My WebLink
|
Help
|
About
|
Sign Out
Home
Browse
Search
1993-09-20_GENERAL DOCUMENTS - C1981017 (2)
DRMS
>
Day Forward
>
General Documents
>
Coal
>
C1981017
>
1993-09-20_GENERAL DOCUMENTS - C1981017 (2)
Metadata
Thumbnails
Annotations
Entry Properties
Last modified
1/29/2021 4:50:24 PM
Creation date
5/3/2012 9:33:22 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981017
IBM Index Class Name
GENERAL DOCUMENTS
Doc Date
9/20/1993
Doc Name
Vacation of Notice of Violation or Cessation Order
From
DMG
Permit Index Doc Type
General Correspondence
Media Type
D
Archive
No
Tags
DRMS Re-OCR
Description:
Signifies Re-OCR Process Performed
There are no annotations on this page.
Document management portal powered by Laserfiche WebLink 9 © 1998-2015
Laserfiche.
All rights reserved.
/
10
PDF
Print
Pages to print
Enter page numbers and/or page ranges separated by commas. For example, 1,3,5-12.
After downloading, print the document using a PDF reader (e.g. Adobe Reader).
View images
View plain text
SUMMARY OF POINTS <br /> MID-CONTINENT RESOURCES <br /> VS <br /> COLORADO DIVISION OF MINERALS AND GEOLOGY <br /> 97-CV-131-3 <br /> Greg Lewicki, Greg Lewicki and Associates <br /> Michael S. Savage, Savage and Savage, Inc <br /> April 15, 1999 <br /> As reclamation professionals, we have been independently involved in regulation, maintenance, <br /> design, reclamation, and litigation at the Mid-Continent Resources Coal Basin Mines since 1981. <br /> In our current involvement,we serve as consultants to Mid-Continent Resources(MCR)in the above <br /> litigation. Throughout this litigation, previous litigation initiated by the Colorado Division of <br /> Minerals and Geology (DMG), and reclamation proposed and conducted by DMG , we have <br /> identified areas of concern with respect to the conduct of reclamation and expenditure of monetary <br /> resources at Coal Basin by DMG. The following summary briefly, describes our major areas of <br /> concern. <br /> FOCUS OF RECLAMATION <br /> Since the dismissal of the DMG lawsuit filed against individuals of MCR to obtain additional <br /> reclamation funds, DMG has known that the amount of money available for reclamation is <br /> economically constrained. Realizing this, a prudent reclamation manager would focus reclamation <br /> efforts to obtain the most reclamation possible while achieving the most important reclamation goals. <br /> For years the paramount concern at Coal Basin has been erosion control. Therefore, logic would <br /> suggest that reclamation efforts should be directed at achieving maximum erosion control, through <br /> pro-active and long-term measures. DMG has consistently employed measures that thwart or ignore <br /> this objective. The counterproductive measures include the disturbance of relatively stable steep <br /> slopes for the purpose of aesthetics (planting trees), planting of species not conducive to erosion <br /> control, and poor reclamation scheduling (requiring redisturbance of previously reclaimed areas). <br /> By employing a continuing program of these measures,DMG will exhaust all available reclamation <br /> funds vathout having achieved the primary reclamation objective. <br /> RECLAMATION ACCORDING TO THE APPROVED RECLAMATION PLAN <br /> The Coal Basin Mines were issued a mining and reclamation permit under the Colorado Surface Coal <br /> Mining and Reclamation Act in 1981, which was reviewed and approved by DMG. All subsequent <br /> revisions to both the mining and reclamation plan were approved by DMG. As a required finding, <br /> DMG is charged with determining that the reclamation plan is feasible and can be accomplished. <br /> Since DMG took over reclamation at Coal Basin, the agency has consistently ignored the approved <br /> reclamation plan and contended that the agency is not constrained by the legal requirements of the <br /> approved plan or their own regulations. <br /> Reclanzatioiz of"Pre-Law"Localions <br /> DMG has conducted reclamation activities in locations that were disturbed prior to the current <br /> reclamation law. These areas are not required to be reclaimed by MCR if they were not re-affected <br /> by the company in the course of operations after issuance of their permit under the current <br /> I <br />
The URL can be used to link to this page
Your browser does not support the video tag.