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DEC-80-02 14:16 FROM-Colorado Division of Itlnerale b Geology +13036663567 T-063 P.002/002 F-6B0 <br />requirement is the same way that the industrial land use designation overrides the AVF <br />restoration. <br />Item 3 from the 1/12/2000 letter stated: <br />Gravel operator obtains q1! necessary permits and approvals for gravel exmactton, and coal <br />permittee applies for bond release for the area to be affected by grave! operations, Upon <br />demonstration that the industrial (and use (gravel mining) "has substantially commenced and is <br />likely to be achieved" (3.02-1(2)(e)), the con! bond could be released. Note that, for some period <br />of time until release of the coal bond, the area permitted for gravel operations would be <br />permitted and bonded under both the Coal and Mineral Programs. <br />it is likely that there will be some portions of the area disturbed under the coal permit that will` <br />eventually be disturbed under the gravel pemtit, but the actual disturbance under the gravel \I ~/ <br />pemdt may not occur for several years. It is our position that the vegetation cover requirement of <br />Rule 4.15.10(2) would apply to those areas that will not be disturbed by the gravel operation <br />within the next year (or so). The intent would be to stabilize disturbed lands to m;n;mize water <br />and wind erosion. <br />Dan has asked United Companies to provide DMG with a drafr gravel mining plan and scheduld <br />for the site, that would allow us to identify the critical issues and address in more detail the <br />specific requirements for release of the ooal bond attd termination of the coal permit, under the <br />"fast track" approach. 'They seemed amenable to this. Dan and Steve stressed that, up until the <br />point that the coal permit is terminated, compliance with all components of the coal permit <br />including sediment and drainage crontrols would be required and would be the responsibility of <br />the coal peratinee, <br />In snmmar;~;ng Dan also requested that Roadside provide a sequential reclamation plan in the Q!1/ <br />permit revision contingent upon when gravel mining would begin, This would be consistent with <br />the three scenarios discussed in his January l2, 2000 letter and would require complete co <br />reclamation if gravel mining does not go forward <br />Please give this process soma thought and let me know if you have any concerns. Since this is a ,,I' <br />unique aituatioq it would be a good idea to inform OSM of what we are doing w avoid a surprise (~ <br />in the future. Jim Stover is concerned that OSM might object to a bond release decision after <br />United Companies has obnined all necessary gavel-mining permits. Dan notes that if OSM ~01~P <br />were to apply a very literal interpretation of the rules, they. might conclude that bond release <br />could nbt properly be granted until after grading of the entire site to AOC, demonstration of the ~ yP~ <br />establishment of adequate vegetarian cover, and demonstration of restoration of the essential ~~~('~ <br />hydrologic functions of the A'VF. To avoid this from happening, I suggest we inform OSM of the v/~/ <br />situation at our next meeting. <br />cc. Dan Mathews <br />