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Ill I11111llllllllll <br />C c~sus <br />"~ i3mpire Corporation <br />February 1, 1993 <br />Kent A. Gorham <br />Office of Mined Land Reclamation Division <br />Division of Minerals & Geology <br />215 Centennial Building <br />1313 Sherman Street <br />Denver, Colorado 80203 <br />P.C. Box 68 <br />Craig, Colorado 81626 <br />303-824-8246 <br />~~~~~ <br />~,~T <br />FFB~ 3 ~;~ <br />~i~NFgq~SS~~~ 1993 <br />~ GEC` <br />~~Y <br />RE: Permit Revision 03, Alternate Land Use Adequacy Response <br />Permit C-81-071 <br />Dear Mr. Gorham: <br />The following responses are provided in answer to concerns raised <br />in your 11/18/92 adequacy review. These responses are numbered the <br />same as the original questions or comments in your 11/18/92 letter. <br />I believe there is one typing error in your adequacy review letter. <br />The correspondence from T. Johnson (CYCC) to K. Gorham (DMG) is <br />dated 9/14/92 not 10/14/92. <br />The following are CYCC's responses. <br />1.) CYCC disagrees with the Division regarding consideration that <br />should be given to land ownership. The Division's regulations, the <br />Act and OSM regulations all require landowner consideration; <br />Section 4.16.3 "Alternate land uses may be approved by the Division <br />after consultation with the landowner" and Section 2.05.5 (1)(a) <br />(iii) "The consideration which has been given to making all of the <br />proposed surface coal mining and reclamation operations consistent <br />with surface owner plans and programs;". Although land ownership <br />is not a serious concern at this time and although land ownership <br />may be outside the jurisdiction of the Division, CYCC does not <br />understand how the Division can claim it is not germane to the <br />issue and then ask under Item 6 what lands CYCC controls. From <br />discussions with the Division, it appears this question was asked <br />to determine how much of the existing woody plant dominated <br />habitats within a five mile radius could be protected. If the true <br />issue is to prevent or mitigate adverse impacts to fish and <br />wildlife, then anything that impacts wildlife both negative and <br />positive is pertinent to the issue. <br />2.) There appear to be thr~i3 general topics or concerns identified <br />under item 2. These are value of the reclamation to 1) elk, 2) <br />raptors, and 3) wildlife in general. <br />