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GORHAM ENERGY CONSULTANTS LLC <br />January 13, 2016 <br />Rob Zuber <br />Colorado Division of Reclamation, Mining, and Safety <br />1313 Sherman St, Rm. 215 <br />Denver, CO 80203 <br />Re: Adequacy Responses #2 (question #3), SL -03 Bond Release Request <br />Dear Mr. Zuber: <br />Please find enclosed EFCI's adequacy response to question #3 of your letter dated January 8, 2016. <br />DRMS question: <br />3. The Division understands that the reference to Attachment I was a mistake; no additional <br />response required. Regarding EFCTs explanation as to why the LS factors for the <br />reclaimed areas and the non -mined areas are identical, the Division still believes that is <br />best to assess the LS parameter separately: the post -mining condition should be based on <br />the current topography of the areas where bond release is sought, whereas the pre - <br />mining condition should be based on the pre -mining topography of the actual location of <br />the RDA and facilities area or on the topography of adjacent unmined areas. Also, Map <br />13 and 29 are referenced in the sediment demonstration for the mine site; however, these <br />maps are related to the loadout. Please correct this error. <br />EFCI Response: <br />EFCI revised the sediment demonstrations for the mine site, specific to the RDA in accordance <br />with suggestions from the Division, and is using Map 33 to obtain topographic information for <br />the demonstrations rather than Maps 13 and 29. Text corrections have been made as necessary. <br />The representation of the formula for the LS factor has been corrected for slopes greater than <br />9%. Revised sediment demonstrations are included. The loadout demonstration was corrected <br />to reflect the proper formula with no changes to the calculations required. Additional sediment <br />demostrations were conducted and included as an addendum (text and tables) to the original <br />demonstration. Supporting calculations for the LS factor and the cover factor for the RDA only <br />are also included. <br />Please review and feel free to call or email if I can answer any further questions. <br />Sincerely, <br />Kent A. Gorham <br />