2009-04-21_REVISION - M1988044 ‎(3)‎

• Permit No: M1988044
• IBM Index Class Name: REVISION
• Doc Date: 4/21/2009
• Doc Name: Additional Information
• From: SES
• To: DRMS
• Type & Sequence: AR3
• Email Name: JLE
• Media Type: D
• Archive: No

Southwestern
Ecological
Services
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37 East Colorado Avenue • Denver, Colorado 80210-3105 • [phone]
April 21, 2009
Jared Ebert
40 Division of Reclamation, Mining and Safety
Room 215
1313 Sherman Street
Denver, CO 80203
RE: Definition of undisturbed, bonded land to be released from the older permit areas.
Dear Jared:
Enclosed please find some materials that accurately define the undisturbed, bonded land requested for release.
Included is am 11" x 17" map showing the locations of the different categories of land present in this operation,
including the land requested for release. Also included is an 8'/z" x 11" map showing the codes for each parcel that
are used in the acreage accounting sheet on a separate page.
As you can see, there is a total of 43.32 acres included in the request for release of undisturbed, bonded land. The
total affected land to remain bonded is 196.7 acres which includes all land that is currently in use for mining and
processing as well as all land that is being reclaimed. This land will be included in the new reclamation costs and
bonding. In addition to the 196.7 acres a technical revision has been submitted to add the 300 acres in the new
amendment area which will bring the total bonded land to 496.7 acres. At that point all anticipated affected land will
be included in the reclamation bond. Please keep in mind that much of the 138.88 acres in reclamation processes no
longer counts in the 150 acre limitation required by the lease. To be more precise, only areas RC1 (16.69 acres) and
RC2 (12.3 acres) count in the 150 acre limitation. All the rest of the 138.88 acres has been seeded or will be in the
next few weeks. Bond must remain on the seeded acres not included in the 150 acres until it is considered adequate
for release by the Division. Thus the total of areas MN1, MT, RC1, and RC2 is 86.81 acres. That leaves a total of
63.19 acres available for affecting before reaching the 150 acre lease limitation. That is about equal to the entire area
of Area 1U in the amendment that could be disturbed without doing any additional seeding. Of course, in the next
year areas RC1, RC2, and whatever is disturbed in MT will be reclaimed because mining will shift to the amendment
Area 1U. Area MN1 will essentially remain as is until the end of the operation as that includes access and processing.
So area MN1 (43.3 acres) will remain as a fairly constant base acreage of affected, unreclaimed land throughout the
operation. Other affected land and affected land that is being reclaimed will vary from time to time with only
unseeded, affected land counting in the 150 acre lease limitation. It is complicated, to be sure, but this is the only way
to meet both the requirements of the lease and the requirements of the reclamation law without creating problems
with compliance in one or the other or both.
Thank you.
Sincerely,
Mark A. Heifner
cc: Scott Davis