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February 16, 2016 <br />Mr. Rob Zuber, Reclamation Specialist <br />Colorado Division of Reclamation Mining & Safety <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Permit: Energy Fuels Coal, Inc. Permit number: C-81-014. <br />RE: Bond Release Field Review (Erosion) <br />Dear Mr. Zuber, <br />Your question is italics and my answer follows. I included the text that you have paraphrased. <br />In your letter, you make the following statements (I have paraphrased a bit). <br />1. The sediment demonstration report incorrectly and selectively applies vegetation cover in the <br />sediment demonstrations (second paragraph on second page). <br />2. The analysis used specific portions of the permit area with the greatest vegetation cover, in <br />particular the portion of the analysis that focuses on the RDA (This is also on page 2.) <br />Can you tell me if your first statement entails more than the content in the second statement? If <br />so please elaborate. <br />Thanks for any clarification. <br />Rob <br />This is the complete statement (1) above: <br />The sediment report has failed to demonstrate any true sediment analyses, failed to adequately <br />compare reclaimed and non -mined lands (or pre and post mine conditions), failed to use the best <br />available information, incorrectly and selectively applied vegetation cover in the model <br />demonstrations, failed to provide, discuss, or demonstrate RUSLE model assumptions, or <br />violations of these assumptions, which resulted in a conclusion that cannot be defended based on <br />the data and the explanation provided in the report. <br />The complete paragraph referencing the RDA above (2): <br />As an example, the Addendum states it is a supporting analysis specific to the length slope (LS) <br />factor and the sediment demonstration for the mine site. The demonstration only examines the <br />RDA and surrounding area, not the mine site as a whole (46% of the reclaimed area). By <br />specifically selecting the RDA, Mr. Gorham chose a best case scenario in which to demonstrate <br />LS. The reclaimed RDA happens to have the greatest recorded vegetation cover compared to <br />any other reclaimed land or to any of the three reference areas. In addition, averaging the gentle <br />slope of the top of the RDA and the steep slopes of the RDA also provides best model results for <br />this area, as does averaging all model output values. <br />