GENERAL54214

• Permit No: M1977211
• IBM Index Class Name: General Documents
• Doc Date: 11/4/2004
• Doc Name: Enhanced vs. Permitted Reclamation Plans
• From: Southwestern Ecological Services
• To: DMG
• Media Type: D
• Archive: No

Southwestern
Ecological
Services
L ~ ~~"' '
Vegetation Analysis
~~ Wetland Ecology
/~~/ /
-
Y Land Rehabilitation Planning
/ Photodocumentation
37 East Colorado Avenue
November 2, 2004
Bmce Humphries
Division of Minerals and Geology
l/ Room 215
1313 Sherman Street
Denver, CO 80203
RE: Question regarding Enhanced vs Permitted Reclamation plans.
Pikeview Quarry (M-1977-211) ar: ± Sny er ua:ry ~ - -~
Dear Mr. Humphries:
~ FiECEIVE®
NOV 0 q 2~q
Division of Minerals and Geology
At the CMRF Board meeting on October 29, 2004, a question arose regarding whether the enhanced plans are
included in the permit for these two operations or if not whether they should be. Mr. Scott Davis, CMRF Boazd
member and Vice-President of Schmidt Construction, felt that if the plans are not included then there might be a
question at some time in the future regarding whether the permitted plan was implemented or not Mr. Jerry
Hermann, Vice-President of Castle Concrete, asked me to inquire regarding this matter. As you are, I believe, the
only, person~leftat DMG who went through those sometimes tortuous negotiations to develop the enhanced plans, I
felt.it.most appropriate• thaT.rhis matter,be presented to yourself, in addition io your being the head of DMG's,
Minerals Program.:. - ~ ,~ ,
~. ~ 7:
In my review,Iof the permits on these two operations, there appears to be two different treatments of this question at
this time. I do not believe there is any problem or issue at Snyder. The enhanced plans were included in the 1994
amendment, but as an unbonded overlay plan that was to be implemented on top of the permitted reclamation plan.
Because nothing has really changed from the 1994 situation at Snyder, I would have to assume that the approval of
that amendment addresses this issue and that approval is still applicable today. At Snyder the enhanced and
permitted plans axe well distinguished.
1 Iowever, the situation at Pikeview has now become somewhat different. Originally, the enhanced plans were
included in the same fashion as Snyder, that is, as an unbonded overlay reclamation plan. Since that 1994
amendment at Pikeview though, the situation has changed somewhat. Herein iies the concem regarding Pikeview.
Although elements of the original enhanced plan at Pikeview are still the same and have been implemented
according to plan, a portion of the original enhanced plan for this site has been extensively altered. Most significant
are the changes to the enhanced revegetation for the "Previously Mined Areas" portion of the enhanced plan. Simply
put, the enhanced plan for that area was originally a shotgun seeding approach of loading the area with a seed
mixture that would include most anything and everything that might potentially grow there and would be compatible
with the surrounding vegetation. There wasn't much of anything else that could be done.
Since that•time, this azea.of die enhanced plan has been taken over by the layback plan. The layback plan includes
completely re-mining the "Previously Mined Areas" and implementing a different revegetation plan that is
immensely.more sophisticated than the shotgun approach originally planned. In examining the layback plan,
prepared<by Banks and,Gessg ipappears that portions of the revegetation part of the layback plan were bonded as
.part of_the approval of the layback plan, while other portions may,not have been included in the bond. ',
Unfortunately, this seems to be very.poorly defined in the layback amendment. Herein lies the concern on the part
of the CMRF.
Denver, Colorado 80210-3105 [phone] Fax [phone]
C'rl~iu C...~-C~ C 5