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~cTnTr nF rr~1 nannr~ • • Roy Romer, Governor III IIIlillllllll III DEPARTMENT OF NATURAL RESOURCES DIVISIC)N ®F WILDLIFE 999 AN EQUAL OPPORTU NIiY EMPLOYER Perry D. Olson, Director 6060 Broadway Denver, Coloradc 80216 Telephone: (303)297.1192 3 October 1990 Mr. S1:even Renner Reclamation Specialist Mined Land Reclamation Division 1313 :>herman Street, Room 215 Denver, CO 80203 SUBJ: Mined Land Permit No. M-90-112; State Pit Dear ~~teve: 0.EFER i0. I l ~.c i OCT 0 9 1990 Mined Land Reclamation Division F'e have reviewed the above referenced application for a 112 permit and offer the following comments. The application, as written, is confusing and ambiguous regarding the mining plan and reclamation plan. It is unclear, as stated, how reclamation shall proceed since the bond amount was based upon reclaiming only 60 acres of the 755 acres indicated as being affected by mining. However, after a conversation with Dan Hernandez, it is my understanding that the applicant has proposed the use of a "floating" bond which will cover 60 acres at a time with reclamation being performed as mining proceeds. If that is the case then the Division recommends bond be set based upon the cost of reclaiming 180 acres. In that way, sufficient time will be given to allow establishment of vegetation on the first 60 acre parcel when applicant wishes to move the mining process off of the second 60 acre parcel into the third 60 acre parcel. We believe this to be especially prudent due to the local climatic conditions that e:tist in the Pueblo area with regard to precipitation, wind, and ambient temperature. These conditions make it especially difficult for revegetation efforts and as such may require additional time for establishment of adequate stands of vegetation. This proposal would seem especially advantageous to the applicant in tha~= it would allow them to proceed with mining of the 121st acre even if reclamation on the first 60 acre parcel does not meet MLRD standards. This methodology also would address our Concerns regarding a local herd of antelope utilizing this site and adjacent areas. Although the life of the mine is expected to be 30 years a minimum number of acres will be affected at any one time since reclamation will proceed with the mining operation allowing contincled use of different portions of the site by antelope. DEPARTMENT OF NATURAL RESOURCES, Hamlet J. Barry, Executive Director WILDLIFE GOMMISSIOIJ, George VanDenBerg, Chairman . Robert L Freidenberger, Vice Chairman . William R. Hegberg, Secretary Eldon W. Cooper, Member . Rebecca L. Frank Member o Dennis Luttrell, Member . Gene B. Peterson, Member . Larry M. Wright, Member