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WESTERN MINING ACTION PROTECT <br />Roger Flynn, Esq., <br />Jeffrey C. Parsons, Esq. <br />P.O. Box 349 <br />440 Main Street, Suite 2 <br />Lyons, CO 80540 <br />(303) 823 -5738 <br />Fax (303) 823 -5732 <br />wmap@a,igc.org <br />July 26, 2011 <br />Via email and hardcopy <br />G. Russell Means <br />Environmental Protection Specialist <br />Colorado Division of Reclamation Mining and Safety <br />Grand Junction Field Office <br />101 South 3rd, Suite 301 <br />Grand Junction, CO 81501 <br />Re: JD -8 Mine Environmental Protection Plan (EPP), AM -01, Permit No. M- 1984 -014 <br />06 u <br />Dear Mr. Means: <br />Please accept these comments submitted on behalf of Sheep Mountain Alliance regarding <br />Amendment AM -01 for the C -JD -8 Uranium Mine (JD -8), Permit No. M- 1984 -014. owned by the <br />Cotter Corporation and situated in Montrose County, Colorado. AM -01 encompasses the Cotter <br />Corporation's submittal of an Environmental Protection Plan (EPP) as required under the Colorado <br />Mined Land Reclamation Act (MLRA). <br />As detailed herein, the submittal of this EPP raises substantial issues regarding the Cotter <br />Corporation's compliance with the MLRA. First, AM -01 brings into question the propriety of any so- <br />called "intermittent status" designation for JD -8, given the length of time the mine has taken advantage <br />of the temporary cessation allowance in the MLRA. Further, through AM -01, Cotter appears to <br />propose that admittedly necessary environmental protection activities be delayed in implementation <br />until mine production begins at some unidentified future time. Lastly, the data presented in the EPP is <br />incomplete and in some places contradictory, particularly with respect to groundwater impacts arising <br />from the site. <br />Intermittent Status is Not Allowable for the C -JD -8 Mine <br />The application for AM -01 repeatedly represents that the JD -8 Mine is in "intermittent status" <br />and therefore somehow not subject to the full application of the MLRA. However, there is no <br />reference to any "intermittent status" in the MLRA, and the references to this status in the MLRB <br />Rules place strict requirements on any operation seeking such status — that notably have not been <br />complied with by the Cotter Corporation — and in any case, the MLRA specifically mandates that in no <br />case may a mine be left in a nonproducing state for longer than 10 years. Rather, it appears that <br />1 <br />RECEIVED <br />JUL 2 6 2011 <br />GRAND JUNCTION FIELD OFFICE <br />DIVISION OF <br />RECLAMATION MINING & SAFETY <br />RECEN <br />AUG 042011 <br />Division of Reclamation, <br />Miming and Safety <br />