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RPR.24 '98 10~12RM ~GJCT 1~ 2410336 ~ P.3 ;alternative land use, along with a schedule for implementation. The map should dclincatc existing and proposed industrial or commercial, residential, and developtd recreation (gulf course, etc.) sites widtin and immediately adjacent to the permit arcs, as well as remaining wildlife habitat and cropland, and any' proposed buffer zones or gncn belts associated with the alterna[ive land use developments. The map should depict both permit and disturbed area boundaries. 2. "I'hc application narr¢tivc addresses the spccitic rcquinments of Rule 4.16.3(1)-(6) separately, nn pages .5-29 thrnueh 5-31. I have tha: following comments: (1) The ¢pplication states that the proposed alternative uses aze compatible with La Plata County plamning designations. Doctrmcnta[ion from the county should he provided. (2) The rule states th¢t the Division may require appropriate demonstrations to show that the planned procedures are feasible, reason¢ble, tout integrated with mining and reclamation. As noted in Item 1, above, specific plans and schedule for proposed dcvclopmcnt of sltcrnativc land uses on the reclaimed aeeas have not been provided, and such plans arc needed in order for the Division to evaluate whether the proposal is feasible, rc¢sonablc, and integrated with mining and reclamation. Permit application natmtivc states that "stu:ccssful reclamation will he accomplished on disturbed areas within the permit azca boundary which would not be of use in the dcvclopmcnt, construction, nr operation of the planned and ¢pproved land uses." Depending on the location and extent of such areas, desigitatinn as "wildlife h¢hitat" pnstmining land use, with spccitic reclamation ~ plans and rcvcgctation success standards applicable to that land use might be appropriate. The operator should provide appmpriatc narrative and map information to describe and dclincatc "developed" and "undeveloped" areas on the postmine surface. Justification for inclusion of any "undeveloped" areas within designated altcmativc land use sites, as opposed to separately designating such sites as "wildlilc habitat" postminc lattd toe should also be provided. (4) "Phis Wile requires that the alternative use(s) not involve unreasonable delays in reclamation. 'I'hc ¢pplication text states that, because the "uses have already been implemented, there would he no delay in reclamation of the mine site attributable to implementation of the pnstmining land uses." My undcrslanding is that, with the exception of the grivel mining area. the altcm¢tivc land uses have not yet been implemented un existing and proposed coal mine disturbance areas. Flow could it be claimed that residential dcvclopmcnt, golf course development, or equestrian facilities h¢ve been implcmcntcd if the lands in question are either unreclaimed mine pit, fill, or associated facilities, or designated for future coal mining disturbance? The rule does not define "unreasonable delay in reclamation", however Rulc 4.15.1Q(2) is pertinent to this issue. w