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999 <br />March 1 , 1991 <br />Mr. Brent Anderson <br />Parcel, Mauro, Hultin & <br />1801 Ca]ifornia Street, <br />Denver, CO 80202 <br />RE: Grassy Gap Mine, <br />Response Review <br />Dear Mr. Anderson: <br />Spaanstra, P.C. <br />#3600 <br />File No. C-81-039, Bond Release Request Adequacy <br />The Division has completed the review of your adequacy responses submitted on <br />February 21, 1991. Based on our review, we have the following comments: <br />Phase I Bond Release <br />1. Rock castle has amended the map to include permit and disturbance <br />boundaries, title block, and professional certification. However, <br />Rock castle has declined to indicate post-mining topography of Pits 5 <br />and 6. The narrative response speculates as to the Division's motives <br />for requesting this information and then indicates why it is not required <br />and that this is not specifically addressed in Parts IY(1) and (5) of the <br />June 27, 1990 Agreement. However, an accurate depiction of post-mining <br />topography is essential for any Phase I bond release request, regardless <br />of when the reclamation occurred and whether or not AOC is at issue. <br />Following mining, the post-mining topography becomes "baseline" for the <br />next land-use. The Division would be remiss in failing to mairttairt this <br />portion of the public record concerning reclamation results at the Grassy <br />Gap Mine. Irt addition, as indicated by the copy of the coal handbook <br />memorandum provided to you previously, this information is a standard <br />requirement pursuant to 34-33-125 and Rule 3.03. Please note that in <br />Part V of the June 27, 1990 Agreement, Rock castle agrees to request bond <br />release in accordance with Rule 3.03. <br />Rule 3.03 and 34-33-125 both indicate that the applicant must include "a <br />description of the results achieved...". It is the Division's opinion <br />and policy that topographic mapping and cross-sections are the <br />appropriate descriptions for back filling and grading results. There is <br />no substitute. Therefore, we respectfully reiterate our request that <br />topographic mapping and cross-sections be provided for Pits 5 and 6. <br />