Dear Members of the Colorado Mined Land Reclamation Board,
The Information Network for Responsible Mining, Earthworks, San Juan Citizens Alliance and Sheep Mountain Alliance submit this combined objection to comprehensively address nine requests to extend temporary cessation status from the Cotter Corporation (Cotter). These organizations object to Cotter’s requests for temporary cessation for the following permits:
• SR-13A Mine, Permit No. M-1977-311 • SR-11 Mine, Permit No. M-1977-451 • Mineral Joe Claims, Permit No. M-1977-284 • C-LP-21 Mine, Permit No. M-1977-305 • JD-9 Mine, Permit No. M-1977-306 • CM-25 Mine, Permit No. M-1977-307 • JD-6 Mine, Permit No. M-1977-310 2 • SM-18 Mine, Permit No. M-1978-116 • JD-7 Pit, Permit No. M-1979-094-HR
With the exception of the Mineral Joe Claims, these operations are situated on public lands leased to Cotter Corporation through the U.S. Department of Energy (DOE) Uranium Leasing Program. For the purposes of clarity and simplicity, the multiple issues that collectively concern these mines and reasons to deny the permit-specific requests for temporary cessation are discussed together in this document. The staff and members of the objecting organizations are directly and adversely affected parties as defined by Rules 1.1(38.1) and 1.13.6 and take a direct interest in the operations and final reclamation of these mine sites.
The staff and members of these organizations regularly use and enjoy the public lands at and surrounding Cotter Corporation’s mines, including at Slick Rock, Bull Canyon, Monogram and Davis mesas, Long Park and Uravan, all within the Dolores-San Miguel watershed. We appreciate the opportunity to provide these comments and objections and request to participate as a party to the hearing requested by Cotter before the Mined Land Reclamation Board. As the party requesting the hearing, Cotter bears the full burden of proof to demonstrate that it is entitled to temporary cessation for each of the permits.