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application mentions that an additional ventilation bore -hole may be necessary in the area of the <br />"Better Be" mine, but no such impact is displayed on the reclamation maps nor the affected land maps <br />(including additional roadways and other ground disturbances necessary). Lastly, no characterization <br />of the ore or waste rock for the "Better Be" mine is provided. Should the applicant connect to the <br />"Better Be" inactive mine, it should also be responsible for any surface reclamation that might be <br />necessary for that property. That is to say, the applicant should be afforded the benefit of access to the <br />ore without the commensurate requirement to conduct any necessary reclamation. <br />Overall, it appears that a significant amount of additional information and detail is needed to <br />determine the baseline conditions, the impacts, and the reclamation needs associated with access to the <br />"Better Be" mine. <br />Additional Issues <br />While the above issues demonstrate that the mine permit application is lacking in some <br />substantial respects, the following list of issues have also arisen during the course of our review that <br />require attention by the applicant in order to establish a complete application warranting detailed <br />DRMS review. Given the above issues, commenters reserve the right to update and supplement these <br />comments as warranted. <br />1) The application (DRMS Application Form, p. 3) lists only "rangeland" as the primary present and <br />post- mining land use, neglecting to recognize "wildlife habitat" as a proposed present and post- mining <br />land use. This is despite assurances elsewhere in the application that the applicant will reclaim the site <br />for dray rangeland and wildlife habitat. Ex. D at p. 9 (section D(a)). The listing of only rangeland as a <br />site use is also contradicted by the Colorado DOW comment letter dated April 14, 2011, which <br />identifies the proposed mine area as "severe winter range for mule deer and elk. ... The effects on <br />these animals could be significant as new roads are established and habitat is destroyed." Given the <br />value of winter habitat, the application should at least recognize this important use, and more <br />importantly DRMS should consider restricting winter use of the mine site to protect these wildlife <br />values. Indeed, the application acknowledges that the mine has no plan for continuous activity (Ex. C <br />at p. 4). Given this lack of need for continuous activity, the DOW's suggestion for seasonal mining <br />closures makes great sense. In any case, reclamation should be designed to protect this important <br />wildlife habitat upon mine closure. <br />2) The applicant's statements of the likelihood of inactivity and intermittent production at the mine <br />raise issues regarding compliance with the MLRA's temporary cessation requirements. Should the <br />mine cease production and sale of ore for processing, compliance with the Act and Mined Land <br />Reclamation Board Rule 1.13 governing Temporary Cessation is necessary. This includes the <br />application process and other requirements and limits on Temporary Cessation status. <br />3) The application at Ex. C page 4 indicates that the mine site will have locked gates. Currently, <br />however, the site lacks gates. <br />4) The spur road leading to the mine (CR U16) is about 2.5 miles long. While portions are in good <br />condition, others are not. There are no signs of recent road surfacing. Given the potential for heavy <br />rains in the region — as occurred this year — erosion and water flow can be expected all along the <br />roadways all over the mesa. On the softer surface of U16, erosion is readily noticeable. Erosion, <br />rutting, road impacts and improvements should be addressed, as well as drainage issues for the mine <br />site overall. <br />4 <br />