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2013-03-12_REVISION - C1981008
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2013-03-12_REVISION - C1981008
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Last modified
8/24/2016 5:14:50 PM
Creation date
3/18/2013 2:08:22 PM
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
REVISION
Doc Date
3/12/2013
Doc Name
Comments (Faxed)
From
JoEllen Turner
To
DRMS
Type & Sequence
SL14
Email Name
SB1
DAB
MLT
Media Type
D
Archive
No
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three consecutive years and the results are higher off the reclaimed areas than what exist in the <br />reference area. These properties will continuously decline in production in the years because of <br />the regulations governing pasturelands. If it were croplands as they were pre -mine, then they <br />could plow up those fields and revegetate them without starting the time clock over, but because <br />they are pasturelands this cannot occur and the vegetation gets worse every year as well as the <br />production. This is not WFC's fault, this is the rules and also what the State approved from the <br />beginning. The farmers do not want their fields to look like the reference area which also cannot <br />be revegetated without starting the time clock over. This field was chosen without proper <br />expertise , but the reclaimed areas should not have to match the reference area which does not <br />and has never had the alfalfa seeding or production that the reclaimed areas have. The reclaimed <br />areas far exceed the reference area. The State nor the Mine were farmers nor did the State have <br />any personnel checking the reference area and understanding vegetation as was needed. But <br />don't punish the landowners for the shortcomings of others. Bond release has been requested by <br />several landowners and we even wrote letters several years back requesting that bond release be <br />given. WFC has done all that they can do on these properties requesting phase three bond release. <br />They have been very productive in the past and as good in production as pre -mine. There are <br />sink holes and production will decline as time goes on. The farmer will get their property hack <br />and plow it up and reseed and then get their production again, but the way the rules are set up <br />governing pasturelands, this cannot happen until bond release is granted. Let the farmers go back <br />to farming that know how to farm and get their lives back. <br />This is not right for the State to continue keeping these properties and not give them back to the <br />landowners. When we lease lands to the mine, it is with an agreement and understanding that in <br />the last three years of reclamation which is the 8th, 9th, and 10th years that the production will be <br />calculated and then in the 10'" year bond release will be given. The 10 years have come and <br />passed almost twice now, this isn't right. These are the rules and regulations. If Bond release is <br />not going to be achieved or WFC is doing something wrong, then they should be told before the <br />time for bond release so they can correct those things and still get bond release, not wait until all <br />the property owners are waiting to get their property back and then deny the bond release. <br />This makes it very hard to even consider leasing the mine property to mine coal if the landowners <br />are never going to get their land back. It does not do the State any good to deny bond release <br />when the properties cannot get better with age, they only get worse. These properties should <br />have gotten phase three bond release years ago. The State should have been on top of these lands <br />from 1992 on, not now that everyone is waiting to get their lands back. Some landowners have <br />already died waiting to get their property back and never being able to farm it again because they <br />didn't get bond release as they were told prior to mining. None of this is right. <br />You are also LUMPING all the individual landowners properties together. This isn't right. This <br />is also not a rule or regulation that allows for you to do that. Each place and each landowners is " <br />site specific" and each landowner should be consulted with and if his property meets the <br />production standard and he agrees to sign off on it, then bond release should be given. The time <br />frame has been completed, the vegetation study has been done, and the landowner wants his <br />property back. The State should have been on top of these discrepancies from day one and <br />should have been giving specific instructions on what they needed to do, but don't punish the <br />Z' d Z99L - 0L 6 <br />aewnl uell3or <br />
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