HS,Thanks for your response. You said:"Without this permit there...

HS,

Thanks for your response.

You said:

"Without this permit there is no mine vintage. It really is that simple, it is one of the most critical requirements and a major pre-cursor to approval for an ISR mine to proceed"

HS, I totally agree. But all 4 required permits (all decided on by different agencies) are necessary for mining to commence. All are equally important.

But, of course, this one has great symbolic (as well as substantive) importance - as it will indicate that PEN management has the goods to negotiate the government regulatory systems. "One down...three to go" will inspire confidence.

On the matter of confirmation of the DDW Permit, you correctly quoted this from the WDEQ website:

"If a hearing is not warranted and no comments are received, the final permit will be issued at the end of the public comment period."

You then said:

"The above are not my words and they make it clear the "final permit will be issued".

That is technically correct, but the permit will be useless if it is not supported by the EPA's simultaneous issuance of the Aquifer Exemption.

In other words, without the aquifer exemption, there is no point in building the wells as nothing can be discharged from them.

This is all made clear in Chapter 13, Section 4 of the WDEQ Water Quality Division's Rules and Regulations. Extract below:

"Section 4. Control of Class I well subsurface discharges;
permit required; aquifer exemptions.

(a) Class I wells shall be allowed only pursuant to
the Wyoming Environmental Quality Act, Chapter VIII, Wyoming Water Quality Rules and Regulations, and this chapter.
(b) Discharges into or construction of Class I wells
are prohibited unless a permit has been obtained from the
Department of Environmental Quality through the Water Quality Division.
(c) Injections from Class I wells shall be restricted
to those receivers defined as Class VI groundwaters by the
department pursuant to Chapter VIII, Quality Standards for
Wyoming Groundwaters, Water Quality Rules and Regulations and receivers which have obtained an aquifer exemption pursuant to this section.
(e) The procedure for obtaining an aquifer exemption
from the U.S. Environmental Protection Agency shall be as
follows:
(i) Water Quality Division shall submit one complete copy of the application, the Draft Permit, and the public notice to the U.S. Environmental Protection Agency,
Region VIII. This submission shall be made so that EPA
receives the complete application at least twenty (20) days
prior to the scheduled start of the public comment period.
(ii)Within forty five (45) days of EPA receipt of a complete aquifer exemption request, EPA shall provide the department a written interim determination of intention to issue or deny the aquifer exemption pending receipt and review of the results of the public participation process conducted by the department. The interim response will become final if there are no comments relating to the aquifer exemption request during the comment or hearing process. If comments are received during the public comment or hearing process, the interim response will
become final if not modified by EPA in writing within thirty (30) days of receipt of all comments"

The EPA must declare its intentions by 24th March. So that will be a critical date.