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III. COMMENTS-COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made during <br />the inspection. Comments also describe any enforcement actions taken during the inspection and the <br />facts or evidence supporting the enforcement action. <br />This partial inspection of the La Plata Coal Mine was conducted by DMG staff from the Durango Field <br />Office, 701 Camino del Rio, Room 125, Durango, CO 81301, phone (970) 247-5469. <br />The permit was revoked in 1989. The surety, Rocky Mountain Bank & Trust, became the successor <br />operator for the purposes of completing reclamation. Rocky Mountain Bank & Trust has attained <br />Phase I and II bond reduction and has requested Phase III release for completion of reclamation. The <br />inspection for the Phase III bond release occurred on June 4, 2004. In the report generated from the <br />June 4, 2004 inspection, DMG indicated that Rocky Mountain Bank & Trust appeared to have <br />completed reclamation with the exception of repair to an isolated gully located in the main drainage <br />channel within the permit area. This inspection focused on the recently completed gully repair. Three <br />photos accompany this report. <br />DMG records indicate that the gully resulted from an intense precipitation event occurring during late <br />summer of 1996. DMG records do not indicate that the gully feature has enlarged since that time. As <br />shown in Photo 1, the lower portions of the gully appear stable due to the rocky nature of the soils and <br />dense vegetative cover. Recent repairs to the gully appeared to have been concentrated further <br />upslope where soils were less rocky and potential for future erosion existed. <br />As shown in Photo 2, previous gully development in upslope areas had exposed a soil stabilizing <br />erosion control mat. Recent repairs to the gully at this location included backfill, rock placement and <br />vegetation transplants (Photo 3). All work appeared to have been done with hand tools. Rock fill <br />material had been hand picked from surrounding surface locations. Disturbance to the established <br />vegetative cover had been minimized. <br />