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t~~~ ~~~~~~~~~~~~ ~~~~~~~~~~ ~ ~~~~~~~~~ <br />1409 larimzr square dznvzr, Colorado 80202 000-571-1000 <br />October 28, 1977 <br />Chairman <br />Colorado dined Land Reclamation Board <br />1313 Sherman Street <br />Denver, CO 80202 _ <br />RE:~ Interpretation of Rules and Regulations for Limited Impact <br />Mining Operations. <br />Gentlemen: <br />In recent pre-hearing negotiations e7ith staff Reclamation Specialists <br />it has come to my attention that one interpretation of the <br />definition of affected land for limited impact operations could <br />have severe effects on the ecology and on the economics of mining <br />for small operations. The ruling in question is that use of previously <br />disturbed areas for stockpiling, spare equipment, parking or haul roads <br />would require that those previously disturbed areas containing no <br />commercial mineral be included in the less than 10 acre figure for <br />the mine. If this definition prevails it would be imprudent for <br />small mining operations to stockpile or store equipment in <br />previously disturbed areas since a greater a~.ount of product mineral <br />could be mined under the permit if the equipment storage and <br />stockpiling Caere done on virgin land to be mined in the future. <br />There are tcao consequences of the use of virgin land for stockpiles, <br />haul roads, and equipment storage. <br />1. The land is disturbed prior to its intended date for <br />mining causing a greater area of disturbance than would <br />otherwise be anticipated and, <br />2. Some land will possibly be disturbed that would not be <br />disturbed otherwise at all should the need for that <br />particular mineral at our clients operation be curtailed. <br />