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Wally Erickson <br />June 28, 2010 <br />Page 3 <br />B-3, Attachment B-4, Exhibit C, Attachment C-3, Figure E-2, and Figure <br />E-6 of AM-01. <br />The laboratory analyses of water, soil and rock samples, utilized to <br />characterize the May Day Mine, are identical to those utilized to <br />characterize the Idaho Mine. <br />The two sites utilize common sample locations for surface and ground <br />water monitoring. <br />• Figure X-X proposes to delineate a 200 foot buffer for the May Day Mine. <br />Portions of that buffer actually extend 1, 400 feet from the permit boundary <br />for the May Day Mine and appear to have merged with the 200 foot buffer <br />for the Idaho Mine. <br />The two proposed operations appear sufficiently entangled to be difficult, if <br />not impossible, to separate for enforcement purposes should adverse impacts to <br />surface or ground water occur. The potential for confusion and conflict is <br />greatly increase if the two permits are later transferred to different successor <br />operators. As noted by La Plata County, the two 110(2) applications appear to <br />describe one 112 type operation. Please address. <br />Response to Adequacy Issue No. 2: As an initial matter, in its April 26, 2010 letter <br />La Plata County does not use the terms, "110(2) operation," "110(2) application" or "112 <br />operation." As it clarified in its letter dated May 21, 2010, La Plata County commented <br />only that: "Pursuant to La Plata County's Code, requirements, such as water and access <br />must be proven for each site and each permit must have independent proof of water and <br />access." See Letter from E. Aune, La Plata County, to DRMS, at 1 (May 21, 2010). <br />Because Wildcat Mining presents adequate proof of water and access for both the May Day <br />Mine and the Idaho Mine, it satisfies Chapter 82 of the La Plata County Code. <br />Moreover, to the extent there is any confusion between the applications for the May <br />Day Mine and the Idaho Mine, such confusion has existed since at least the early 1980s. <br />By way of example, the permit for the May Day Mine which was approved by DRMS <br />includes a Legal Description at Exhibit A, a Mine Plan at Exhibit B, a Reclamation Plan at <br />Exhibit E, a Proof of Local Government Approvals at Exhibit F, and a Source of Legal <br />Right to Enter at Exhibit G, all for the, "May Day - Idaho Mine." Wildcat Mining has <br />merely adopted these same naming conventions for its amendment application, AM-01. <br />The May Day Mine and the Idaho Mine are located in close proximity to each other <br />and exist together in the same ecological and geological setting, and historically both mines <br />have relied upon the same road for access. This explains why the mines have similar or <br />common support facilities; laboratory analysis of water, soil and rock samples; sample <br />locations for surface and ground water monitoring; and buffer zones.