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GENERAL54214
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Last modified
8/24/2016 8:39:31 PM
Creation date
11/23/2007 9:17:38 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977211
IBM Index Class Name
General Documents
Doc Date
11/4/2004
Doc Name
Enhanced vs. Permitted Reclamation Plans
From
Southwestern Ecological Services
To
DMG
Media Type
D
Archive
No
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Page 2 <br />Nov 2, 2004 <br />Pikeview Enhanced Plans <br />Bruce Humphries <br />Recall that the CMRF was specifically designated as the body to oversee and implement the enhanced plans <br />developed by the Mining Reclamation Advisory Committee. This designation was provided in a joint meeting <br />between the Colorado Springs City Council and the EI Paso County Commissioners. 'T'hus, in the 1994 Pikeview <br />amendment, the enhanced plans were well distinguished from the permitted plan. But now that distinction seems to <br />be vague at best, but only with regard to the "Previously Mined Areas" of die enhanced plans. Everyplace else the <br />distinction remains as originally stated in the 1994 amendment. The question, therefore, is this. On the layback area <br />("Previously Mined Areas") what now constitutes enhanced reclamation and what constitutes pemutted reclamation? <br />If the permitted plan has now replaced the enhanced reclamation plan far tbir pecific area, is there, in fact, any <br />enhanced reclamation? Ox, are there portions of the enhanced plan, as envisioned for other areas, applicable to this <br />area where the plan boundaries have become quite vague? In other words, certain actions proposed for new mining <br />areas under the enhanced plan may have become applicable to the Previously Mined Areas because that area is now <br />anew mining area. <br />We don't doubt that whatever is implemented on the layback, enhanced or permitted, will be immensely better than <br />what was proposed when the enhanced plans were originally drafted. And we would hope that at least most parties <br />will be pleased with the final product. However, there is a concern that because the differentiation between <br />enhanced and permitted reclamation on the layback area is unclear, disputes might arise in the future. <br />Clearly, the original approach of including the enhanced reclamation plan in the permit as an unbonded overlay to <br />die permitted plan is still in effect and still very much a part of the permit. But with respect to the layback area it <br />appears the situation has changed. We believe this probably should be addressed in the permit in some fashion so <br />that when all is said and done people Five or ten years from now will know how to think about the final reclamation <br />product and be able to tell who did what. Perhaps only an update to the enhanced plan in the permit is needed, as <br />the mechanism For inclusion of that plan is already in place. Or perhaps a memorandum of understanding between <br />DMG, MLRB, and the CMRF is needed that defines the course of action on the layback azea at Pikeview. In short, <br />some means to bring the boundary between the two plans on the layback area into better focus. <br />Please think about these issues and if you desire, we can discuss it further in the neaz future. <br />Sincerely, <br />Mark A. H fner <br />cc: Jerry Hermann, Castle Concrete <br />Wanda Reaves, CMRF <br />Scott Davis, CMRF <br />
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