2011-09-29_GENERAL DOCUMENTS - M1977285

• Permit No: M1977285
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Date: 9/29/2011
• Doc Name: Public Comments
• From: Energy Minerals Law Center
• To: DRMS
• Email Name: RCO
• Media Type: D
• Archive: No

Via email and hardcopy
Dear Mr. Oswald,
Energy Minerals Law Center
a nonprofit law firm serving communities impacted by energy mining
1911 Main Avenue, Suite 238, Durango, Colorado 81301
Phone: [phone] Fax: [phone]
Email: emlc @frontier.net
-
Bob Oswald
Colorado Division of Reclamation Mining and Safety
Durango Office
691 CR 233, Suite A -2
Durango, CO 81301
Bob.Oswald @state.co.us
OCT 04 2011
Division of Reclamation,
Mining and Safety
September 27, 2011
RECEIVED
SEP 2 9 2011
Durango Field Office
C l ion of Reclamation,
Twining and Safety
Re: Public Comment Sunday Mine Complex 112d Designated Reclamation
Permit/Environmental Protection Plan for Sunday Mine,
SsJAdaY
�M- j77-2-
These public comments address the Reclamation Permits and Environmental Protection Plans
( "EPP ") for the Denison Sunday Mine Complex in general and the 112d Designated Mining
Operation/Environmental Protection Plan Permits at Denison's Sunday Mine, # M -1977 -285;
Topaz Mine, # M -1980- 055 -HR; and West Sunday Mine, # M- 1981 -021. These comments are
submitted on behalf of Sheep Mountain Alliance and Center for Biological Diversity and
INFORM.
These comments update, incorporate, and reassert the issues raised in attached comments
provided on August 29, 2011 and August 6, 2009, regarding the Sunday Mine Complex. As in
2009, the main areas of concern are water quality issues. The Sunday Mine Complex is
proximate to the Dolores River in the Big Gypsum Valley. Both ground and surface water from
the Denison mine sites involve the Dolores River Watershed, which is home to threatened and
endangered species and provides a prime area for recreation involving direct human contact.
Currently, the Sunday Mine complex is the subject of an ongoing baseline characterization and
monitoring program mandated by the U.S. Bureau of Land Management (BLM) as part of its
obligations under the National Environmental Policy Act (NEPA). As detailed in the record file,
these baseline and monitoring plans focus on water impacts. Due to the fact that such relevant
and fundamental information related to water quality, quantity, and hydrologic balance impacts
may come out of those baseline and monitoring program, commenters reserve the right to update
these comments as appropriate.
As detailed in the attached comments, the BLM NEPA study will provide a significant amount of
relevant information and data upon which the DRMS should also conduct its review. These
mines are also within the scope of study of the ongoing Programmatic Environmental Impact
Statement and Endangered Species Act consultation being carried out by the Department of