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PERMFILE47013
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PERMFILE47013
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Entry Properties
Last modified
8/24/2016 10:49:05 PM
Creation date
11/20/2007 1:00:21 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2006073
IBM Index Class Name
Permit File
Doc Date
4/4/2007
Doc Name
Adequacy Response 2
From
Banks and Gesso, LLC
To
DRMS
Media Type
D
Archive
No
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Sundance Resource, M-2006-073 <br />Second Adequacy Response <br />April 3, 2007 <br />Page 2 <br />original map and legend provide an accurate statement of the status of the well. <br />The well is properly abandoned, a fact reconfirmed in the process of preparing <br />this adequacy response. <br />For the Division's information, the cited General Note language is a generic note <br />applicable to a broad range of situations. Under unusual circumstances, the <br />COGCC database may not be accurate or current, and occasionally wells are <br />abandoned without proper records filed with the COGCC. Under these <br />circumstances, control of the structure reverts to the land owner by operation of <br />law. That analysis is not necessary in the present case, as the noted well was <br />properly abandoned and control has been relinquished in accordance with <br />COGCC regulatory procedures. <br />Rule 6.4.5 - Exhibit E (1.) <br />Rule 6.4.5(2)(a) requires a discussion of why the proposed type of reclamation <br />plan was chosen. Lafarge with the landowner have decided to change the <br />reclamation type from rangeland and developed water to agriculture and <br />developed water. The Division should disregard previous references to <br />rangeland. <br />For the record, the availability of irrigation water, as noted in the Division's <br />comment, is the primary difference between rangeland and agriculture. The <br />Division is correct to note that the existing use of the land includes irrigated <br />crops; however, these crops are primarily feed for a cattle operation also housed <br />on the site. The Division's determination of the appropriateness of rangeland <br />versus agriculture would serve no other purpose than to dictate the intensity <br />(e.g., head of cattle) of a livestock operation, not the use itself, not the <br />environmental suitability of the use, and not the economic viability of the <br />operation. The Division's review of this land use decision is also, in essence, an <br />attempt to regulate the beneficial uses of water, in potential competition with the <br />intent of providing for developed water on the site. While the applicant will <br />stipulate to agricultural uses at this time for permitting and bond purposes, a wide <br />range of options for agricultural use, including dryland planting and grazing <br />consistent with rangeland, are all viable post-mining scenarios for the site. <br />Rule 6.4.5 - Exhibit E (2.) <br />Rules 6.4.5(2)(d) and (2)(f)(v) require a plan for topsoil segregation, preservation, <br />and replacement depths. Lafarge commits to re-using all topsoil removed and <br />stockpiled so that no topsoil stockpiles remain on site upon final reclamation. <br />Due to significant acreage dedicated to water storage, not needing topsoil <br />application for reclamation, this topsoiling plan will result in post-mining topsoil <br />depths exceeding pre-mining depths in planted areas of the reclaimed site. <br />
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