REV15504

• Permit No: M1988044
• IBM Index Class Name: Revision
• Doc Date: 6/25/2002
• Doc Name: Responses to adequacy letter of April 26 2002
• From: Southwestern Ecological Services
• To: DMG
• Type & Sequence: AM2
• Media Type: D
• Archive: No

Southwestern`'
ECOIOgICdI
Services
37 East Colorado Avenue • Denver, Colorado 80210-3105 • (303)
June 24, 2002
Al Amundson
Division of Minerals and Geology
Vegetation Analysis
Wetland Ecology
Land Rehabilitation Planning
Photodocumentation
[phone]
RECEIVED
JUN 2 5 2002
Room 215 Division of Minerals and Geology
1313 Sherman Street
Denver, CO 80203
RE: Responses to adequacy letter of April 26, 2002. Coal Creek Resources amendment. 0~ ~~
Permit Number: M-1988-044 J
Dear Mr. Amundson:
Following are the responses to the questions in your adequacy letter for this amendment.
Item 1: Regarding Permitted Acreage - It is hard to tell exactly what the permitted acreage is at this
point. The original permit maps were based on the four USGS quad sheets that contain this area. The permit
area'is at the intersection of four maps. Errors have been found on one of those maps when compared to
•.coordinated, orthgraphic 'satellite photos, `but'the other' maps, seem to be very close to true; It is not known
how the~original:map' pi-eparers'resolved'the'errors of even if they were noticed. Furthermore, as discussed
~previously;~one section line is consideiablydifferent from where it should be. It appears that in scanning the
map to produce a computer tracing for insertion into AutoCad, the scanner may have accelerated during the
scan, thus stretching the map acid ct-eaiing one section line where it should be but the next section line to be
extended a greater distance than where it should have been. That map (the South Lowland area appears to
contain a progressive error that becomes larger from left to right which would indicate an accelerated scan.
Unfortunately, it is hard to tell for sure.
Considering all the difficulties and the fact that the permit is actually defined on the ground and by the
lease, rather than the maps, it is proposed that we simply agree that the number provided on the application
form be accepted. It seems to us that it is more important to have the area defined on the ground as the maps
are simply a representation. Fortunately, section corners in this area are well defined and located and that
forms the basis for the lease definition.
Item 2: Location quarter-quarter section - Although I agree that the "center" is more closely defined
by the NW t/a of the NW t/a of the Section 13, the application form asks for "The center of the area where
the majority of the mining will occur.° That is more difficuh to define because the permit is in two parts with
potemially three operations, any of which could be, potentially, the area where the "majority of the mining
will occur." However, because the majority of the mining has been done in the east upland, the south
lowland is nearly completed, and the west upland will probably not be operated, it seemed to us that the
NEt/n of the NEt/< better described the response to the statement on the form where "majority of mining','
seems to be functionally more important than "center." ~ -
Item 3: Mining Plan cut and fill'description . = I agree that, ac least in theory, this discussion should be, in
the reclamatiori'plan: However, iit preparing permits I generally do not include only.tnining,items in the
Mining*Plati* acid ohly'reclamation items in the Reclamation Plan. Because, plans are, not only for the benefit
of.the regulatory agency bu[ also the operafor, I prefer to include items from each plan iri the other plan.
This presents a more correct operational philosophy and approach to mining based on the idea that mining