2010-01-22_REVISION - C1981008 (2)

Home Browse Search

C-1981-008 PR-06 PAR 22-Jan-2010 Page 2 of 26 The PR-06 application has been reviewed by the Division for preliminary adequacy with respect to the Regulations of the Mined Land Reclamation Board (Rules). Our comments are itemized on the following pages, for your consideration and response. Rule 2.03.4 - Identification of Interests 1. The Division has conducted the initial AVS Check and Evaluation for this Permit Revision. There are differences between Section 2.03.4 (last updated for MR-75 in November 2008) of the permit and AVS information obtained for Tri-State Generation & Transmission Association. Please update Section 2.03.4 to reflect the current officers and directors for Western Fuels-Colorado, LLC and Tri-State Generation & Transmission Association. Rule 2.03.6 - Right of Entry and Operation Information 2. The PR-06 application requests that the Permit Area for the NH 2 Mine be increased by 3.88 acres and requests an increase to the Disturbed Area of 2.4 acres. Numerous revised maps were submitted with the application, illustrating the proposed permit boundary and disturbed area. However, the accompanying legal description, found in Attachment 2.03.8-1, has not been updated. Please submit a revised Attachment 2.03.8-1- Legal Description which describes the proposed new permit boundary. Rule 2.04.3 General Requirements: Site Description and Land Use Information WFC has identified the following pre-mining land uses in the revised application: Cropland- Irrigated Orchards (ICO); Cropland-Irrigated Alfalfa Hay (IC); Pastureland-Irrigated Hay (IPH); Pastureland-Irrigated Grass (IP); Pastureland-Irrigated Swale(IPSW); Rangeland-Sagebrush (SG); Pinyon-Juniper (PJ); Rangeland-Deciduous Trees (DT); Commercial-Roads(R); Floodplains (FL); Residential-Farmsteads (F); Residence-Open Space Areas (D) and Developed Water Resources-Ponds (P). The abbreviations are used on revised Map 2.04.3- Pre-Mine Land Use Map. 3. The introductory land use discussion in subsection 3.0 of Section 2.04.3 contains some discrepancies that need to be clarified. This section makes reference to the Irrigated Pasture and Irrigated Swale pre-mine land use categories depicted on Map 2.04.3, but does not reference or summarize the Pastureland-Irrigated Hay category. It may be that the term "Irrigated Pasture" as used in some contexts is meant to be inclusive of both Pastureland-Irrigated Hay and Pastureland-Irrigated Grass, but this is not entirely clear. WFC has re-designated 25.02 acres of lands currently labeled irrigated cropland as irrigated pasture. Toward the end of revised section 3.0 WFC states "...two areas of