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<br /> <br />Mr. Joe U. Carrillo - 2 - July 15, 1986 <br />general public good (e. g., reclaiming public lands and, in so doing, <br />contributing to public safety); 2} reclaim lands that would not otherwise be <br />required to be reclaimed under the provisions of the Mined Land Reclamation <br />Act (i. e., mining having been done prior to 1976); and 3) cost as much or more <br />~to reclaim than the total of your outstanding civil penalties to date (this <br />total can easily be calculated by you). If the Board approved this plan, you <br />should also request that the time period within which Las Animas County must <br />pay the various civil penalties be indefinitely continued until reclamation of <br />the approved site has occurred. Approval by the Board: of final reclamation of <br />the site will then be accepted in lieu of payment of your civil penalties. <br />The way that our Board now finally approves such alternate reclamation plans <br />is in the form of a reclamation-only permit. Las Animas County will need to <br />submit a permit application for any approved site having all the normal <br />exhibits and information, with the exception that there will be no mining <br />plan. I have enclosed one copy each of our new 110, limited impact and 112, <br />regular permit application forms for your use in this regard. Asa part of <br />this application, you should submit actual reclamation cost calculations <br />showing that the reclamation will cost enough to offset your civil penalties. <br />The 52,500.00 per acre cost you mentioned in your letter is not an accepted <br />reclamation cost figure. Rather, it is the statutory financial warranty <br />amount for 111, special permits. Actual cost calculations (e. g., using the <br />Cat Handbook, Rental Blue Book, etc. figures) must be submitted to us to <br />justify this plan. <br />The matter of preliminary Board acceptance of your plan must be accomplished <br />during the July 24-25, 1986 meeting. I suggest that you prepare your proposal <br />to the Board and contact either me or Karen Hellner to arrange its scheduling <br />before the Board as soon as possible. We will both be glad to assist you in <br />this matter. <br />Finally, as you are aware, the Board ordered Las Animas County to have a 110 <br />permit issued for the operation east of Aguilar by no later than <br />August 1, 1986 or a 112 permit issued by no later than September 5, 1986. To <br />my knowledge, no application has yet come in to us for this operation, and it <br />is now too late for such an application to be reviewed, published and be ready <br />for Board approval. You should, therefore, also be ready to request an <br />extension of this time period within which this permit is to be issued (and <br />justify your request). The Board must also approve such a request during the <br />July 24-25, 1986 meeting. <br />Sincerely, <br />Gam. - <br />Mark S. Loye <br />Senior Reclamation Specialist <br />MSL/ddt <br />Enclosure(s) <br />2238E <br />