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2011-06-21_APPLICATION CORRESPONDENCE - C2010088
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2011-06-21_APPLICATION CORRESPONDENCE - C2010088
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Last modified
8/24/2016 4:34:43 PM
Creation date
6/22/2011 9:31:52 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C2010088
IBM Index Class Name
Application Correspondence
Doc Date
6/21/2011
Doc Name
Adequacy Review No. 2
From
DRMS
To
CAM Colordo, LLC
Email Name
MPB
SB1
Media Type
D
Archive
No
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Corey Heaps <br />CAM Colorado LLC <br />June 21, 2011 Page 4 <br />provide opportunity for CDPHE/HMWMD to review and provide comment on the <br />proposed operations and reclamation plan upon submittal, to confirm that such plans do not <br />require any action from HMWMD. <br />CAM Response: Unsuitable subgrade material will be excavated and placed in pond 6 as <br />shown on Map -16. Two feet of material will be placed on top of the unsuitable subgrade <br />material. Please see revised page 2.04 -12. <br />Division Response: Response accepted. <br />The boundaries of the designated premine and postmine land use types identified on Map 7 <br />and described in the narrative of Sections 2.04.3 and 2.05.5 require further clarification. <br />The map does not contain clear boundaries separating the land use types. Narrative in the <br />two sections contains some contradictions as well. Please amend the narrative sections and <br />map to be internally consistent, and revise the map to clearly delineate boundaries between <br />the designated land use types. Separate maps for premine and postmine land use may be <br />warranted for clarity, if the land use boundaries or categories differ between premine and <br />postmine. For example, if premine management of all or a portion of the non - industrial <br />part of the permit area included livestock grazing, the appropriate designation would likely <br />be combination Rangeland/Wildlife Habitat, but if planned postmining use would not <br />include livestock grazing, the appropriate designation would be Wildlife Habitat. <br />We presume that premine and postmine land uses for all areas to the east of Reed Wash <br />within the permit area are identified as "Industrial ", as stated in the narrative, based in part <br />on the Mesa County land use classification. However, for the purposes of the DRMS <br />permit and associated reclamation requirements and standards, it may be appropriate that <br />the boundary between "Industrial" and "Fish and Wildlife" land use be defined by the <br />perimeter of the lands that have been physically disturbed by past industrial activity. Given <br />that the soils and vegetation conditions, and reclamation practices within the currently <br />undisturbed greasewood habitat on either side of Reed Wash are the same, it would seem <br />logical that land use (and associated reclamation success standards) should also be <br />consistent. Please give this matter consideration and either define the Previously Disturbed <br />Lands perimeter as the land use boundary, or provide justification for inclusion of the <br />undisturbed greasewood habitat east of Reed Wash as "Industrial ". <br />CAM Response: Typo corrected on page 2.04 -2, changed Reed `Gulch' to Reed `Wash'. <br />Page 2.05 -40, changed land use types east and west of Reed Wash. Map -07 has been <br />revised to show a clear delineation between industrial and fish & wildlife land use types on <br />the east side of Reed Wash. Page 2.04 -1 removed the `commercial' land use type as it is <br />not applicable to the DRMS permit, the type was used based on Mesa County land use <br />types. 'Rangeland' was added as a land use type on page 2.04 -1. <br />Division Response: The content of this item has been resolved; however, the Division <br />requests that CAM update Map -07 to more clearly delineate between Fish & Wildlife and <br />
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