Accurate? Not by a long shot! Your post describes the circumstances 180° from what it is in reality. You presented this in your original post:
That is not what this "Temporary Cessation" is about, nor is it in any stretch of the imagination close to what you presented in this last post.. "Temporary Cessation" is just what it says it is, a request or notification by the mining operation telling the state that there is an intent to stop work for more than 180 days and no longer than 5 years, with an option to extend that classification for an additional 5 years.
Here is what you failed to include: (omission in red)
The POW mill is a leaching operation, so this would apply in either case, permanent or temporary. CGFI has recently asked for guidance from the DRMS regarding these rules and what circumstances would put them into the "Temporary Cessation" category. (That document is on the DRMS web site. The DRMS site is non responsive today, so you will have to look for it later, but the DRMS's response is basically a repetition of this section, if my memory is accurate.) In respect to these rules, the "penalties" for non compliance do not exist unless the operation is deemed to be a TC first. Only then would penalties apply if the operator performs work on the site that exceeds those listed above. What you are claiming to be fact is absolutely wrong. Look on the DRMS web site as it becomes available. All those letters to Wallace Erickson, Environmental Compliance Specialist, from CGFI, were to insure that any work being conducted on the POW mill was within the scope of permitted tasks under the C&D order. Remember that letter with all those tasks listed and the word "proceed" repeated over and over?
Your words:
What "non compliance penalties" are you referring to? There have been none in relation to the "Temporary Cessation" classification. There can't be. CGFI has not been classified "TC". And what "fees are piling up" as you put it? You are making unsubstantiated claims.
CGFI has, by your own admission, paid all fees associated with the permit as it stands today. Your Post #45583, dated 5/7/12:
The reason for classifying an operation as "TC" is to insure that environmental precautions and abatement procedures are performed during the cessation period. Since, as you have pointed out so many times, no production is being done since 2008, how can there be any cessation of work?
Your stated logic is faulty. Your claims that the fees "keep piling up" are by your own post's content, wrong, or a gross exaggeration at best.
I submit that CGFI is investigating, with due diligence, what the removal of the C&D order's effect will have on its permit's standing, and what actions will be necessary to fulfill the requirements regarding a possible extended period before the mill is in operation. That is just a prudent thing to do.
I submit that your interpretation is just an erroneous opinion that has no valid research behind it. You have presented a "guess" with specious proof.
Don't take my word for it,Do your own research! Then you will know it's true!
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