PERMFILE135119

• Permit No: M2003037
• IBM Index Class Name: Permit File
• Doc Date: 7/21/2003
• Doc Name: Objection
• From: Friends of Spring Creek Mesa
• To: DMG
• Media Type: D
• Archive: No

07/21/03 15:47 FAX [phone] TH6t8siQ
Mr. Carl B. Mount
July 21, 2003
Page 8 of.10
This application has failed to propose a reclamation plan that conforms to the
foregoing definition. Specifically, but not by way of limitation, the
application currently proposes 'cropland' as a post mining land use. The
claimed probable success of that proposal is not supported by the application
and is counter intuitive. The applicant proposes to leave two approximately
40' pit depressions, without drainage, lying immediately above an
impermeable shale layer, below the probable seasonal groundwater table,
without an irrigation plan, crop choice, farming business plan or farmer. By
all reasonable accounts, the probability of the success of the proposed post
mining land use in this configuration is questionable at best.
Additionally, by operation of Rule 3.1.3, the applicant is required to and
claims to intend to implement concurrent reclamation. The application must
therefore .demonstrate the technical and economic feasibility of farming
reclaimed phases during adjacent active mining and manufacturing
operations, in small, approximately 25 acre 'fields' over the life of the mine.
The application completely fails to make such a demonstration.3
Reclamation -Visual lmpact
Contrary to the requirements of Rule 3.1.5(5), the application has failed to
demonstrate that all refuse materials that have been mined will be handled
and disposed of in a manner that will control unsightliness°. The application
has proposed insufficient revegetation and irrigation plans to remedy the
inherent unsightliness (visual impact) of the proposed operations. The
overburden that will be stored as berms wilt not only fail as visual screening
for the operation, but will itself present as essentially unaddressed,
unsightly, weed invRing, wind and water eroding, disturbances.
Reclamation Plan and Rec/amation Costs
l i. :.
Rules "6'.4:5 and 6.4.12 require specific detailed and informative information
and data to be submitted to enable proper public and agency evaluation of
the application. This application fails to supply the required information and
data and must be amended to correct this deficiency. In addition to the
' For dmilar reasons, the appllcatlon also frills to sathfy the mandated grading rs:quiremersts statssd at Rule 3.t.5(n,
uAskh states that "Crading shill be carried on so as to ueate a final topography oppropdate to the fiord land use
selected in the Reclamation Plan.
`Rule &TS(5) provides: The Operator shill set forth the measures thsst vn11 be taken to meat a9 the fo9owing
rtxluirernents: (5) All refuse ._ materials that have been mtrsed sfsoil be handled and disposed of fn a manner that
un71 torstrol unsightliness and protect the drairsage systom from pollution
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