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REV13340
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REV13340
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Entry Properties
Last modified
8/25/2016 1:24:22 AM
Creation date
11/21/2007 10:41:10 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1980005
IBM Index Class Name
Revision
Doc Date
4/4/2006
Doc Name
1st Response to Adequacy Comments
From
Seneca Coal Company
To
DMG
Type & Sequence
TR40
Media Type
D
Archive
No
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Mr. Mike Boulay <br />Department ofMinem/r and Geology <br />Page 2 <br />description ofBRB-4 and 5 be e~rpandec~ to clarify that these blocks would be subject to <br />provisions ofthe Colorado Permanent Program. <br />Response: The text has been revised and updated. <br />3. We have several questions relating to the BBB delineations on Exhibit 13-13.1 <br />a) Then it an area of barren, eroded spoils within BRB-1, which apparently war affected by acid fornring spoil material <br />It it our understanding that the barren area will be excluded from the bond release block when the initial baud release <br />application is submitted, and that a plan for remedial reclamation will be pursued Please confum that out <br />understandingis correct. <br />Response: SCC has included this azea in the Phase I Bond Release application, since backfilling and grading <br />is complete. It has not been fully determined what version of the xclamation law applies to this azea. <br />Therefore a plan for potential "remedial reclamation" is still to be completed. Phase I is completed. The <br />remedial reclamation is a bier concern for Phase II evaluation. <br />b) Numerous Tree Plot areas an delineated on the Exhibit. Our assumption is that there areas an locations when <br />planned shrub ar the planting war conducted, and that there areas do not necessarily correspond to the ",shrub <br />concentration areas"or synonymous `high density shrub patches'; referenced rn subsequent sections of the appendix. <br />Please rnnfrrn or clarify as appropriate <br />Response: Your assumption is correct, <br />c) Directly youth of Parzrl 99-1 f, in BI~B11, then it a reclaimed parcel that includes a large Tne Plot area. The passel <br />doer not appear to have slate/number designation. Alra, then it a parcel in BRB4, at the extreme southern end of <br />the reclamation, that is designated 86-4e. If the parcel were reclaimed in 1986, it would logically be included in BRB- <br />3. Please address and correct these apparent discrepancies as appropriate. <br />Response: An updated map is attached. <br />4. The Logical Land Management Units (I.I MU'r) as described in the appendix and delineated on Exhibit 13-13.2 <br />compare individually fenced pastures. These units do not appear to correspond precisely with the Logital Land Management <br />Units terminology as described in the 1995 DMG Guidelines document. Under `Band $eleare Block Constraints'; on <br />page 14 of the Guidelines, a bond please black is described as agrouping of reclamation parcels that comprise or an <br />contained within a single hgical land management unit. This does not appear to be the care with respect to the BRB'r and <br />L.LMU'r as delineated on the map exhibiu in the appendix: For example, the B1~B-3 bond release block appears to <br />extend into 5 separate L.IMU's, ar defaned in the appendix (Cow Camp Pasture, Pecom Parton, IY/adge Pasture, Powder <br />House Pasture, and Thompson 440 Pasture). <br />It may be the case that multiplepastxres could be appropriatelygrouped into a single LT11fI7, based on the factors described <br />in Part 2 (pager 14 and 15) of the Guidelines. If so, the necessary amendment may be limited to mission of the narrative <br />under `2eigica! Iand Management Units'; on page 2 of the appendix, to describe and just the inclusion of multiple <br />designated pastures within a single I.LMU. If this it not the case, it may be necessary to further dtvide the proposed bond <br />release blocks, to create additional bond release blocky such that each BItB it mntained within a single L,IMU. <br />Please review the referenced Guideline sections and amend the appendix as necessary to <br />demonstrate that the Band Re%ase Block/Logicalland Management Unit framework of the <br />appendix is m acrnrdance with the Guideline. <br />
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