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site wells have indicated exceedences of groundwater standards. The connections between the JD -8 <br />site and the mill site groundwater contamination should be much more rigorously explored to satisfy <br />the MLRA and Rules. In addition, Cotter's Drainage Plan admits that some portions of the stormwater <br />management system are not designed to meet DRMS standards with regard to a 100yr /24hour event. <br />All such components should be upgraded to meet all standards. <br />Given these inconsistencies and questions, more detail is necessary for Cotter to provide the <br />required detailed information on groundwater pathways that may contribute to the groundwater <br />contamination evident at the mill site, located just below to the northwest from JD -8. This additional <br />information is consistent with the Rules, which require 5 quarters of data showing water quality and <br />quantity among other detailed information. See e.g. Rule 6.4.21(8), (9), (11), (12) and (14). <br />Cultural Resource Assessments Are Not Complete <br />Given the reported high number of historic and prehistoric cultural, archaeological, and <br />paleontological resources in the area, the Division should coordinate with the Colorado SHPO to <br />ensure that Cotter has appropriately inventoried, identified, and mitigated impacts to, all historic <br />resources at the site. <br />Abandoned Mine Features in the Area Should be Considered for Reclamation <br />Cotter notes that the abandoned Black Diamond Mine is in the vicinity of JD -8. Area maps <br />indicate other historic mines in the area as well. As part of any EPP, the Division should explore with <br />Cotter the potential for reclamation work to be accomplished on these abandoned mines to improve <br />and mitigate the wildlife, water quality, and other impacts in the area. <br />Sheep Mountain Alliance looks forward to working with you on this EPP application. <br />Sincerely, <br />/s /Jeffrey C. Parsons <br />Jeffrey C. Parsons <br />Western Mining Action Project <br />on behalf of Sheep Mountain Alliance <br />cc: Jeff Fugate, AGO, via email <br />Tony Waldron, DRMS, via email <br />Loretta Pineda, DRMS, via email <br />5 <br />