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Page two <br />Letter to Ms. Carol Pahlke <br />• and Mr. Tom Pike <br />Re: Kerr North Expansion <br />April 24, 1980 <br />appropriate baseline study design, applicable compliance ob- <br />ligations and other details relevant to the preparation of <br />the permit application for the Kerr North Expansion. <br />The first of these meetings was held on April 2, <br />1980, at the offices of the Mined Land Reclamation Division. <br />In attendance were Dean Massey, Carol Pahlke, Jerry 2impfer <br />and Roy Cox of the MLRD, Tom Pike of OSM, Rick Brown, Jeff <br />Saunders, Ken Crofts and Gary Myers of KCC, and Hubert Farbes <br />and myself from our office. <br />We will set forth below in sentence outline form <br />the matters which were discussed and conclusions reached at <br />this meeting. Please contact us immediately if you disagree <br />in any way with our restatement of these matters or with any <br />of KCC's proposals with respect to the permit application. <br />I. GENERAL MATTERS <br />A. Public Roads: The coal which is mined at KCC's <br />• mine is transported by truck approximately 8 miles from <br />the mine site along State Highway 14 to the Kerr tipple site <br />in Walden, Colorado. it is our understanding, based upon a <br />review of the applicable OSM permanent program regulations <br />together with discussions at this meeting, that this length <br />of public road is not subject to compliance obligations <br />under either the MLR or OSM regulatory schemes. This result <br />is predicated primarily on the fact that KCC has neither <br />ownership nor control with respect to the public road which <br />would allow it to implement compliance measures. <br />B. Permit Area and General Area Boundaries: This per- <br />mit application will encompass the existing Kerr Mine, and <br />the proposed expansion area and the tipple area located at <br />Walden, Colorado. The permit boundary for the mine area is <br />specifically delineated on that map entitled "Kerr Work <br />Map". This map also illustrates the boundary of the federal <br />coal lease which will be offered in May in response to KCC's <br />emergency lease application, The boundary areas for the <br />tipple site are outlined in the accompanying map entitled <br />"Kerr Tipple Drainage Control Plan". In addition, we have <br />included a map entitled "Kerr Coal Company General Area" <br />which delineates a "general area" with respect to the mine <br />site as that term is used in the applicable OSM Permanent <br />Program Regulations, particularly with regard to potential <br />hydrologic impacts. <br />r1 <br />U <br />