GENERAL48560

• Permit No: M1981148
• IBM Index Class Name: General Documents
• Doc Date: 10/24/1978
• Doc Name: MEMO-SPECIFIC PROBLEMS
• Media Type: D
• Archive: No

grazing land until the operation ceases. There is a statement
that total acreage to be reclaimed will be determined at
that time. In addition, the application recites that "when
operation ceases most of the land will have been reclaimed
as we advanced with the pit."
The recitations referred to above suggest that reclamation
will be accomplished as operations progress and a one-time
mining concept is in effect. However, the proposed plan is
very general and it is suggested that we request Robinson to
include more affirmative language to indicate this method
will be employed.
The statute and regulations do not provide a clear
indication of a timetable for proposed reclamation and the
Reclamation Act allows the operator to delay implementation
of its reclamation plan until the conclusion of the entire
operation. Thus, the means by which periodic reclamation
could be enforced would be through the permit and for that
reason it is important to include specific provisions pertaining
thereto in the permit application.
With respect to periodic assignments to the City of
Lakewood, it is suggested that an agreement be obtained
which provides that Robinson will assign fully mined lands
to the City only after the tined Land Reclamation Board has
approved the reclamation plan and released Pobinson from
further obligations with respect to reclamation pursuant to
the provisions of the Act.
3. The City should be in receipt of and be responsible for
approval of plans showing existing topography of proposed
final grading for the area to be mined.
Exhibit B of the permit application indicates that
overburden will be used for fill and graded to a one-to-one
slope. However, Exhibit D indicates Robinson will follow
the recommended action by the Soil Conservation Service and
slope the areas to 3 to 1 or flatter leaving them rough
enough to hold topsoil and water where possible to aid in
the revegetation process.
The Act and F.ules and Regulations promulgated pursuant
thereto contain several provisions pertaining to grading and
require the operator to create a final topography appropriate
to the final land use selected in consultation with the
landowner. It is suggested that we determine the final
grading desirable and request Robinson to commit to that
concept in the application. Once again, this will provide
the Board with a specific power of enforcement.
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