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The Corley Company <br />2605 Constellation Drive <br />Colorado Springs CO 80906 <br />June 4, 2013 <br />Ms. Janet Binns RECEIVED <br />Environmental Protection Specialist III JUN, Q 6 ?113 <br />Colorado Division of Reclamation, Mining and Safety <br />" "�TION` <br />1313 Sherman Street, Room 215 <br />r� <br />Denver, CO 80203 <br />Dear Janet, <br />Yes, you sent us the maps on May 21, 2013. The Mine Area Vegetation map dated 11 -10 -89 has an <br />unknown and unspecified coordinate grid. The Southfield Mine Portal Reference Area 2009 Aerial Photo <br />has no coordinates and the photo is four years old. It appears to be a satellite photo because of the lack <br />of definition. I am unable with my GPS equipment to convert a PDF file to ground coordinates or to <br />georeference that picture to the ground. Since the proposed location is adjacent to pre -law disturbance <br />it would seem to be important to delineate this reference area with more precision than scaling from a <br />photo map. Never the less, I don't think it is your responsibility to have to inform us about the locations <br />of the veg reference areas. EFCI should be the party to give us those exact locations, particularly since <br />we have asked for locations for about a year. EFCI has apparently chosen to try to keep us uninformed. <br />Even in the past few days EFCI has not answered written questions such as how the new veg area might <br />be delineated or why the new veg area is advantageous to EFCI. This last question is very important. <br />EFCI has told us that they would never be able to meet the old reference area standards. You have told <br />us that the new area would be more stringent, and we respect your opinion. But I cannot believe that <br />EFCI would request to be held to a higher standard. Why would they have spent so much time, effort, <br />and money just to have to meet a higher standard? <br />Therefore, if a formal hearing with the Board is necessary to sort out these issues I will try to comply <br />with Rule 2.08.4(6)(b)(iii). I believe that The Corley Company portal reclamation will be adversely <br />affected by the proposed switch to a new vegetation reference area. Issues to be raised at the Board <br />hearing include: <br />1. How was the proposed area delineated on the maps provided? <br />2. How will the mapped delineation be transferred to the ground? <br />3. How will the very complicated polygon consisting of mostly curves be marked on the ground? <br />4. If the new reference area is more stringent why does EFCI want to be held to higher standard? <br />5. If the new reference area contains essentially trees how will this area be used as a standard for our <br />portal reclamation for which there were no deliberately introduced trees? <br />Sincerely, <br />W.D. Corley, Jr. <br />Pres., The Corley Co. <br />