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JG y Ct���� III I II'II'II'lll III <br /> t <br /> 999 <br /> WESTERN MINING ACTION PROJECT 3 <br /> 1405 Arapahoe Ave. <br /> Boulder, CO 80302 <br /> (303) 473-9618 1.99f� <br /> Fax (303) 440-8052 <br /> Division o1 t1^IfiNraiS 4 <br /> Via Fax - Hardcopy to Follow by Mail April 4, 1996 CJ 7 7 5 7 Y <br /> Vr. J. David Holm, Director <br /> Colorado Water Quality Control Division <br /> 4300 Cherry Creek Dr. South <br /> Denver, CO 80222 <br /> Re: /proposed Consent Decree and Draft Discharge Permits - Sunnyside Gold Corp. <br /> Dear Mr. Holm: <br /> The following are the comments of the Mineral Policy Center (MPC) by their <br /> undersigned attorney regarding the proposed Consent Decree and Order (CD or proposed CD) <br /> and associated draft and current discharge permits regarding the Sunnyside Gold Corporation. <br /> MPC is a nonprofit citizens organization that has been concerned with the water quality <br /> impacts associated with the Sunnyside mine. Due to the length and complexity of the <br /> documents, these comments are arranged by page number or paragraph number for quick <br /> reference. Thus, the comments are not listed in order of importance. <br /> Overall, the proposed CD and associated documents raise a number of serious <br /> concerns regarding the protection of water quality from active, inactive, and abandoned mines <br /> in Colorado. MPC respectfully requests that the state of Colorado reject the CD and <br /> associated permits until the following issues are resolved. <br /> Para. 3 - It is not clear that the CD and other documents are "consistent with the purposes of <br /> the [Water Quality] Act." CRS 25-8-102(2)(emphasis added) states that "the public policy of <br /> this state [is] to conserve state waters and to protect, maintain, and improve, where necessary <br /> and reasonable, the quality [of water] ...." At best, the CD attempts to "maintain" water <br /> quality, it makes no progress towards improving water quality in the Animas Basin. For <br /> example, the CD assumes that existing sites in the basin (the proposed "mitigation" sites) are <br /> fully complying with the Clean Water Act. In actuality, these sites are point sources (adits, <br /> tunnels, tailings and waste piles, etc.) that should have been issued traditional point source <br /> discharge permits long ago (i.e., since these discharges are not "stormwater" under EPA and <br /> state policy). <br /> 1 <br />