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affected area, must all be located within the boundary of the permitted area; no affected area <br />may exist outside the permitted azea boundary. <br />B. "Affected area" includes all land that will be disturbed during the life of a permitted <br />operation, whether it is disturbed immediately after permit issuance or ten years hence. It is <br />"affected area" whether the area to be affected by mining was disturbed before the permit was <br />issued or is not yet disturbed by mining. The necessary size and extent of an affected area <br />should be carefully determined, then defined and marked, since it cannot be adjusted simply <br />on the whim of the operator when more land is needed, and its boundaries are not to be <br />exceeded. Land additions involving boundary adjustments are accomplished through the <br />amendment process. And finally, after a disturbed area is reclaimed, it remains "affected <br />area" until the Division approves the release of the land from further reclamation liability. <br />C. No comment needed. <br />D. The GMG # 13 decline and surrounding azea were used (re-disturbed) by the operator under <br />this permit and, as such, are to be considered a part of the affected area. This small site must <br />be defined and described for the file, since it is part of the affected area. However, as noted <br />in (lA) above, all affected areas where disturbance occurs must be within the permitted area, <br />so this is a pertinent statement. <br />E. All azeas of pre-existing disturbance which have not been re-disturbed under the permit, are <br />not liable for reclamation or bonding. At the GMG # 13 site, it is assumed that there are <br />historic or pre-Law features which have not been touched by the permitted operator since the <br />permit issuance in 1977. These do not have to be reclaimed by the permitted operator nor <br />included in the bond. But it is clear that there are portions of the site, such as the decline <br />opening, overhead electric power supply, stormwater control structures, road, etc., that have <br />been used during the life of this permit, and therefore must be included in the affected area, <br />included in the reclamation bond, and reclaimed. As explained above, the disturbance to be <br />reclaimed by a current operator may have been caused by a former operator. (That is part of <br />what a successor operator agrees to when a permit is transferred.) <br />F. Bond includes closure of a specific number of underground openings (vent shafts) which at <br />this time aze presumed to include the GMG # 13 decline. This maximum number of permitted <br />openings (limited by the bond amount and/or specific permit language) may change once the <br />total inventory of openings is well documented. Likewise, the acreage affected at the GMG <br /># 13 site is currently presumed to be included in the 40-acre affected area total, though until <br />all affected areas are measured, the actual total acreage of all affected areas will not be <br />known. <br />G. Good. <br />H. N/A <br />I. N/A <br />J. This was related to a point made in a paragraph addressing all five of the permits in the <br />group, some being 110 permits, some bring 112 permits. As my last correspondence to you <br />clarified, "permitted area" is the same as `affected area" fora 110 permit. As explained in <br />(1B) above, a clear description of the land surface to be considered affected area must be <br />made. As (lE) states, all disturbance related to the permitted mining is to be bonded. <br />Therefore, all land areas and features must be quantified, described, located, marked, etc.; <br />they must be in all ways documented for purposes of monitoring and bonding. In the context <br />of this (112) permit, my original comment is applicable with reference to ensuring that the <br />remote vent hole sites and their access roads are all located within the 755-acre permitted area <br />boundary, as well as ensuring that they aze all adequately described as lying within affected <br />area boundaries. <br />K. This is apparently a misquote. My letter stated, "...disturbance at or near the portal..." Tlus <br />refers to mining-related disturbance since the permit was issued. The earlier maps being <br />referred to are the annual report maps from 1979(?), 1980, 1981, 1982, April 1983, a <br />