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cotter <br />VIA EMAIL AND U.S. MAIL <br />August 23, 2010 <br />Mr. Anthony J. Waldron <br />Division of Reclamation, Mining and Safety <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Re: Schwartzwalder Mine, Permit No. M-1977-300; Corrective Actions 2 &1 of the August <br />11, 2010 Mined Land Reclamation Board Order <br />Dear Mr. Waldron: <br />This letter respectfully responds to your August 13, 2010 letter, stating that plans for addressing <br />items 2 and 3 of the August 11, 2010 Mined Land Reclamation Board Order ("Order") must be <br />submitted as a technical revision to the permit by August 23, 2010. <br />The Order specifically states that "[a]ny party to a hearing may petition the Board to reconsider <br />its decision. Please refer to Hard Rock Rule 2.9 for guidelines, time limits, and procedures for <br />filing a Petition for Reconsideration." Pursuant to this provision of the Order, Cotter Corporation <br />(N.S.L.) ("Cotter") plans to petition for reconsideration. Therefore, it is inappropriate for the <br />Division to request a technical revision. <br />In addition, the Order says nothing about requiring a technical revision, defined as "a change in <br />the permit or an application, which does not have more than a minor effect upon the approved or <br />proposed Reclamation or Environmental Protection Plan." See 2 CCR 407-1 Rule 1.1 (52). As <br />Cotter has consistently stated on numerous occasions, the definition of a technical revision clearly <br />does not cover mine dewatering and treatment, and Cotter remains opposed to this corrective <br />action for the reasons set forth in its submissions and its testimony at the hearing. <br />Please contact the at 719-275-7413 (ext. 202) if you have questions. <br />Very truly yours, <br />S <br />John S. Hamrick <br />Vice President, Mill Operations <br />Cotter Corporation Telephone (719) 275-7413 <br />Canon City Mill, P.O. Box 1750, Canon City, CO 81215-1750 USA Fax (719) 275-1669