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<br />Division of Minerals and Geology <br />Attn: Me. Kamnikar <br />September 26, 2000 <br />Page 6 <br />8. Concurrent Reclamation. Although implied in the application <br />and discussed in the Arapahoe County meeting of 6-26-00, need <br />language in Exhibits "C" (e.g., sheet 1/4, MINING, EXCAVATION <br />AND LAND LEVELING OPERATIONS, Section 4, ¶ 9), "D" and "E" <br />that concurrent reclamation will be employed and that mine <br />site will be regraded to historic contours. Limit the maximum <br />acreage requiring reclamation at any one time to 24 acres. <br />This would ensure concurrent reclamation and minimize topsoil <br />loss due to erosion, soil-moisture loss due to exposure, <br />topsoil degradation due to stockpiling and the costs of <br />stabilization (Rule 3.1.5(1), (2), (3) and (5), 3.1.6(3), <br />3.19(1) and (3) and 6.4.4(2)(e)). <br />Implement immediate soil stabilization measures for topsoil to <br />be stockpiled more than one growing season; e.g., plant with <br />perennial grass cover (Rule 3.1.9(3)). <br />9. Reclamation. Neither the Mining Plan Map nor the Reclamation <br />Plan Map of Exhibit "C" complies with the submittal <br />requirements as set forth in the Arapahoe County Zoning <br />Regulations, Section 602.03 (f), which mandates "Existing and <br />proposed finished grade topography at two foot (2') contours <br />or less, tied to a datum acceptable to the County" or in the <br />Colorado Mined Land Reclamation Board Construction Material <br />Rules and Regulations, Rule 6.4.3(c). Both maps are contoured <br />at 10' intervals. The 10-foot contour interval is too general <br />to reflect the detail needed to ensure that final grade and <br />reclamation are adequately addressed (Rules 6.4.5(2)(f) and <br />6.4.6). <br />The Reclamation Plan Map (Final Grade Map) of Exhibit "C" does <br />not reflect the historic drainage pattern. The closed <br />"lollipop" contour on the western portion of the map is <br />physically impossible and must be corrected, as must the <br />"floating" contour to the right of the "lollipop" (Rule <br />6.4.6). <br />For your assistance, a copy of the above-referenced June 30, 2000 <br />staff report prepared by Arapahoe County for the Board of County <br />