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.~ <br />v, :.< <br />~I~ I~~~I~II~~~~~ ~I~ <br />5731 State Highway 13 <br />Meeker, Colorado 81641 <br />(303) 824-4451 <br />Ms. Janet Binns <br />Reclamation Specialist <br />Colorado Division of Minerals and Geology <br />215 Centennial Building <br />1313 Sherman Street <br />Denver, Colorado 80203 <br />RE: NOV C-93-072 <br />Permit C-81-019 <br />Colowyo Coal Company <br />Colowyo Response to July e, 1993 <br />Civil Penalty Assessments <br />Dear Ms. Binns: <br />August 13, 1993 <br />~Ft;F!VFC? <br />AUG 17 1993 <br />DNISiprl U1 tiIIIi BlB~S U ubJi~yg <br />Attached for the Division's consideration is a written <br />response to the Proposed Civil Assessment for NOV C-93-072. These <br />comments also provide additional comment with respect to that <br />portion of the Division's memo of June 1, 1993 addressing NOV C-93- <br />072. <br />Comments regardin4 the June 1, 1993 DMG memo. <br />In general, we believe this memo contains a number of <br />factual errors and misrepresentations which ultimately adversely <br />influenced the Penalty Assessment. The following comments are <br />respectfully submitted to correct the record from Colowyo's <br />perspective and to clarify a number of important issues. <br />"Background" <br />Placement of topsoil in windrow stockpiles below and away <br />from mining areas is not a new or unique practice at Colowyo. It <br />has been routinely used effectively elsewhere at the Colowyo <br />minesite. All topsoil stockpiles at Colowyo are graded, seeded and <br />otherwise protected from wind and water erosion. The Division's <br />implication that these particular stockpiles were a novelty and <br />thus received substantially more attention and discussion is an <br />overstatement, Colowyo never had intentions that these stockpiles <br />were to be handled differently than all other stockpiles. <br />