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JUN-13-2000 13:11 DELRNEY & DELRNEY 970 945 2303 P.06 <br />Steve Sennett <br />Sune 13, 2000 <br />Eage 5 <br />there a sequence of mining? How is the material to be removed <br />from the quarry - i.e., by the existing roads in their present <br />condition? In a post-reclamation configuration? who is <br />responsible for any environmental damage under the community pit <br />designation? Who is responsible for added reclamation <br />responsibilities which may occur as a result of the operations <br />carried out under the community pit designation? Is an a <br />additional bond amount to be pcsted for additional reclamation? <br />If so, by whom? The BLM? <br />It would seem that under the community pit designation, BLM <br />contemplates extraction of materials from the site on an ongoing <br />basis for years to come. If so, this is difficult to reconcile <br />with Pitkin Iron/Mid-Continent Resources Carrying out and <br />ccmpleting reclamation. Reclamation cannel be done on an area <br />subject to continued further disturbar_ce. <br />Applicable regulatcry requirements, and the plan itself, <br />contemplate carrying out backfill, grading and vegetation of <br />disturbed areas only after the completion of mining. For Mid- <br />Continent/Pitkin Irvn to complete backfill/grading and seeding, <br />only to have the area redisturbed as material is extracted on an <br />on-going basis for read base or other materials, makes no sense. <br />The result of disturbing cur reclaimed area would be an <br />unreclaimed site. <br />Please note that the State regulations for Mined Land <br />Reclamation, require: " <br />3.15(4) All backfil.Ling and grading shall be <br />completed as soon as feasible after the <br />mining process. <br />Tile approved reclamation plan provides, at Sec. II, page 2, <br />1989 amendment, that: <br />"No reclamation can be accomplished prior to <br />cessation of mining because all the areas <br />(haul roads, access roads, fines storage <br />area, processing and production benches) are <br />utilized in the mining process." <br />Also: <br />"Reclamation will be accomplished during the <br />first four or five working seasons following <br />cessation of mini~ls. <br />