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K2T LLC Linda Saunders and Tena Gallagher, members 34315 Forest Park Dr. Elizabeth, CO 80107 -7842 Emailed to: David Barry, Mike Boulay, Janet Binns, Rob Zuber, Dan Hernandez at janet.binns @state.co.us, rob.zuber @state.co.us, mike .boulay @state.co.us,david.berry @state.co.us, daniel.hernandez @state.co.us Colorado Division of Reclamation Mining & Safety 1313 Sherman St, 4215, Denver, CO 80203 Date: March 17, 2015 RE: Objection to TR 45 Request by EFCI to change the revegetation standards We are sorry that this has taken longer than we had initially planned because of family being out of town, etc. This letter represents all of the Vento property owners. They have each read it and agree anonymously. Please notify each of us that these following points will be considered during the staff review of TR 45. A reclaimed mine must still meet the required reclamation success criteria before the Division can approve a reclamation bond release Even though a mine site may have achieved the minimum liability time period the operator must still provide sufficient data to demonstrate that the reclamation success criteria have been met. Energy Fuels had a lease that ran from March 20, 2000 through March 20, 2002 (A MiningLease VentoProperty 20000320 SignedCopy pdo. EFCI has been on our land for thirteen more years without any lease or any rental payments. It seems premature to be talking about TR 45 when the ten year revegetation analysis from EFCI has not been filed. Are they waiting for this TR change to get approved before writing their final report? Each time throughout the entire past fourteen years when Linda Saunders or I questioned the lack of vegetation on our property. We were told to wait until the final revegetation report to be presented including the comparison of the reference areas with the revegetation. Since we are a family owned property and have no previous experience with how the entire process is done, we just raised our concerns and tried to address them. The mining company needs to inventory the reference areas compared to their revegetation success earlier in the process, not in years ten and fourteen and make their necessary adjustments. We should not have to have waited this long after repeatedly asking for interseeding and replanting of schrubs to be dealing with the change of standards and weighted averages. The problem of not having the Division enforce their requirements is seen throughout our years of reclamation through the eyes of the land owner. One of the first ones was CV -97 -019 when "vegetation monitoring was not conducted as required in 1992, 1993, 1994, 1995, and 1996 on the refuse pile and could not be done since the time had passed so the violation could not be abated." It was hard for me to read this TR 45: Accordingly this Technical Revision is to modify the Vegetation Standards to verify successful revegetation and better enhance the approved Post Mining Land use which is approved for rangeland livestock grazing and wildlife habitat at the Southfield mine. I don't understand how LOWERING the standards could better enhance anything. Any change in revegetation standards in Year 14 of revegetation is not acceptable to the property owners. EFCI asked to change the reference area for the portal in TR40 and that was approved. Now they want to change the standard for the revegetation after 15 years of knowing it would not pass the standards for almost a decade! The Division has reviewed the techniques and standards to judge reclamation success