You are correct there are a lot of other things to keep in mind. If CGI acquires the property for the purpose of supporting the mining (milling) operation, CGI will have to Amend their permit to incorporate the affected lands into the Reclamation Plan. They will also be required to comply with any requirements of San Juan County, and, depending on the location, may also be involved with US Army Corps of Engineers, Colorado Department of Public Health and Environment, BLM and/or USFS. To the best of my knowledge CGI has only discussed the concept of dry stack with DRMS, but no specific details.
The Truth is out there all you have to do is look for it