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1101, <br />COAL <br />s <br />COMPANY .� <br />Alt,Opr-E•PRODUCTION <br />A review of the process surrounding TR -73 provides a straightforward <br />narrative for the chain of events leading to the curve numbers currently <br />utilized as a result of approval for TR -73. <br />During this process, Colowyo provided several alternative paths and <br />mechanisms that would not have applied the pre -mine soil classification <br />(Class Q to reclaimed areas, but the Division insisted that this was the <br />only option that would be approved. Due to the circumstances <br />surrounding drafting TR -73, Colowyo and the Division needed to resolve <br />the issue in a timely manner. Colowyo conceded, and provided the <br />Division with the modified curve numbers currently approved. <br />At the core of this debate, and the reason why Colowyo is seeking "relief' <br />from the elevated curve numbers approved in TR -73 for areas not <br />reporting to the Prospect Pond, is the long -term implications to <br />Colowyo's ability to meet expectations for contemporaneous reclamation <br />of currently disturbed mining areas in the future. <br />A very real and problematic symptom of the elevated curve numbers is a <br />significant reduction in the potential for annual addition of new <br />reclamation areas, as the overall area reclaimed and reporting to a <br />particular pond increases overtime. This phenomenon existed prior to the <br />most recent change in curve numbers, however, previously it did not limit <br />Colowyo's ability to maximize its equipment fleet and manpower <br />resources to minimize our disturbance footprint. Colowyo agrees that it is <br />prudent to reclaim the areas reporting to Prospect Pond over a more <br />protracted time scale, however, applying this concept to the remainder of <br />the disturbance footprint is not a reasonable assertion, given the stability <br />and success of historical reclamation activities in the past, and excellent <br />water quality compliance history. <br />The issues encountered within the Prospect Drainage have been unique to <br />the Prospect Drainage and are not applicable across the balance of the <br />mining operation. <br />Colowyo believes the information submitted to your office on June 25, <br />2012 is a reasonable and necessary modification that addresses the <br />Divisions original concerns and protects the public from potential impacts <br />of designed flows, both physically and from a water quality perspective. <br />A Western Fuels- Colorado, LLC mining property <br />