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III IIIIIIIIIIIII III ~ f`'`~° STATE OF COLORADO Roy Romer, Governor DEPARTMENT OF NATURAL RESOURCES MINED LAND RECLAMATION DIVISION FRED R. BANTA, Director DATE: May 17, 1988 T0: Mike Long FROM: Cathy Begej ~~~ RE: Bourg Permit Revision 1, Flatiron Coal Company I am attaching a copy of Flatiron's response to our February 24, 1988 adequacy letter, as well as that letter itself for your perusal. They basically are planning to retain their original proposed topography. They continue to ignore our request to characterize soil loss on a disturbed site. Preparation of Iqy written response in no way indicates accord with soil loss factors fora disturbed site. Furthermore, they contend that vegetation monitoring is adequate to monitor success of this site. I would like to tell them that the failure to provide a detailed hydrologic monitoring plan and a feasible alternative source of sediment control should the terraces prove ineffective will produce a denial of this PR. Lastly, I need some guidance from you on how far I should push the AOC issue. Pre~nining drainage density in the permit area was significantly greater than proposed. However, these terraces may adequately handle overland drainage. I had understood that Flatiron agreed to submit the parameters and assumptions which they would use in SEDIMOT. This response discussed the parameters used in their soil loss calculations but not those required for SEDIMOT. I expected to see the watershed imput parameters (hydrology, watershed, and sedimentology characteristics) as well as sediment basin imput parameters per the SEDIMOT Design manual. The intent of acquiring approval on these parameters would preclude the necessity of performing multiple (expensive) computer runs. 7392E CWB/scg 215 Centennial Building, 1313 Sherman Street Denver, Colorado 80203-2273 Tel. (303) 866.3567