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,o. ~ ` '`~ lirl~d States Department of th~nterior ''" ' ~ OFFICE OF SURFACE MININ ~~ ~~__ .9 Reclamation and Enforcement ~ '* - BROOKS TOµ'ERS 1020 I STH STREET DENVER. COLORADO 802D2 December 22, i98_^ `lemoraadum To: Director, Offic/e~ of S rface Mining From: Admiaistrato ue n Technics enter Subject: Response to Solicitor's Comments Roadside and Cameo Decision Package The Solictor identified tha*_ the state required numerous stipulations to correct deficiencies. The mining complex has numerous "Grandfathered" features and problems and is located in an environmentally sensitive area that requires close eaoiro~ental and reclamation control. Therefore, a number of stipulations are required to monitor and assure proper reclamation. it is felt that the operator of this 1,100,000 tons per year mice, will diligenty comply with the stipulations as evidenced by their record cooperation with the Regulatory Authorities to achieve a decent standard of mitigation and reclamation. The Solicitor also identified the problem to whom the "bond" is payable. This was a typographical error and the State and company both realize the bond is to be made payable to the State Regulatory Authorities and the Federal Govert>ment . Regarding the concerns the Solicitor had with ownership change, Western Associated Coal sent a letter (see letters of concurrence) detailing the ownership changes. Alsa a revision to the MRP was submitted by Powderhorn Coal Corporation in January 1982 detailing the requirements for the change ownership. The WTC staff checked this information for adequacy and found the material to be complete. These documents are all on file in the WTC office. The Solicitor's final concern regarding revegetation is a serious problem in this semi-desert environment. The area has a very sparse vegetation density with limited precipitaion sad poorly developed soils. This concern will be closely scrutinized to assure compliance by the company according co Jim Herron, Reclamation Specialist, C:II.RD. Revegetat'_on in semi-arid areas ass, to date, been demonst.ated only on such severe'_y disturbed areas such as in highway construction sites and is the continuing concern of oversight.