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Comments and Response <br />To <br />CDMG Letter Dated March 15, 2002 <br />Comment: <br />The Division recognizes the advances made from the earlier drafts of proposed postmining <br />topoyraphy associated with Sections 4, 9, and the northwestern quarter of Section 16. However, <br />these areas appear to retain aspects still short of compliance with the rules. Areas proposed at <br />elevations below approximate original contour (such as the proposed West Pit Ditch and the <br />proposed topography of the NE'/. of Section 9) preclude, by definition, permanent excess spoil <br />fills at elevations above approximate original contour (such as the upper reaches of the West Pit <br />Fill). Please address the followiny gems in a refined version of the proposed postmining <br />topography in these areas. <br />Resaonse: <br />Discussions with Byron Walker on the above term of "approximate original contour" (AOC) <br />revealed that he was refemng to the pre-mining slope. This is an important distinction because <br />the AOC is what Colowyo is defining in their proposal. AOC has a broad and ambiguous <br />definition that deliberately uses terms like "closely resembles" and -general surface <br />configuration" in order to introduce flexibility in the design. In the rules the Backfilling and <br />Grading Section 4.14 also infers that the surface configuration can be above or below pre- <br />mising topography in the final design. Colowyo believes their proposal meets all the <br />requirements for AOC and Backfilling and Grading. <br />Colowyo has made revisions to the post-mining topography (PMT) to accommodate CDMG <br />suggestions. Again, in this submittal Colowyo has made revisions that take into account <br />constructive improvements from CDMG. Within the arena of -reasonable and practical " <br />Colowyo has compiled a final topography that meets both AOC and Backfilling and Grading <br />requirements. <br />Colowyo has reviewed the following information for this proposal in order to ensure compliance <br />with the AOC and Backflling and Grading requirements: <br />Volumetric Calculations For Meeting Th1ck Overburden Requirements <br />Pre and Post Mining Slope Aspect D1strlbution and Comparison <br />Pre and Post Mining Slope Distribution To Include The Following Statistical <br />Measurements: <br />Minimum Slope <br />Maximum Slope <br />Average Slope <br />Median Slope <br />Standard Deviation <br />Number of Datum <br />Spacing <br />Pre and Post Mining Average Elevations <br />Pre and Post-Mining Angle of Confluence for Drainages <br />Adjacent Landtorms In The Area <br />Geo-technical Stability <br />Other Natural Resource Perspectives for Enhancing the Overall Reclamation Plan <br />In conclusion the present design meets all requirements for AOC and Backfilling and Grading <br />CF4.1.2.7 TR56 <br />