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Varra Companies, Inc. <br /> OFFICE OF SPECIAL PROJECTS <br /> 8120 Ga2e Street Frederick,CO 80516 Telephone(303)666-6657 Fax(303)666-6743 <br /> It is our understanding that the selection should not restrict the <br /> establishment of developing the location in a manner that elevates <br /> the land to the highest level of Use attainable under its diverse <br /> parts. It would appear logical that if the entire permit area cannot <br /> be put into a basin that above ground portions will form an <br /> alternative, and hence, multiple, Use. To narrow the range of <br /> acceptable uses within the framework of acceptable reason and <br /> purpose is unnaturally constrained and at odds with the purposes of <br /> reclamation. <br /> The current understanding of the OMLR, appears to place the <br /> operator in a Catch 22, whereby the above ground portions of the <br /> permit will be at odds with the completed basin. If necessary, the <br /> applicant will provide a change in the Use requested by the OMLR <br /> to that of `Developed Water Resources,' with the understanding that <br /> all above water portions of the reclaimed permit area will revert to <br /> the existing Industrial/Commercial designations of Weld County, <br /> Colorado without impeding the diverse potential Use of the <br /> contained waters. <br /> From the 13 March 2011 Adequacy Reply: <br /> 1. The Applicant has stated a Technical Revision may be <br /> submitted to allow for the lining of the pits. As noted in the Division's <br /> previous Adequacy Review Letter, the Division considers lined pits to <br /> be a developed water resource, which would constitute a significant <br /> change from the proposed post-mining land use of <br /> industrial/commercial and would require an Amendment rather than a <br /> Technical Revision. The Division understands mine sites may be <br /> reclaimed to multiple land uses. However, if the Applicant does not <br /> identify `developed water resource' as one of the post-mining land <br /> uses, then the Applicant will be required to amend the Reclamation <br /> Permit should they decide to line the pits in the future. It is common <br /> practice to identify multiple post-mining land uses on the permit <br /> application. The Applicant should be familiar with this practice as <br /> they have identified multiple post-mining land uses on previously <br /> submitted permit applications (copy enclosed). The Applicant may <br /> revise page four of the permit application to include multiple post- <br /> mining land uses. <br /> Varra Companies, Inc. Western Sugar Land Development Project 6 <br /> OMLR Permit #: M-2010-049 Amendment 7 December 2015 <br />