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COLORADO <br />Division of Reclamation, <br />Mining and Safety <br />Department of Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />October 3, 2014 <br />George Patterson <br />Energy Fuels Coal, Inc. <br />P.O. Box 459 <br />Florence, CO 81226 <br />Re: Southfield Mine (Permit No. C- 1981 -014) <br />Technical Revision No. 41 (TR -41) <br />Relocate Vegetation Reference Area. <br />Dear Mr. Patterson: <br />The Division has reviewed EFCI's application for technical revision No. 41for the Southfield <br />Mine. Energy Fuels Coal Inc. provided additional information on September 2, 2014, and <br />September 8, 2014. <br />EFCI provided a letter from the surface landowner with a statement that the landowner does not <br />object to use of the surface for a vegetation reference area, and that the land owner, Adamic family, <br />has no plans to disturb this property in through 2015. This information was requested in the <br />Division's letter, dated May 5, 2014. This submittal adequately addresses Rule 4.15.7(3). <br />EFCI provided a detailed discussion of the Soil Resource Information based upon Map 15 in the <br />PAP. EFCI also provided vegetative cover and herbaceous production values from 2013 <br />sampling of the proposed load out reference area. EFCI provided a discussion relating the <br />dominant soil complex to NRCS Range Site descriptions based on the NRCS Soil Survey of <br />Fremont County. This discussion provides a good description of the comparability of the soil <br />conditions, slope, dominant aspect and elevation as outlines in the DRMS Guidelines for <br />Compliance with Land Use and Vegetation Requirements. It also helps describe the dominate <br />vegetation type. Rule 4.15.7(4)(c) states that when 4.15.7(3)(b)(ii) is applicable, reference areas <br />may be based upon comparison of a specified ecological site based on soil, elevation and <br />topographic characteristics with a corresponding site on the revegetated surface. <br />This discussion addresses Rule 4.15.7(4)(c) for the grassland community at the load out. <br />The proposed Load Out reference area comprises 1.02 acres. Although this is less than the <br />recommended 3 acres in size, the Division concurs that this is the largest continuous undisturbed <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http: / /mining.state.co.us <br />John W. Hickenlooper, Governor I Mike King, Executive Director I Virginia Brannon, Director <br />Off' 0410 <br />0 <br />� rt <br />* <br />1876 <br />