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OF A <br /> N p DEPARTMENT OF NATURAL RESOURCES <br /> ,Fy * David H.Getches,Executive Director <br /> MINED LAND RECLAMATION DIVISION <br /> \�87�/ DAVID C.SHELTON, Director <br /> r <br /> Richard D.Lamm <br /> Governor <br /> v <br /> GATE: July 14, 1986 <br /> TO: Candace Thompson <br /> FROM: Jeffrey Deckler <br /> RE: MID-CONTINENT MID-TERM BOND RESPONSE <br /> I have completed my review of the above referenced submittal . In this <br /> response, the operator identified six (6) issues which they felt needed <br /> clarification. My findings, which are included below, are formatted to <br /> address each of these issues. These findings also reflect our meeting with <br /> the operator of July 9, 1986. <br /> I. Verification of Disturbed Acreage. <br /> The operator has presented evidence that the original calculations of <br /> disturbed areas included in the permit are in error, and that the total <br /> surface disturbance is 283.3 acres rather than 432 acres. However, no <br /> discussion concerning how the limits of the disturbance were calculated was <br /> included in the submittal . Specifically, the division requires information as <br /> to whether outslope disturbance created by downspoiling on mine benches and <br /> roads was included in the measurements. These areas must be included at least <br /> with respect to revegetation costs. The Division is prepared to accept a new <br /> estimate for the disturbed acreage upon clarification of the estimating <br /> method. The operator has expressed his intent to supply the required <br /> information. <br /> II. Backfilling and Grading, and the Application of Approximate Original <br /> Contour (AOC) Requirements. <br /> Two issues concerning AOC are addressed in the Mid-Continent submittal . The <br /> operator contends that; (1 ) a variance from AOC requirements has been granted <br /> by the Division, and therefore, (2) AOC requirements should not be considered <br /> in the bond calculations. <br /> First, it must be noted that although a variance for steep slope mining was <br /> granted, it was approved with stipulations. These stipulations require the <br /> submittal of stability analyses and detailed reclamation plans for the <br /> applicable surface disturbances (mainly haul roads and mine benches). To date <br /> the Division has not received this information, as the operator is in the <br /> process of a continuing study which will not be completed until December, <br /> 1987. Until a specific reclamation plan is proposed by the operator and <br /> approved by the Division, bonding cannot be based on the current proposal from <br /> the operator, which does not include backfilling and grading. <br /> 423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. (303) 866-3567 <br />