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Mr. Steve Renner <br />September 4, 1991 <br />Page 2 <br />4. It seems that the primary intent of Phase II is to control erosion. However, with the 1987 reclaim <br />area at Canadian Strip, eventhough this demonstration was successful and the Division approved <br />reclamation of sedimentation control structures, Phase II could not be granted because of the 90/90 <br />statistical revegetative cover requirement. This seems to be impractical to utilize a vegetative cover <br />standard in the SedCad modeling and a second set of cover criteria for Phase II which is also utilized <br />in the Phase III standards. The 90/90 cover standard for Phase II seems [o be redundant. Because <br />Phaze II haz not been granted, another field analyses for revegetation cover will need to be conducted <br />and another application will need to be submitted to achieve Phase II. This represents a significant <br />cost to the operator to conduct these activities and significant tracking of these various stages of <br />liability release by the operator and the Division. <br />5. In terms of bonding, the Division haz ruled that no phase of bond will be released until all portions <br />of the requirements for that phase have been completed. In the case of Canadian Strip, the erosion <br />control requirements of Phase 11 have been met, the sediment control structures have been removed, <br />and still no bond release is granted for achieving these standards. Calculation of the remaining bond <br />is less than half of that which is being currently held. If the 90/90 vegetative cover requirement is <br />maintained for Phase II, than incremental bond release for reclamation activities accomplished should <br />be considered. Again, this is an unnecessary cost for the operator to have the site over-bonded. <br />Should you have questions or need additional information concerning this request for an adjudicatory <br />hearing, please do not hesitate to call Mr. Jerry Koblitz or let me know. <br />Sincerely, <br />~~.~~~ e~ <br />Lawren J. Corte <br />Attorney <br />Attachments <br />cr Jerry Koblitz - Greystone <br />