The Congress Mine is not under any regulatory order to do any reclamation. The only reason that Owens would pay anybody (a consultant, a water treatment company) to do anything with his worthless tailings piles is to lay the groundwork for a "story". It has been a decade since he was nailed for his USAR scam, so it is about time to start ripping off a new crop of investors.
The Determination of Applicability is often referred to as a "pre-application". It is not really part of the permit itself - it simply provides sufficient information to ADEQ so that they can say that a permit is needed, or not needed.
KJ's odd way of saying he has "permitted and completed a number of Determinations in Arizona" is very telling. You don't "permit" a determination. Not to mention that he and CDNL are not registered in Arizona with the AZBOTR or the ACC to legally provide professional consulting services. So, how has he done a "number" of anything here in Arizona.......???
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