2008-06-18_REVISION - M1980244 (7)

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WESTERN MINING ACTION PROJECT Roger Flvnn, Esq., Jeffrey C. Parsons, Esq. P.O. Box 349 440 Main Street, Suite 2 Lyons, CO 80540 (303) 823 -5738 Fax (303) 823 -5732 wmap(aJgc.ort p JUN 18 2008 f)1V'5'u:a - , �uci,senation, Mining and Safety Via Facsimile (303- 832 - 8106), email ( berhan .keffelew(it %state.co.us), and hard copy via U.S. Mail first class June 17, 2008 Mr. Berhan Keffelew Division of Reclamation Mining and Safety 1313 Sherman St., Room 215 Denver, CO 80203 RE: Comments on CC &V Amendment 9 application (Permit # M -1980 -244) Thank you for the opportunity to present these comments to the Division of Reclamation Mining and Safety ( "DRMS ") on the application submitted by Cripple Creek & Victor Gold Mining Company ( "CC &V ") for a revision to the existing Mined Land Reclamation Permit M- 1980 -244 for the Cresson Project. These comments are submitted, through the undersigned, by Citizens for Victor, Rocky Mountain Chapter of the Sierra Club, and INFORM (collectively "commenters "). The undersigned commenters regret the short amount of time available to review and comment on this complex and technically detailed proposal. In fact, the documents were not scanned in and made available to the public in any electronic form until after May 23, 2008, a full month after the same was received by the Division. While commenters appreciate the fact that physical hard copies of the multi- thousand page application were available in Teller County and at the DRMS office in Denver, the lack of any timely electronic copy, particularly in this digital business age, has greatly handicapped and in a large respect deprived the ability of the public to effectively understand and comment on this application. In light of this circumstance, commenters request that the DRMS accept future comments on this application as an understanding of the proposal develops. To this end, commenters would welcome any opportunity to meet with the Division staff and /or CC &V representatives, in combination or independently, to review the technical aspects of the application to better understand the proposal and hopefully to alleviate concerns raised in this comment letter. Regardless, bulleted below are concerns commenters have identified with the proposed application. • The application does not demonstrate that the current or proposed point(s) of compliance for purposes of compliance with groundwater quality standards is protective of public health or the environment.