2015-02-19_REVISION - M1977302 - Laserfiche WebLink

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Mr. Beck Page 2 February 19, 2015 the Applicant request a surety reduction for the associated reclamation rather than an acreage release. If the Applicant requests and receives approval of a surety reduction, then the area which has been reclaimed will remain as part of the permitted acreage. The benefit to this option is that the Operator may re- affect this area by posting an increased financial warranty at any time during the life of the mine. If the Applicant requests and receives approval of an acreage release, then area which has been reclaimed will be released from further reclamation responsibility and will no longer be a part of the permitted acreage. Once a reclaimed area has been released from the permit boundary, any disturbance to the area that results from the mining or reclamation operation may result in a possible violation for failure to protect areas outside of the affected land from slides or damage. 3. The Applicant has requested clarification that the existing bond estimate of $1,023,700 is the total bond amount, not what is required in addition to the existing bond amount of $522,500. The financial warranty calculation which has been provided to the Applicant is the total amount required based on the proposed mining and reclamation plans and does not include the existing financial warranty held by the Division. 4. The Applicant has proposed posting a financial warranty in an amount that would allow for up to 130 acres to be affected. The bond estimate of $1,023,700 is based on the existing disturbance at the site. The Annual Report submitted on September 22, 2014 indicated there are 96.86 acres currently affected (mining + incomplete and/or unreleased reclamation) and approximately 30 acres which have been backfilled, graded and seeded. The Applicant has indicated approximately 17 acres have been reclaimed and are ready for release. Please clarify if the 17 acres which have been fully reclaimed were included in the 30 acre estimate. The Division's estimate gave the Operator credit for the 30 acres which had been reclaimed. If there are additional acres which have been reclaimed, the Division will inspect the reclaimed area at the Operator's request in order to determine if the financial warranty may be reduced for reclamation work completed. The Operator should note the required financial warranty will increase if 130 acres are to be affected. In order to calculate a bond estimate for 130 acres of affected land, the Operator must specify how many acres will require reclamation at any given time and the various types of disturbance associated with the affected land. The Division recommends breaking down the types of disturbance into three categories: 1) Fully affected — areas where mining is complete and reclamation has not commenced. 2) Partially affected — areas where partial reclamation has occurred including backfilling and grading. 3) Reclaimed — areas where all reclamation tasks have been completed, including seeding.