepresented here. It is stated on Exhibit Page 24, EXHIBIT <br />G -WATER fNFORMAT[ON, "This operation is expected to directly but not significantly affect surface and <br />ground water systems in a positive manner... The mining and reclamation as planned should produce no <br />significant indirect or direct negative impacts." How can this be determined when a clear understanding of the <br />river ecology-namely the fishery-- is not understood? The environmental engineer, Nathan A. Barton, PE, <br />DEE has done some selective research. He leas either suppressed information from your Division intentionally, <br />which constitutes misrepresentation, or he has discovered the regulations and research on the Dolores River and <br />intentionally no[ presented it in the application so it would not be properly understood by your Division. To <br />further support this, I would like [o bring your attention to Exhibit Page 25, where it is stated, "no other <br />information .vas available from publications or monitoring data, such as flow rates, water table elevations and <br />water quality conditions." This is, once again, absolutely false. The US Geologic Survey has monitored the <br />Dolores River for decades and collected extensive stream flow data, both upstream of the proposed mining site <br />and do~vns[ream of the site. The Bureau of Reclamation collected extensive water quality monitoring data <br />before the construction of McPhee dam and the elaborate canal and pipeline system that is supplied by it. The <br />Towns of Dolores, Cortez, and Dove Creek all collect water quality information for their municipal water <br />systems. The Environmental Protection Agency has data and watershed assessments available to the public, <br />even available via the Internet, which the environmental engineer can access because he has email (see <br />"PERMITTING CONTACT," page 3 of General Operation Information). The Dolores Water Conservancy <br />District has had 3 public meetings regarding water quality monitoring and regulation on the Dolores in [he past <br />18 months and has implemented another monitoring program. The local high school even monitors the quality <br />of the Dolores River. These statements regarding water quality data availability and regulation are intended to <br />deliberately mislead your Division to believe that the environmental engineer has provided you with all <br />available inforntation. He obviously has the capacity to collect information and interpret it, as evidenced by his <br />calculation of the land area representing "O.l% of the drainage basin;' but he does not present what he [ells you <br />he presents in the perntit application, namely an assessment of all available water quality information. <br />B In regards to wildlife impacts, on Exhibit Page 28, EXHIBIT H -WILDLIFE INFORMATION, two <br />important wildlife species that have been seen at or near the proposed mining site are not listed. First, the <br />largest draw to the Dolores area in the fall is elk hunting. I have personally seen herds often or more elk at the <br />proposed mine site. It is stated on Exhibit Page 28, item 3, that "Due to the poor quality of forage and grazing <br />on the site, mining will have little or no negative impact on wildlife." This is preposterous. Elk graze there, <br />and they will no[ graze [here with crushers, loaders, bulldozers, 30-80 trucks per day, and pits in the ground <br />where there used to be forage, however marginal. Again, the elk were left out of the permit application and this <br />is a misrepresentation of material facts. Elk habitat is an important component of the river valley and the <br />economic future of the area. In fact, the owner of the property, Duvall Truelsen, also owns a restaurant in <br />Dolores that profits significantly from elk hunters during that season. He knows that elk graze at the proposed <br />site, and has not provided that information in this application. <br />Another issue is described in the permit application that warrants attention in consideration of the reclamation <br />of the proposed site. That is the owner. It is stated by the NRCS representative and quoted in the application <br />~. Z <br />