2009-05-14_REVISION - C1980007 - Laserfiche WebLink

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To receive processing of the drilling of the geotechnical boreholes as a Minor Revision, please remove the reference to the proposed temporary access road and to the proposed borehole into the Oliver Mine. MCC should consequently submit a separate application for a Technical Revision for these two other activities. Please feel free to contact me directly at 303-866-3567, extension 8126, if you would like to discuss this personally. Should you wish to discuss this matter with Coal Program Supervisor David Berry, I'm sure he would be willing to listen. Daniell. Hernandez Daniel I. Hernandez Senior Environmental Protection Specialist Colorado Division of Reclamation, Mining and Safety 1313 Sherman St, Room 215 Denver, CO 80203 New Phone Number: 303-866-3567 ext 8126 Fax: 303-832-8106 Website: www.minina.state.co.us From: Welt, Kathy [mailto:KWelt@archcoal.com] Sent: Friday, May 08, 2009 10:14 AM To: Kaldenbach, Tom Cc: Hernandez, Daniel; Nolte, Doug; Sweetwood, Ryan; Nyikos, Chris Subject: MR 354 - Geotech Boreholes Tom, I received your phone message in regard to MR 354 late yesterday. From that message I understood you to say that after talking to Dan that because roads are proposed, this application must be a TR, and that BLM needed to be contacted for approvals in accessing coal. I left you a brief phone message in response saying that the BLM need not be involved, as both the coal and surface land ownership is Mountain Coal (MCC), and that I would follow-up today in regard to a TR (a 50-day minimum process) being required due to temporary access being cleared and/or constructed to four of the 8 to 10 proposed borehole sites. As I said, both the surface and minerals in this location are owned by MCC, so there is no need to contact the BLM. In addition, these are soils sample and geotechnical investigation boreholes - not coal exploration or MDW sites. The total length of these soils investigation activities, including reclamation, will be no more than three weeks time - less than half of what a TR process would require. I've reviewed MCC's permitting files and found at least six geotechnical and soil sampling borehole projects proposing up to 230 boreholes, with more than 70% of these sites requiring temporary access such as proposed in this application, that were reviewed and approved as MRs. These were MR189, MR210, MR218, MR244, MR 245, and MR247. I found that no TR applications have ever been required for these temporary, small-scale soils and geotechnical evaluations. I am certain that similarly, our mining neighbors to the east (including my own permitting experience with them), has been that these soils investigation projects fit within the MR criteria. The proposed temporary access to the four sites will be field-fit by an experienced earthwork contractor (Chesnick Construction) who has more than 40 years of road pioneering experience, the past 14 years being on MCC's projects (including access to the boreholes the MRs mentioned above). No drainage structures (like culverts) are anticipated either, as "Tweety" Gulch (aka Unnamed Gulch) is typically dry. I recognize that I have not been directly involved in the more visible and controversial permitting activities that both MCC and the CDRMS have had to endure over the past few years, but this project has no similarity or relation whatsoever to those applications (again, this is not a coal exploration or MDW application, nor on public lands), processes or subsequent (and in some cases, continuing) issues. As for "transparency" or public review, I am aware that both the town of Paonia and WSERC