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,- ~• ENVIRONMENT, INC. NOVEMBER 13, 1997 PAGE 2 I think it is best to work this out now rather than go thru a bond reduction request later. My concern is the issue would remain until or if the west parcel is mined and it will save us all, time and money in the long run to resolve the problem now. As we proposed in the amendment the slopes will be reduced as mining takes place around the exterior, but on the working face this is not practical. I included the cost to dewater the active mining azea, the existing west lake and do grading/backfilling on the face in the reclamation cost estimate. Your suggestion to take picture for future is an excellent idea and I will suggest that Delta do this in the future. RECLAMATION PLAN 1. I think the issue here boils down to the island and how do we come to an agreement that allows Delta to take the island out and still have an acceptable plan. The island was originally to be built with overburden or waste material generated by the mining operation. As technology improved we found that waste material was valuable and could be utilized by the company. During your inspection earlier this year you noted the island was not built, the mine was not phased and that we needed to address these problems. About this same time we found out the Blacks wanted their property mined so we decided to address all the deficiencies noted in your inspection report and increase the permit area, all at one time so this amendment was prepared. When I made the statement in the Reclamation Plan text 1 was referring to the revegetation program and not to the changes in the lake configuration. The rules state that we only have to submit information on the changes we propose and the island removal was addressed, both in the text and on the maps. I apologize for not being more clear, but I truly believe we were doing the proper thing at that time. Since the discussion we have had in the past is part of the adequacy review and the changes we made were part of the amendment I do not understand how we would have to republish and extend the comment period if all the changes we have been discussing are part of the amendment document. We seem to be stuck on the future use of the old azea and it is my belief that we changed it when the amendment was prepared. Even the legal, adjoining, Board of County Commissioners and SCD notices stated the proposed future use was "Recreation". The Tamarisk issue is new in this review letter. A simple response would be to say that we will take a brush cutter to them, but we feel they have value on this site. While Tamarisk are not politically acceptable to Federal agencies, it is my experience that they are used by wildlife. They have invaded the site over the years and were not introduced by Delta and they do serve to prevent erosion around the lake perimeter. They also provide a riparian buffer along the lake used by mammals and birds for protection. Mr. Ripp told me that the submerged Tameisk area is where their best bluegill fishing is and he did not want to lose that. I am not trying to avoid sending you a particular plan on the shallow slope vegetation, I just do not think it is necessary because the aquatic plants that are on the site now were not planted by Delta and natural invasion seems to be adequate. Delta will agree to place 6 nesting platforms for geese along the north side of the existing lake area. They will be built and installed this spring (1998) before the geese start nesting around the lake. These platforms will provided more surface area than the 260 sgft island