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conceptual water treatability studies, currently there is no definitive water treatment <br />plant design nor is RGS permitted by the State of Colorado to discharge treated water <br />at this time. It will likely be several years before water treatment plant design and <br />construction is completed and the necessary permits (e.g., Colorado Discharge Permit <br />System permit) are in place. Until these approvals are obtained and facility designs are <br />completed, RGS does not have adequate knowledge of the water treatment process <br />and design to create an Environmental Protection Plan (EPP), even if DMO status is <br />somehow triggered by RGS's exploration activities. Any EPP for water treatment plant <br />facilities would need to await the future design and permitting of such plant. <br />3. Potential conditions at the mining operation, including the disposal of waste rock <br />and sub - economic mineralized materials and the exposure of ore at the surface, <br />may expose or disturb acid- or toxic - forming materials. <br />Ongoing and proposed exploration activities at the Bulldog do not include the <br />exposure or disposal of ore or sub - economic mineralized materials on the surface. <br />RGS' exploration plans, as approved and proposed in its application to the USFS, <br />include excavation of mineralized materials for the limited purpose of offsite testing. <br />Additionally, as discussed above, any waste rock brought to the surface during <br />exploration will not include acid- or toxic - forming materials. See Exhibit A, Preliminary <br />Bulldog Waste Rock Characterization Report. <br />If future activities at the Bulldog transition from the current exploration plans to <br />mine development, RGS will re -visit the issue of DMO status at that time with DRMS. <br />4. Mined ore will be processed at a milling facility at the site, which facility will utilize <br />acid or toxic chemicals. <br />5. The tailings resulting from the milling and extraction of metals potentially expose <br />or disturb acid- or toxic - forming materials. <br />The current and proposed exploration activities at the Bulldog do not include any <br />onsite milling or other ore processing. Until exploration shows the feasibility of a mining <br />operation, no EPP for ore processing (mining, milling or tailings emplacement) can be <br />developed. Any "potential" for these activities to occur at the Bulldog is entirely <br />speculative at this time, and cannot support a DMO designation. In the event future <br />mining and mineral processing operations are proposed at the Bulldog, the question of <br />DMO designation will be reevaluated in coordination with DRMS. <br />For the reasons described above, the Bulldog exploration project is not a "mining <br />operation," and does not meet the other criteria for triggering DMO status. Although the <br />Bulldog exploration project is not a DMO, and a formal EPP is not required, RGS is <br />