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SENT BY~Administration Office ~ 4-12-93 ~ 9:31 <br />Y • <br />c <br />~~~~ <br />Yampa Yall~y <br />oak <br />April 9, 1993 <br />Kent Gorham <br />Reclamation Specialist <br />Division of Minerals and Geology <br />1313 Sherman street, Room 215 <br />Denver, Coloraflo 80203 <br />RE: Permit Revision No.3 <br />Permit Number C-B1-071 <br />Dear Mr. Gorham: <br />Company (CYCC) provides the following as specific <br />company disagrees with the Division's denial <br />referenced permit revision. It is still request <br />matter be heard at the May, 1993 Hoard meeting. <br />In response to your call oP April 9, 1993 <br />The first criterion the Division based its deei <br />definition oP "Land Vse". By application of this <br />CYCC's proposal the Division determined that rang <br />defined by the proposed land mnnagement practices. <br />the proposed land managsmant practices fir the <br />"Pastureland" and not "Rangeland". I believe the c <br />over the fact that CYCC mny not have to utilized <br />such Ae seeding and fertilization during the <br />liability period due to the superior condition o: <br />lands. At such time as these inputs, as determined <br />vegetation monitoring during the bond release <br />appropriate cultural input will be utilized to maint <br />production. It appears CYCC is being penalized fo <br />reclamation work completed at the mine, and due to <br />arises of Pitting the reclaimed mine site into the c <br />definition. <br />re to <br />and a <br />to be developed, and not on determining land use <br />boundary. These agencies have the ability to x <br />and provide advice to the Division on the <br />mitigation plan to prevent adverse impacts. At <br />not been provided with the data the agencies ut <br />adverse impaCC will result trom the proposed c2a <br />CYCC is requesting that the data used by the agc <br />to the company so that a reasonable attempt <br />that the state and federal wildlife agancd.ea a <br />there is a proven adverse impact to wildlife <br />in referanee to the second criterion, the Divi <br />decision on the ability of the Division of Wildlife <br />use planning elements of a reclamation plan. It ii <br />CYPRUS YAMPA VALLEY y <br />~_..f . <br />wi <br />303 632 6106 # 2 <br />pa Valley Cod Corpora110n <br />t County Road #27 <br />cabredo eoas~ <br />:. <br />ido Yampa Coal <br />eaeons why the <br />of the above <br />l at that this <br />,ion on is the <br />definition to <br />land ie better <br />CYCC believes <br />definition of <br />mfueion arises <br />:ultural inputs <br />ten year bond <br />the reclaimed <br />by the ongoing <br />period, they <br />iin pastureland <br />the excellent <br />this a problem <br />~rrect land use <br />ion based its <br />:o approve land <br />CYCC's opinion <br />~e consulted if <br />mitigation has <br />hin the permit <br />ew and comment <br />~quacy of the <br />~ time CYCC ha^ <br />axed to show an <br />a in land use: <br />es be supplied <br />n be made at <br />