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Preliminary Adequacy Issues for AM-01 <br />Possible Conflict with La Plata County Land Use Code - Appropriate Type of Reclamation Permit <br />1. As noted by La Plata County in their correspondence dated April 26, 2010, the amended <br />application for the May Day Mine does not secure motor vehicle access for the site and does not <br />include the water supply ponds within the permit boundary. These two critical components of the <br />proposed operation are apparently addressed under a different permit application (Idaho Mine, <br />M-2010-003). La Plata County has indicated that the permit may be in direct contradiction with <br />the requirements of Chapter 82 of the La Plata County Code. Pursuant to C.R.S. 34-32-115(4)(c)(1), <br />no part of the proposed mining operation may be contrary to the laws or regulations of this state <br />or the United States, including but not limited to all federal, state, and local permits, licenses, and <br />approvals, as applicable to the specific operation. Please resolve the possible conflict with the La <br />Plata County Land Use Code. <br />2. La Plata County also noted a potential for confusion resulting from the division of one 112 <br />operation into two interdependent 110(2) operations. The operation proposed at the May Day <br />Mine appears to be dependent upon the plans proposed at the Idaho Mine. If fact, AM-01 <br />acknowledges the interrelatedness of the two operations by describing various features as the <br />"Mayday-Idaho Mining complex," and the "Mayday-Idaho mine diversion," and the "Mayday- <br />Idaho Wildcat Augmentation Ponds" (page four of Exhibit Q. Additional examples of <br />interrelatedness include: <br />• Support facilities for the May Day Mine, which are proposed to be permitted under the <br />Idaho Mine, are described in Exhibit B, Attachment B-3, Attachment B-4, Exhibit C, <br />Attachment C-3, Figure E-2, and Figure E-6 of AM-01. <br />• The laboratory analyses of water, soil and rock samples, utilized to characterize the May <br />Day Mine, are identical to those utilized to characterize the Idaho Mine. <br />• The two sites utilize common sample locations for surface and ground water monitoring. <br />• Figure X-X proposes to delineate a 200 foot buffer for the May Day Mine. Portions of that <br />buffer actually extend 1,400 feet from the permit boundary for the May Day Mine and <br />appear to have merged with the 200 foot buffer for the Idaho Mine. <br />The two proposed operations appear sufficiently entangled to be difficult, if not impossible, to <br />separate for enforcement purposes should adverse impacts to surface or ground water occur. The <br />potential for confusion and conflict is greatly increase if the two permits are later transferred to <br />different successor operators. As noted by La Plata County, the two 110(2) applications appear to <br />describe one 112type operation. Please address. <br />Public Notice <br />3. Prior to submitting the application to the Division of Reclamation, Mining and Safety, the Applicant <br />was to post a notice at the mine entrance in accordance with the requirements of Rule 1.6.2(1)(b), <br />and provide an affidavit that such notice had been posted. The Applicant provided the affidavit <br />and the Office accepted the affidavit as representation that the appropriate notice had been <br />posted. However, during a recent site inspection the Office observed that the posted notice