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Response to DRMS Adequacy Review — Cotter JD -8 Mine Reclamation Plan Amendment <br />Cotter Corporation (N.S.L.) ( "Cotter ") submits this response ( "Response ") to the October 3, <br />2011 letter from Russell Means, Division of Reclamation, Mining and Safety ( "DRMS "), to <br />Glenn Williams, Cotter. The DRMS' comments are in italics and Cotter's responses are in bold. <br />The Response has three parts. The first part is Cotter's response to comments by Russell Means. <br />The second part is Cotter's response to the memorandum, entitled JD -8 Mine Drainage Design <br />Plan - General Stormwater Comments, Permit No. M- 1984 -014 / AM -01, from Tim Cazier (P.E. <br />DRMS) to Russ Means (DRMS), dated August 22, 2011 ( "Response to Tim Cazier <br />Memorandum "). The third part is Cotter's response to the technical memorandum, entitled <br />Review of Environmental Protection Plan for Cotter Corporation JD -8 Mine M- 1984 -014, from <br />David Bird (DRMS) to Russell Means (DRMS), dated August 29, 2011 ( "Response to David <br />Bird Memorandum "). <br />RESPONSE TO RUSSELL MEANS COMMENTS <br />On June 8, 2011 the Division of Reclamation, Mining, and Safety (Division) called Cotter <br />Corporation's (Cotter) submittal of an Environmental Protection Plan (EPP) amendment, AM- <br />Ol for the C-JD-8 Mine, Permit No. M -1984 -014, complete for review. The decision date is set <br />for November 7, 2011 provided all technical and administrative requirements are satisfied. An <br />applicant, at its discretion, can request an extension of the decision date to address issues <br />brought up during the review process. <br />On June 20, 2011 the Division received and forwarded comments from the Colorado Historical <br />Society. The Society noted five sites in the area were surveyed in the past. They recommended <br />resurvey of sites after ten years. The Division has requested Cotter respond to the Historical <br />Society and copy to Division staff. <br />Cotter response: A cultural survey was conducted for Cotter in October 2011 by <br />ERO Resources Corporation of Durango, Colorado. Due to the confidential nature <br />of cultural surveys, the report is being provided to the Historical Society. <br />On July 26, 2011 the Division received comments of objection from Sheep Mountain Alliance. <br />The Division forwarded those comments to Cotter so Cotter can develop a response to the issues <br />raised. <br />Cotter response: Cotter has responded to the comments by the Sheep Mountain <br />Affiance in Attachment 1. <br />On August 3, 2011 the Division received a letter from the Department of Energy (DOE). The <br />DOE indicated the EPP and amendment addressed surface operations on patented lands and not <br />on the C-JD-8 DOE Lease Tract, therefore, they had no comments. <br />The Division has begun review of the EPP amendment. A multi - disciplinary team of <br />Environmental Protection Specialists have reviewed the application. This document consists of <br />all staff comments in respect to the application as a whole. As much as possible, the comments <br />are combined and referenced to applicable review memos (attached). However, it is Cotter's <br />responsibility to address all issues raised by the team. Please submit all responses and questions <br />Page 4 <br />