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02i`12/1998 11:22 9702597514 PAGE 04 <br />• <br />The inaccuracies and lack of detail are highlighted by the proposed reconstruction of the <br />intermittent stream that runs toward the northeast Review of the reclamation map shows that the <br />stream has the same direction and rate of slope as the entire 158 acre pazcel under consideration, <br />even though it runs from the center of the pazcel to the northeas and then turns to run almost <br />directly east This leaves unanswered the question of where waters in the eight mining uniu that - <br />slope to the east-southeast will run. Applicant's simultaneow claims that there will be no <br />interaction with groundwater and that no stormwater will run off-site until Unit 1X defies logic <br />and is indicative of the level of accuracy and detail in the overall application. <br />The stream reconstruction plan provided admiu that "re-vegetation of the stream bottom. <br />.. is impractical, and shall not be required nor attempted in the reclamation phase of the <br />operations." )~., ¶5. Instead, the applicant merely plant to "rip-rap" the lower end of the stream <br />channel where there is a steeper stream gradient. Review of the application and revisions leave <br />the reviewer to guess the slope of this steeper gradient. Serious analysis of the proposal is not <br />possible due to the paucity of information provided by the applicant. In any event, applicant <br />provides n~ asstuance that this reconstructed stream on a reclaimed hillside with a supposedly <br />even gradient will maintain its course over time or in any way avoid erosion and siltaticr. during <br />or after reclamation of the proposed operations. <br />Ar.~ther intervening factor is especially troubling: DMG's recent withdrawal of its <br />finding that a reason to believe a violation exists. A January 30, 1998, Bureau of Land <br />Management site visit revealed eighteen test pits on the 158 acre parcel. Each test pit disturbed <br />an azea that varied from 200 to 750 square feet, resulting in unauthorized disturbances of <br />between 3,600 sq. ft. and 13,500 sq. ft., well over the 1600 sq. ft. exception in the Rules, even <br />assuming argueado that the Rule is still valid. The BLM report discredits and contradicu the <br />DMG inspection report that located only five test piu, but is quite consistent with the reports <br />made by my ciienu. -The staff s withdrawal of the finding is aggravated by the fact that the <br />violations impacted sites of historical and archeological significance, although not enough to <br />destroy thew significance. Further, these sites have yet to be adequately reclaimed. <br />The serious issues raised by my clienu provide ample reason why this application can not <br />be legally approved. These issues also provide ample legal grounds to deny this application <br />The Colorado mining laws seeks to promote an economically sound and stable industry that fully <br />