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MIX,GVr all la=r-r- VOVQ 111 Vaal l,urVlYn VUIIrL�arr WJ Vvt- <br /> r � <br /> took appropriate action and OSM-APO would take the necessary enforcement actions. <br /> You said Bob Hagen would call me with the status when he returned to the office. (He <br /> has not yet done so.) <br /> I ask that you send me copies of OSM's actions, reversals and any supporting material. <br /> CCC*s Co n . <br /> 1. The site must be reclaimed to the full performance standards; the reclamation plan <br /> cannot be amended to matcb the paltry sums available. (i would note that the permit <br /> cannot be relied on to guide this reclamation because it did not meet the standards with <br /> regard to highwall elimination, accurate identification of pre-law and post-law distur- <br /> bance areas, post-mining land use - the roads - and others_) <br /> 2. OSM has direct responsibility for reclamation on this federal lands mine and cannot <br /> pass the buck to the state. <br /> 3. OSM must pursue reclamation funds from the officers and directors of Mid-Continent <br /> Resources. <br /> 4. Off-site damage must he assessid, repaired and reclaimed; OSM-has not addressed this <br /> and must do so. <br /> 5. All highwalls must be eliminated; there is ample coal refuse material on site to use for <br /> this. <br /> G. if Dutch Creek is relocated, it must be done without using channelization or other <br /> construction methods that do not endure without periodic maintenance and repair. <br /> 7. Downslopes of portal benches and coal refuse piles were disturbed post-law and must <br /> be reclaimed to the full performance standards. <br /> 8. Topsoil used for covering the refuse piles cannot be obtained from beaver dam <br /> meadows on the White River National Forest, as Mr. Lewicki proposed, or from any <br /> wetlands. <br /> 9. Reclamation ezpenditurec must be accurately tracked and not inflated with unrealistic <br /> costs such as Mr. Lcwicki's statement that the $1 million worth of work to be done this <br /> Beason includes $600,000 for the use of equipment on the site. <br /> 10. Reclamation must he overseen by knowledgeable and competent parties; Diane Dela- <br /> ney does not have those qualifications. <br /> 11. OSM must block all individuals and companies on the AVS system_ <br /> 12. OSM must take prompt enforcement actions on all violations and give no deference to <br /> Colorado's bi7.arre interpretation of alternative enforcement. <br /> Acr ynely . Johnson <br /> Program Coordinator <br /> c.c. Bob Hagen <br /> Steve Rnthhun <br /> 2 <br />