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NOLAN RRCHSTECT'3 303325A417 i • CONCERNED CITIZENS OF OURAY COUNTY 20 Parkway Ridgway, CO 81432 May 2, 1992 Larry D. Oehler Mined Land Reclamation Division Colorado Dept. of Natural Resources 1313 Sherman St., Room 423 Denver, CO 80203 FAX No. (303)832-8106 RE: Peck, Inc. Limited Reclamation Permit Submitted April 14, Dear Mr. Oehler, Impact operation (110(2)) Application 1992 We wish to offer the following comments regarding the referenced application. P.d2 Backcround Information: Peck, Inc. first submitted an Application for Permit from your division on July 11, 1990. That application was submitted under the Colorado Mined Land Reclamation Act, 34-32-101 ET.SEQ.,CRS 1973 as amended. It involved the same parcel of property as the present Limited Impact Application. The permit was denied following a hearing on February 27, 1991. Prior to the hearing, your Board issued deficiency letters on 10/10/91, 11/13J91, 11/16/91, 11/30/91 and 2/1/92. The letters of 11J30/91 and 2J1/92 recommended denial of the permit because the applicant failed to provide substantial evidence on the problems identified by the Division. Those problems included a lack of studies and technical information that would allow the Division to analyze 1) Offsite Impacts, 2) Hydrologic Impacts, and 3) Mining and Reclamation Plans. We have reviewed the current application and have concluded that it is similarly deficient. We find no competent studies or plans to review and feel that the Applicant is following the same course that led to the previous denial. The public and your Division cannot be left substantially in the dark regarding this operation which is proposed for a highly sensitive area. eoecilic Deflciencias: It is extremely difficult to comment on specific deficiencies since the Application contains primarily conclusionary comments about the operation and virtually no studies to analyze. Nonetheless, comments at this point are as follows: