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iii iiiiiiiiiiiiiiii <br />9~ <br />September 12, 1998 <br />Mr. Harry Ranney <br />Reclamation Specialist <br />western roeis-Colorado Division of Minerals & Geology <br />P.0. Box fi18 1313 Sherman St., Room 215 <br />N~~ia, Colorado 81414 Denver. CO. 80202 <br />F~~~:E~1fED <br />SEP 1 6 1998 <br />p1V. OF MINERALS <br />Telephone 970/8841165 <br />Fax 9701884-1188 RE: RESPONSE TO ADEQUACY REVIEW QUESTIONS DATED MARCH 26 AND JULY <br />31, 1998 FOR TECHNICAL REVISION No. 36, REVISED REVEGETATION <br />PERFORMANCE STANDARDS FOR NEW HORIZON 2 MINE AREA. NEW <br />HORIZON MINE, PERMIT C-81-008 <br />Dear Mr. Ranney: <br />I failed to adequately answer some of your questions from the March 26, 1998 adequacy <br />review letter. I will attempt at this time to answer your questions. I have listed my responses <br />below. <br />1 a. WFC's original proposal for production standards was based upon five local farmers <br />production. Since this submittal, I have learned that I can not base the total <br />production for a particular grass cover on just "one" years worth of data. This Is <br />understandable. I then verbally discussed with the Division other options to come <br />up with production standard measurements and it was my understanding that I could <br />use written testimony from local farmers that had experience with similar grasses and <br />use what they have proposed. By doing this, I would have numerous years of <br />production data that would back up my request. I then resubmitted TR36 with these <br />written testimonies so the first part of your "1 a." concerns should be satisfied. To <br />answer the last part of "1 a." I would like to say that the motivational force for WFC <br />to make this permit revision request is economics. WFC doesn't necessarily disagree <br />with the production from the Bar soil description that NRCS published but we feel that <br />there has to be a more economic method to measuring success than to spend large <br />amounts of money. WFC feels that measuring the "First Cutting Only" would be a <br />fair method of satisfying the regulations in an economic prudent manner. As I have <br />stated in the original TR cover letter, WFC has experience large cost associated with <br />acquiring production figures (three cuttings, pumping cost, and contract labor) due to <br />the price of material, supplies, and labor. I also mentioned in the original cover letter <br />on how the local farmers took care of their own fields before harvesting WFC's and <br />that made it most difficult to get three cuttings. I would like to add that Mr. Dean <br />~:\datn `, r~pdata \revis ions\tr3b.doc Page 1 <br />