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WESTERN MINING ACTION PROJECT <br />Roger P mm, Esq.. <br />Jef ev C. Patrons. Esq. <br />P.O. Box 344 <br />440 lvtain Street, Suite 2 <br />Lyons. CO 80540 <br />(303) 823-5738 <br />Fax (303) 823-5732 <br />wil1anfcrii ?e,.,ttrb <br />Via Facsimile (303-832-3106), email (l?erh n.keffelew Ci?statc ), and hard copy via. U.S. Mail first class <br />June 17, 2008 <br />Mr. Berhan Keffelew <br />Division of Reclamation Mining and Safety <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />RE: Comments on CC&V Amendment 9 application (Permit # M-1980-244) <br />Thank you for the opportunity to present these comments to the Division of Reclamation <br />Mining and Safety ("DBMS") on the application submitted by Cripple Creek & Victor Gold ]Mining <br />Company ("CC&V") for a revision to the existing Mined Land Reclamation Permit M-1980-244 for <br />the Cresson Project. These comments are submitted, through the undersigned, by Citizens for <br />Victor, Rocky Mountaiu. Cha.ptcr of the Sierra Club, and INFORM (collectively "commenters"). <br />The undersigned commenters regret the short amount of time available to rcvicw and <br />comment on this complex and technically detailed proposal. In fact, the documents were not <br />scanned in and made available to the public in. any electronic forum until after May 23, 2009, a fill] <br />month alfer the same was received by the Division. While commenters appreciate the fact that <br />physical hard copies of the multi-thousand page application were available in Teller County and at <br />the DRMS office in Denver, the lack of any timely electronic copy, particularly in. this digital <br />business age, has greatly handicapped and in a large respect deprived the ability of the public to <br />effectively understand and t;un IIicnt on this application. In light of this circumstance, commenters <br />request that the DR.MS accept future comments on this application as an understanding of the <br />proposal develops. To this end, commenters would welcome any opportunity to meet with the <br />Division staff and/or CC&.V representatives, in combination or independently, to review the <br />technical aspects of the application to better understand the proposal and hopefully to alleviate <br />concerns raised in this comment letter. <br />Regardless, bulleted below are concerns commenters have identified with the proposed <br />application. <br />• The application does not demonstrate that the current or proposed point(s) of compliance for <br />purposes ohconiplianca with groundwater quality standards is protective of public health or <br />the environment.