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concerns expressed in his correspondence have several pos- sible consequences that cloud other issues regarding site expansion or closure, and which may trigger regulatory re- sponses on the part of the CMLRD and Dept. of the Army - Corps of Engineers (DA). There is an implied duty on the part of Elbert County to maintain communications with the CMLRD and to express its concerns to the DA. Clearly, the erosive potential and problems at the site are known the CMLRD, and the County and the CMLRD have been clearly caught short in coming to a satisfying remedy. This does not indicate however that an effort has not been made. Clearly, the County has made every reasonable effort to comply with the corrective action called for in the CMLRD Technical Revision, with some potentially favorable exceptions. Unintentional fill from the construction of the west berm could have been anticipated by the County or CMLRD. As for the hydrologic event, the culvert placements were established as agreed. To date, I don't think the County can be held accountable for acts of God, especially. when those acts aren't measured. Without knowing whether or not the 25 year 24 hour event was exceeded, it's difficult to determine the effectiveness of the culvert design. Obviously, if the fill and culvert design requested by the CMLRD had been avoided altogether with a simple streambed crossing, the sediment load result- ing from the destruction of the fill by the hydrologic event could have been greatly reduced. Additionally, the use of rip rap seems of little value since normal flows would contribute sediments over the rip rap or undercut it. The natural eroded vertical walls of Spring Branch indicate that such features are typical of the drainage, are the more stable, and eventually, the im- pacted banks would return to this form regardless of treat- ment. Emphasis on stability of the mine floor and slopes, elimi- nation of the perched access road and possible relocation outside of the flood plain, and benefits via changes to mining and reclamation methodology, including site expan- sion, revegetation of the impacted streambed, and other measures, would do more to aid the overall site and im- pacted areas. This concern should be expanded upon in a CMLRD Technical Revision, as proposed below, Finally, efforts to remove the sediments from Spring Branch would probably create more disturbance and problems to sta- Correspondence of 6/15/91 to Frank G. Starkey. Elbert County Commissioners Office from Bradford Janes, Gambit, Inc. RE: Fondis X Mine - Summary Report.