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lApioA <br />WESTERN MINING ACTION PROJECT <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 />wmapAigc.org <br />October 11, 2011 <br />David Bird <br />Division of Reclamation Mining and Safety <br />1313 Sherman St., Rm. 215 <br />Denver, CO 80203 <br />Re: London Butte Underground Exploration, NOI File No. t- 2011 -029 <br />Dear Mr. Bird: <br />RECEIVED <br />OCT 132011 <br />0Gkpp[ ,, `rlats: D1 v I Mo i f s lamation, <br />WildEarth Guardians a d Information Network for Responsible Mining (INFORM) write to <br />provide the Division of Remation Mining and Safety (the Division or DRMS) with timely <br />information and comments regarding the Notice of Intent to Conduct Prospecting (NOI) for the <br />London Butte Underground Exploration project filed September 26, 2011 by Eagle Minerals, LLC of <br />Phoenix, Arizona and Alma Placer Company of Sheridan, Colorado. As detailed below, the NOI <br />application contains inadequate information about the proposed activities, especially regarding impacts <br />to the environment. This lack of information is particularly problematic with respect to the anticipated <br />water quality impacts. Indeed, as described below, the record indicates that the proposed point source <br />water discharge facilities relied upon and proposed for use in the NOI have been in regular violation of <br />permitted water quality standards and limits. None of this information is evident from the NOI <br />application. In order to meet the requirements of the Colorado Mined Land Reclamation Act (MLRA) <br />and Division regulations, substantial additional information, and likely mitigation action with requisite <br />bonding, is required prior to any approvals. <br />The NOI proposes dewater and rehabilitate existing underground mine adits and shafts in an <br />effort to explore for gold and silver. NOI at 3 -4. The NOI simply states that the amount of material <br />anticipated to extracted during the project is "2000.00 ", with no additional information. NOl at 3. <br />With respect to de- watering, the NOI only indicates that "4 pump test wells will be drilled from the <br />existing pad to define the necessary draw down pumping rate." NOI at 4. Further, the NOI states that <br />"The adit of the London Butte will not require dewatering. Dewatering of the lower levels will be <br />under the existing water right and discharge permits;" and that "Existing stockpiles, ponds, and <br />discharge points will be utilized." NOI at 4. These brief statements appear to encompass the entirety <br />of the description of the project in the NOI application. <br />The MLRA requires that any notice of intent to conduct prospecting activities must "contain <br />the following :..:. (f) Measures to be taken to reclaim any affected land consistent with the requirements <br />of Section 34 -32 -116." C.R.S. § 34 -32 113(2). 'Section 34 -32 -116 specificallyrequires;that: <br />