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iii iiii~~iin~~i iu <br />999 <br />,. <br />i-; . <br />. ; ..~ <br />ENERGY COMPANY <br />P.O BO% 46] GOLDEN, COLORADO B040Y <br />May 23, 2001 <br />Mr. Byron Walker <br />Division of Minerals & Geology <br />Department of Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />Re: Minor Revision No. 38 <br />Additions to Permit Section 2.05.4 <br />Dear Mr. Walker <br />RECEIVED <br />MAY 2 4 2001 <br />Division of Minerals 8 Geology <br />Coors Energy Company (GEC) is in receipt of your letter dated May 11, 2001, concerning the <br />"technical adequacy" of this Minor Revision No. 38. As discussed with you in the course of our <br />most recent telephone conversations, CEC understands and appreciates the interest and concern in <br />maintaining the integrity of our Permit versus the "Regulations" governing coal operations like <br />the Keenesburg Mine. However, CEC believes the focus should be on restoration of the pre- <br />mining environment, irrespective of the time clock known as the "extended liability period". It is <br />recognized that initiating many of the actions proposed in MR-38, once initial seeding is <br />complete, we will necessarily cause the time clock to start over. If by doing so a growing <br />environment is enhanced or a reclamation parcel is saved from damage that might otherwise <br />occur, then CEC will so advise CDMG, and the extended liability period will be restarted. <br />Following review of the suggestions presented in the May 1 I`" letter, CEC has revised and <br />herewith submits three (3) copies of a revised page 115b wherein reference to "extended liability <br />period" (last sentence ofthe first paragraph) has been deleted. GEC's view of the remaining <br />suggestions is that they focus is on preserving the initial time clock, a concept which will gain <br />relevance once the last reclamation parcel at the Keenesburg Mine has been seeded and Phase III <br />bond release is more than a distant goal. It is also possible (and hoped) that by that time CEC <br />will have mastered the methods and means to reestablish the best reclamation environment with <br />each first attempt at seeding, as opposed to the current alternative. <br />Again, thank you for your assistance and suggestions. CEC trusts that the submitted modification <br />will be deemed sufficient for the approval of Minor Revision No. 38. Please contact me if there <br />aze any further questions. <br />Sincere <br />~bonald W. MacDonal <br />Manager, Energy Services <br />pc: M. Savage <br />