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2011-01-24_ENFORCEMENT - C1981008 (2)
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2011-01-24_ENFORCEMENT - C1981008 (2)
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Last modified
8/24/2016 4:29:19 PM
Creation date
1/25/2011 9:25:46 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
ENFORCEMENT
Doc Date
1/24/2011
Doc Name
Ten Day Notice Regarding Citizen Complaint with attachments
From
OSM
To
DRMS
Violation No.
TDNX11140182002
Email Name
DAB
SB1
MLT
Media Type
D
Archive
No
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Description: The landowner had gated pipe, furrow, sideroll, traveling big gun and central pivot <br />irrigation before mining. Ms. Turner alleges that the Board, by approving PR -06, said they must flood <br />irrigate after not flood irrigating for 39 years. We interpret this complaint to allege the irrigation plan is <br />not equivalent to the level of management on the land prior to mining. <br />6. <br />State Law / Regulation Potentially Violated: 4.14.2(1) <br />Description: "We cannot irrigate with a sideroll because we cannot grow corn under a side roll and <br />furrow irrigating can never be done again the way they put the land back and all of the sink holes and <br />the ups and downs." We interpret this complaint to allege that the post- mining topography does not <br />approximate the general nature of the pre- mining topography. <br />7. <br />State Law / Regulation Potentially Violated: 2.07.6(2)(a) <br />Description: Complainant alleges PR -6 was all false documentation. Complainant specifically discusses <br />false documentation of soil depth ( "A" lift characterized as 36 inches when it was actually 48, "B" lift <br />characterized as 5 or 6 feet when it was actually over 15 to 25 feet thick). We interpret this complaint to <br />allege the permit revision application was not accurate. <br />8. <br />State Law / Regulation Potentially Violated: 2.04.3(2)(b) / 2.07.6(2)(a) <br />Description: "In PR -06, this documentation is still included and then they give a land use description to <br />state that it is pasturelands. They know for a fact that we do not have any livestock and that we grow <br />straight alfalfa as also documented in the lease that is included in PR -06." We interpret this complaint to <br />allege the narrative description of land capability and productivity which analyzes the land -use <br />description was inaccurate and inadequate. <br />9. <br />State Law / Regulation Potentially Violated: 34 -33 -102 <br />Description: Complainant alleges PR -6 does not protect the landowner or his property and takes away <br />land owner plans and permissions. Fully protecting landowners from the adverse effects of coal mining <br />is a basic premise of the regulatory program for which Colorado has primacy. <br />10. <br />State Law / Regulation Potentially Violated: 4.16.1 <br />Description: Complainant alleges PR -06 does not put property back as good or better. We interpret this <br />to allege the reclamation plan will not restore the property to conditions capable of supporting the uses <br />it was capable of before mining or higher or better uses. <br />11. <br />State Law / Regulation Potentially Violated: 2.04.12(1) <br />Description: Complainant alleges a prime farmland investigation was never conducted and the lack of a <br />prime farmland investigation is documented in PR -06 as well as by the Division itself. The state must <br />
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