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<br /> <br />Mr. Jim Dillie <br />Mr. Bob Oswald <br />August 2, 1994 <br />Page 2 <br />the Committee whole heartedly endorses the mining and reclamation <br />concepts described in the proposed Amendments. <br />Castle describes, in both of the Amendments, the efforts of <br />the community and the Committee to develop with Castle plans for <br />enhanced reclamation at the two quarries. These efforts resulted <br />in the plans for eniiancea reclarr~~ition that are included in the <br />proposed Amendments. The MRAC/Castle negotiations were premised <br />on the existing mining plans. One of the Committee's <br />frustrations was that the mining plans were designed only to <br />maximize recovery of aggregate, with little regard to reclamation <br />or the visual impact of mining operations. The Committee was <br />also frustrated with the base reclamation plans that had been <br />adopted in the original permits (1977) and which did not reflect <br />contemporary expectations of the community. Given those <br />constraints, MRAC and Castle developed plans for enhanced <br />reclamation which were intended to take off where the base <br />reclamation plan ended. The enhanced plans were necessarily <br />• premised on the projected topography and the base reclamation <br />requirements. <br />The Amendments now proposed by Castle alter the mining plan <br />and will leave a topography that is different from that on which <br />the enhanced reclamation plans are premised. Therefore, given <br />the proposed mining plans, the enhanced reclamation plans make <br />little sense except to outline the type and intensity of <br />revegetation and the rock staining that needs to be implemented. <br />The Division needs to understand that the so-called enhanced <br />reclamation plans are merely proposals that have not been funded. <br />There are no guarantees that anv of the enhanced reclamation will <br />be implemented. Castle quite appropriately acknowledges this <br />fact in its Amendments. Therefore, it is essential that the <br />Division evaluate the base line reclamation proposed by Castle <br />with the understanding that Castle will be required to implement <br />only the base reclamation and that the bond will cover only this <br />level of reclamation. The Division must be satisfied that the <br />proposed base reclamation meets the minimum requirements of state <br />law. <br />DC[\94999\98610.1 <br />