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~_ <br />The Corley Company <br />Pnone 602-5050 P.O. eos 1621 <br />COLORADO SPRINGS. COLORADO 60901 <br />Mar, 30, 1993 <br />Pls. Catherine W. Begej <br />Div. of Minerals & Geology <br />1313 Sherman St. <br />Denver CO 80203 <br />Dear Ms, Begej: <br />III IIIIIIIIIIIIIIII <br />999 <br />RFCEIVEn <br />MAR 31 1993 <br />~IVISIO(I Uf hLtidi::io 5 veLl.tyy <br />Using your numbering from your Mar. 24, 1993, letter we have these <br />replies. <br />1. You inspected our records during the last quarter of 1992, at which <br />time you yourself selected the volumes of the Harrison Western prepared <br />permit document that you said were our permit. You even put paste-on <br />labels in your hand writing indicating those volumes. We have, there- <br />fore, used the permit volumes you indicated. We decline your suggestion <br />that we give the Division directions for which volumes to keep or <br />archive; in the past when we have accepted your suggestions, the <br />Division has refused to comply with your suggestions. <br />2. Our responses seem to be entirely consistent with 2.03.4(6)(a), (b), <br />and (c) and 2.03.4(7) rev. 6/30/91. What do you believe to be <br />inconsistent? <br />5. Our responses seem to be consistent with the definitions of owners <br />and controllers found in 1.04(83a). What do you believe to be <br />inconsistent? <br />6. The NPDES permit is the only other permit held. Is there some other <br />permit that we should have? 2.03.10 seems self explanatory. <br />7. In 1989, the Division changed the designation of the road from a <br />haul road to a light use road. 4.03.3(3) provides that field-design <br />methods may be used for light-use roads. 4.03(5) states that road <br />surfaces shall be adequate for the use of the road; the road now is used <br />for foot travel for which the surface is more than adequate. 4.03(,6) <br />states that maintenance shall be sufficient to ensure minimization of <br />erosion; the road has reached a stable configuration in the five years <br />we have owned the property. Pulling loose material onto the road will <br />only increase erosion of that material. We do not find any section <br />regarding light-use roads demanding a positive crown. Contrary to your <br />previous comments, the City of Colorado Springs advocates inverted <br />crowned roads for certain applications. However, on a practical basis, <br />there is no way to bring maintenance equipment to the road. <br />Incidentally, we find in the permit Section 4.03.1: "The road shall be <br />maintained to specifications until reclamation...". <br />8. Bertoldi incorrectly used 3.10 in. for a 10-year 24-hour event <br />