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John E. Redd, Jr., CPA, P.C. <br />June 27, 2011 <br />Dear Janet: <br />Alt4 2.9 <br />division of Kec larnal on, <br />Mining and Sates! <br />Janet H. Binns <br />Division of Reclamation, Mining and Safety <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />7410 Sandy Lane <br />Mechanicsville, VA 23111 <br />(804) 746-7112 <br />(Fax) 1-888-907-2342 <br />(email) reddcpa @hotmail.com <br />This letter is intended to serve as my written objection to the bond release at the <br />Edna Strip Mine (Permit No. C- 1980 -001). <br />The inspection that was conducted on June 21, 2011 was intended to demonstrate <br />that the operator had conducted weed control measures that proved to be effective in <br />the control of noxious weeds in the bond area. Based on the inspection, I believe it <br />was shown that the noxious weeds have not yet been controlled. The weed spraying <br />contractor advised attendees that his firm had applied chemical, but the effectiveness <br />of the purported spraying could not be verified. The inspection was conducted to <br />"verify" that noxious weeds were under control; according to my observation, the <br />weeds were not under control. We were simply told that the weeds had been <br />sprayed, but we could not observe the effectiveness of the spraying. <br />In addition to the weed control issues, concerns were voiced regarding the <br />beginnings of an erosion problem (wash out) on several sections of the North Road. <br />The road is in the bond area and would appear to me to be the responsibility of the <br />operator. At a minimum, the operator should contract with a road grading contractor <br />(or a rancher with a tractor and a blade) to scrape and crown the road so that water <br />does not continue to erode the road base. <br />I feel that another follow -up inspection is needed to verify that the purported weed <br />control measures have been effective. Also, a follow -up inspection is needed to verify <br />that the operator has remedied the road erosion issues. The bond should not be <br />released on "promises" or "statements" from contractors; the bond should only be <br />released when there are verifiable results that all parties can observe during an <br />inspection. <br />