Thank you for the opportunity to comment on the proposed financial responsibility requirements under CERCLA 108(b) for classes of facilities in the Hardrock Mining Industry. These comments are submitted on behalf of the undersigned organizations and Earthworks, a national non-profit organization dedicated to protecting communities and the environment from the adverse effects of mineral and energy development, while seeking sustainable solutions.
The rule is based on a simple principle. If you make a mess; you clean it up. Strong financial assurance regulations are needed to protect the American taxpayer from the burden of clean-up costs associated with mining industry – the nation’s leading source of toxic pollution. With an estimated backlog of $20-54 billion for clean-up of hardrock mines, American taxpayers already face an enormous financial burden. Strong rules are necessary to shift the financial responsibility for cleanup to the industry, not the taxpayer, and to ensure timely cleanup to protect American citizens and the environment from the adverse effects of hazardous releases.
