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~~~NN~D TO: Dave Berry PROM: Sandy Brown DATE: December 3, 2002 RE: Roadside Loadour aad Land-Use Change F-990 ....r~luN MINER/ &- GEOLO REC LAMAT MININC•SAF BIII Owcm Gwcmor re6 a walchar Dan Mathews met with Jim Stover and representatives from United Companies (a grave~xeativa Director mining/construction company) regarding the Roadside Laadout azea. United Co. is Vet~nald W. Canany interested in the prospect of ;ravel mining in this location. They wanted to meet with DMG tbt`s"t °1v1'I°" °1n discuss the permitting of the gavel mine and the bond release standazds and process for the coal pernai,t Steve Shuey attended the meeting to discuss the gravel permit requirements. Dan's January l2, 2000 letter to Jim Stover served as the staring point far the discussions. A copy is attached for your information: United Companies is considering the "fast track" approach Dan discusses in his first scenario. In this scenario, a land use change to industrial use for the loadout area is required. The 'fast track' approach assumes mining will be initiated it°mediately upon receipt of the gravel permit. The coal bond would be released after gravel mining has "substantially commenced". Several questions arose during the course of the meeting. Before, DMO commits further we want to be sure that there aze no fatal flaws given the unique circumstances that aze not addressed by the talcs. itenrtl fromthe 1/IZ/20001etterstated: Coal pernrittee lnirlates reclamation, removing any facilities that won't be used in a gravel operation, andfully reclaiming areas that would not be mined. A couple issues were raised is regard to this item. A portion of the current coal loadout ar~- would be disturbed by actual gravel excavation, and most of the remaining coal loadout azea would be used for stockpiles and other facilities ancillary to the gravel extraction. All of those distwbances would be included in the gravel permit Jim Stover wanted clarification that all \~ --• disturbances included in the gavel permit would be exempt from the full reclamation under the coal permit aad not only those areas that would be mined. Daa said chat full reclamation under the coal permit would be required only for those areas that would trot be disturbed lender the IL gravel permit, and that the "exemption" would apply to stockpile and ancillary disturbances as well as to areas of actual gravel extraction. _, econd, Stover stated that the reclamation requiremenu for dte coal permit would be limited to~~n.+~''t facilities demolition and disposal; it would not include the requirement to backfill the site to AOC "'' and restore essential hydrologic fuacrions. Dan confirmed that this was DMO's intention. The ~~ ~<r~r' extent oP demolition, site grading and clean up to be completed under the industrial Land Use ~ 3 <. scenario will be addressed in the Postmine Land Use change permit revision a lication. ~ ~\ it should be noted that Rule 4.14,1(2)(a) requires mstoration of AOC with the cxceptfon of trt'` specific listed exempriotta (excess materials from higltwalls, pre-law highwalls, steep slope , variances). There is no specific AOG exemption in ow rules pertaining to alternative postmine fti landuses. However, Rule 4.14.1(2)(b) does require that backfilled material be placed, to support 5t{~~,Ir ~e poatmining land use. it is ow poriition that the lend use designation overrides the AOC ~, ~~ ~~ DEC-30-02 14:16 FROM-Colorado DIvlslon of Minerals b Geolow +13036663667 Post-it' Fax Note ~, DIVISION OF MINERALS AND GEOLOGY Deparanentof Natural Resources 1313 Sherman sc, Room 215 Denver, Colorado 80203 Phone: (3031 8663 5 67 PAX: (303)832-8106 T-983 P.001/002