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available in order to develop a more complete view of how the various hydrological impacts may <br />relate to each other. <br />The Revenue waste pile will be constructed in an active avalanche path, but there does <br />not appear to be a detailed geotcchnical analysis that examines the suitability of this location or <br />the ability of the waste pile to contain its material in the event that it is covered by a slide <br />(Exhibit D, page 12; Exhibit G, page 12; Exhibit T, page 13). During winter, waste will be <br />dumped on a temporary pile. Although Star Mines says it will conduct avalanche mitigation and <br />blasting to control the area, there is no specificity. Employees will not be allowed to access the <br />pile if conditions are unsafe, but this is not a requirement and there is no discussion about the <br />threshold of danger that will be acceptable. The applicant should be encouraged to develop a <br />more formal operations policy that strictly prohibits risking the safety of an employee in order to <br />dump rock on a pile. <br />The Revenue Mine is located above 10,000 feet altitude in a truly beloved and sensitive <br />alpine ecosystem. In consideration of this, the permitting of the mine should require mitigation of <br />as many of its impacts as possible, such as dust control measures, visual impacts, limiting <br />hauling conflicts with recreational traffic, maintaining landscaping, vegetation and weed control <br />efforts, and limiting the noise of trucks and equipment. The historic structures and the historic <br />mining characteristics of the Yankee Boy Basin area should be protected. Star Mine Operations <br />also plans to treat Ouray County Road 26 at times with magnesium chloride (Exh. T, p. 21), but <br />they should be required to find a more environmentally friendly alternative. <br />The post - mining use for the Revenue Mine site is wildlife habitat, and Star Mine <br />Operations notes that it will ultimately seal the portal with a bat gate. Eventual suitability of the <br />mine for use as bat habitat is commendable. As part of their operations, it would be ideal if the <br />company had a protocol for inspecting the mine for the presence of bats after periods of <br />inactivity or seasonal change before initiating new activity, and take precautions to preserve bat <br />habitat. <br />Thank you again for the opportunity to submit these comments. <br />Sincerely, <br />LLt 1 ` <br />Jennifer Thurston <br />Director <br />INFORM <br />