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~R~/ .: <br />~~ <br />YVCC <br /> <br />Yampa Valley Coal Corporation 129588 Routt County Road .x27, Oak Creek, CO 80467 • (3D3) 879-3800 <br />June 30, 1987 <br />Mr. Dan Mathews <br />Reclamation Specialist <br />Colorado Mined Land Reclamation Division <br />1313 Sherman Street, Room 423 <br />Denver, CO 80203-2273 <br />Dear Mr. Mathews: <br />RECEIVED <br />JUL 11987 <br />MINED LAND <br />RECLAMg710N DIVISION <br />Stabilization - Permit <br />I believe all the items, except for the comments and stipulation <br />contained in Mr. Jim Pendleton's memorandum of June 12, 1987 have been <br />resolved. The following will respond to his comments and the proposed <br />stipulation. <br />Per Jim's memorandum he continues to be concerned about the drainages <br />coming from the swale in Areas 9 and 10. After reviewing his memorandum, <br />CYCC still believes that the monitoring requirements specified in the Rill <br />and Gully Plan adequately addresses the identification and repair of areas <br />experiencing excessive erosion. Therefore, it is CYCC's opinion that this <br />stipulation is not required, and in a practical sense it does not provide <br />for additional protection of the drainage. The outcome is that the areas <br />that are eroded will be repaired excessively. <br />Another concern that CYCC has about the proposed stipulation is a lack <br />of specific deficiencies in CYCC's proposal that would cause the Division to <br />maintain a lingering concern over this topic. If specific reasons for the <br />concern could be provided, I'm confident that CYCC could provide an adequate <br />technical response. I or CYCC's consultant would be willing to meet with <br />the CMLRD to discuss relevant technical concerns about the permit revision. <br />From a practical point of view, the additional monitoring proposed will <br />not provide the information that the Division appears to be seeking. For <br />the monitoring to be valid, before and after surveys of the drainage would <br />be required. The information derived from the survey will not provide <br />additional information needed to reevaluate the drainage design. CYCC's <br />consultant advises that this would provide a topic for a thesis, but does <br />not provide any practical information that could be used by the mine in <br />channel design. <br />