2011-03-02_REVISION - M1981185 (23)

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M_ARCI-I 2, 2011 MAY DAY IDAHO MINI: COMPLEX, PERMIT NO. M-1981-185 PAGE 2 Or 2 accomplished only with detailed Construction Plans showing specific final grades, fill slopes, extent of disturbance, retaining wall details and other fundamental road components. We request that the Board require detailed Construction Plans for the private access road west of the river and ensure that adequate geotechnical, engineering, and construction information is provided to determine: (1) The road is safe for its intended uses, and (2) Adjacent wetlands and the La Plata River will not be damaged Access Road East of La Plata River The access road continues east of the La Plata River. This road is historic and appears to be stable, although it is very steep and with hairpin curves. We recognize these features are inherent to hard-rock mining and that minimization of disturbance is desirable. The applicant is proposing, however, that 20-30 mine employees and occasional service vehicles will use the road. This seems to be a grey line between mining activity and public access. Any evaluation or recommendations the Division of Reclamation Mining and Safety (Division) can make to balance minimization of disturbance and safety of employee and service vehicle access on this historic road would be appreciated. Handling and Monitoring of Waste Materials and Chemicals The May Day and Idaho Mines share an access road with the Incas Mine, which is understood to leach gold from ore using cyanide. The May Day Idaho Mine Complex proposes to use environmentally-friendly chemicals, and these typically have a lower productivity than cyanide. Given the remoteness of the May Day Idaho Mine Complex and desirability of cyanide in gold production, it is unclear how use of the proposed chemical rather than cyanide can be assured. Regardless of the chemical used in the mining process, there will be waste products produced and stored in the La Plata River watershed. We request that the Board use the maximum controls within its jurisdiction to ensure that May Day Idaho Mine Complex activities do not incorporate the use of unauthorized chemicals and that waste is stringently managed so as to have no adverse impacts on the watershed.. We appreciate the Board's consideration of these comments. Sincerely, Erick Aune, AICP Planning Director 1060 E. 2ND AVE. 0 DURANGO, COLORADO • 81301