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ENFORCE22470
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ENFORCE22470
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Last modified
8/24/2016 7:32:13 PM
Creation date
11/21/2007 10:11:05 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981013
IBM Index Class Name
Enforcement
Doc Date
2/28/1994
Doc Name
FAX BASIN RESOURCES RATON WEST PN C-81-013 SUPPLEMENT COMMENTS CONCERNING PROPOSED DECISION & REQUES
From
KRASSA LINDHOLM KUMLI & MADSEN
To
DMG
Violation No.
TD1993020370005TV3
Media Type
D
Archive
No
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M. Long <br />February 25, 1994 <br />Page 2 <br />2. Our preliminary examination of the surface ownership <br />inventory submitted by Basin has revealed that there may <br />be some misidentified ownerships. The identification of <br />such owners should be corrected. <br />3. As of Raton West's last examination of the Division's <br />files prior to February'18, 1994, not all of the required <br />materials had been'submitted by Basin. Raton West has <br />therefore not had time to adequately review the structure <br />inventory and map submitted by Basin and so reserves the <br />right to raise these issues at the hearing. <br />4. The pre-mining land use map submitted by Basin includes <br />the ranchette zoned area of the Rancho Escondido surface. <br />However, the post-mining land use map only shows Basin's <br />surface activities area, which is smaller in extent. The <br />post-mining land use map needs to be enlarged to include <br />Rancho Escondido. Surface development in this area has <br />been occurring at an accelerating pace, and the nature of <br />land use has been changing rapidly. Therefore, it is <br />crucial that materials depicting such information be <br />updated on a regular basis. Accurate representation of <br />post-mining use is especially important, as such use will <br />continue long after any underlying coal may be extracted. <br />5. Stipulation 67: The Division's. determination that <br />'"impacts to the:.overail.hydrologic regime and associated <br />natural resources are not anticipated" is premature, and <br />the language of this Stipulation should be accordingly <br />modified. Until all required hydrologic studies are <br />completed, it is not possible to accurately assess the <br />impacts of Basin's activities on the local hydrology. <br />6. It is Raton West's understanding that Basin plans to <br />conduct exploratory drilling activities in the vicinity <br />of Rancho Escondido. We hereby supplement comment 5. of <br />our February 22, 1994 letter by proposing that some of <br />these exploratory holes be utilized as hydrologic <br />monitoring wells. <br />7. Raton West reasserts its concern, addressed in previous <br />communications with the Division, that some of the maps <br />submitted by Basin do not consistently indicate the <br />position of section corners. Such discrepancies should <br />be addressed in order to facilitate the examination and <br />correlation of the various maps provided to the Division <br />by Basin. <br />/Cinssa, IiidhaGn, Rumli & Madsrn <br />
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