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<br />Steve Bennett <br />June 13, 2000 <br />Page 9 <br /> <br />assets, so as to provide funding for the full S3 million. <br />Since the purpose of the designation was to safeguard <br />locatable minerals as a supply for the rock dust plant, and the <br />fines materials had been left at the site because of improper <br />sizing for use in the rock dust plant, it would seem that the <br />community pit designation did not apply to these fines materials. <br />Where the purpose for which the community pit has become <br />moot, so too has the community pit designation. As described in <br />your letter, BLM contemplates supplying road base through the <br />community pit, a purpose unrelated to the stated reason for the <br />designation. <br />The letter of May 1~, 2000 indicates that BLM is considering <br />use of the 'lower grade fines pile" for a common variety purpose, <br />namely ongoing maintenance of the Transfer Trail road. At the <br />time of the community pit designation, BLM had taken the <br />position, asserted to the IBLA, that the third pile consisted of <br />non-locatable minerals, whereas the pit was established to <br />safeguard locatable minerals. Thus, it would seem to have been <br />excluded from the community pit designation. <br />Moreover, using marketable locatable grade minerals for a <br />common variety purpose appears to be squandering of valuable <br />resources. <br />RECLAMATION <br />Pitkin Iron agrees that the reclamation plan approved by the <br />Mined Land Reclamation Board, under permit M-92-121, governs <br />reclamation of the quarry. This is substantiated by BLM's letter <br />of July 21, 1989, signed by Bob Elderkin on behalf of District <br />Manager James R. Owings, which provides, 9[6, that "Authorization <br />is subject to all other aspects of operations and reclamation as <br />stated in the submitted plan and plan amendment." <br />The letter of May 17, 2000 states that "uncompleted <br />reclamation responsibilities conflict with our now established <br />community pits, as well as other possible multiple uses." <br />..°,eclamaticn, says the letter, should be started this year. <br />We are uncertain as to what, specifically, BLM has in mind <br />for the community pit, and how or whether this fits with the <br />reclamation required by DMG. Does BLM intend to excavate <br />material? If so, where, when, for how long, and how much? Is <br />