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Introduction During the last nine months, the Division-has taken a number of enforcement actions designed to bring the G.E.C. Strip Mtne into compliance with its permit and with the requirements of the law. It is my belief that these enforcement actions have not been fruitfrl in achieving environmental and regulatory compliance at G.E.C. Strip. Currently, the mine is, for all intents and purposes, abandoned: Over 60 acres lay unreclaimed, no drainage control structures are functioning due to lack of maintenance, topsoil stockpiles may be lost due to unstable hlghwall conditions, and the mine is not secured to prohibit the public from freely accessing a serious health and safety hazard. Additionally, G.E.C. Minerals, Inc. has failed to satisfy several stipulated conditions to permit C-037-81. In short, the site is in a state of unmaintalned and unreclaimed disrepair and perhaps most important, the performance bond for the G.E.C. Strip Mine is inadequate. We believe the disturbance to the underbonded by more than 6200,000.00. The Division considers these circumstances to be a "pattern of violation". We have formalized these problems, as required by Rule S.D3.3, by issuing an order to G.E.C. Minerals to demonstrate why permit C-037-81 should not be suspended or revoked. Issuance of a Show Cause Order requires that a hearing be held artd that the Board decide on this matter. If the Board decides to revoke the permit, then Rule 5.03.5(4) requires the Board to consider forfeiture of the performance bonds to assure reclamation of the site. I will be presenting evidence in my testimony which we believe ~ustiftes: 1. Revocation of permit C-037-81, and 2. Setting a hearing to consider forfeiture of the performance bonds associated with permit C-037-81. ~~ ~~p'~~ Durinq the course of my testimony, I will be referring to a number of exhibits that are available in the public file for this mine. At the end of my testimony, I would like to enter these exhibits in summary as evidence for the record. Orientation 7o begin my testimony, I would like to take a few minutes to orient the Board as to the ,location of G.E.C. Strip and the environmental character of the area. The'G.E.C. Strip Mtne is located about 8 miles south of Florence, Colorado in Fremont County. The mine is situated 1n a transition zone between the foothills of the Wet Mountains and the eastern Colorado plains. The climate of the area is semi-arid. Mean annual precipitation 1s 12 inches with 70% falling between the months of April and September. Existing vegetation 1s primarily an ecotonal mix of grassland and woodland communities classified by the SCS as poor to fair for rangeland and wildlife habitat. Twenty-four inches of topsoil/subsoil are available over most of the site. No prime farmland or alluvial valley floors are affected by the mine. Generally, the hydrologic consequences of the G.E.C. Strip Mine have been considered insignificant by the Division. One final note about the general area, it has been extensively mined since the early 1900'6. Numerous abandoned spoils and refuse dunes are visible throughout the landscape.