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The Division conducted a midterm review (MT -7) of the Foidel Creek Mine permit in 2015 <br />and a midterm review document was provided to the operator on November 23, 2015. <br />During the MT -7 review, the reclamation cost estimate was reviewed and updated. The <br />Division estimated the liability at the Foidel Creek mine to be $10,553,208.47. Since MT -7, <br />the Division has approved a minor revision (MR -291) which also increased the reclamation <br />liability at the site. On January 6, 2016 the Division initiated a bond adjustment/surety <br />increase revision (SI -2) and sent TC a notification letter of the proposed bond adjustment. <br />This letter indicated the Division believed the reclamation liability at the site was <br />$10,577,589.57 based on the reclamation cost estimate conducted for MT -7 and the approval <br />of MR -291. <br />Subsequent to the January 6, 2016 letter, TC requested to have an informal conference to <br />discuss the proposed bond adjustment and requested that the informal conference be held at <br />the end of February. On February 16, 2016 the Division updated the unit costs used in the <br />Division's cost estimating software (CIRCES). This was a program wide update. Division <br />management requested that the reclamation cost estimate for the Foidel Creek Mine be <br />updated using the new unit costs since SI -2 had not been finalized. This was discussed with <br />TC and it was agreed the informal conference would be delayed until the beginning of <br />March, 2016 in order for the Division to update the reclamation cost estimate and for TC to <br />review the new estimate. Using the updated unit costs, the Division estimated the <br />reclamation cost for the site to be $10,652,504.29. This amount does not reflect any bond <br />release for reclamation work completed by the operator (2.07.6(2)(k)). <br />11. The Division has made a negative determination for the presence of prime farmland within <br />the permit area. The decision was based on the publication "Important Farmlands Inventory <br />of Colorado" USDA, Natural Resource Conservation Service (formerly SCS), Denver, <br />Colorado, October 1982. It states that no prime farmland mapping units are found within the <br />permit area or within Routt County. The local office of the NRCS confirmed this finding in a <br />letter dated September 24, 1984. This letter can be found in Exhibit 24 (2.07.6(2)(k)). <br />12. Based on information provided in the application, the Division has determined that alluvial <br />valley floors (AVF) exist within the permit or adjacent area. The alluvial valley floors are <br />known as the Fish Creek AVF, Foidel/Middle Creek Confluence AVF, and the Trout Creek <br />AVF. Based on information provided by the operator, the Division finds that for all the <br />above AVF's: <br />a) The proposed mining operation will not interrupt, discontinue, or preclude farming <br />on the alluvial valley floor. Cattle's ranching on undeveloped rangeland is the only <br />agricultural operation currently in practice in these portions of Fish Creek. Rule <br />4.24.3(1) allows for impacts to undeveloped rangelands which are insignificant to <br />farming. The operator has submitted information that the acreage to be affected is <br />of small acreage relative to the ranches. Previous subsidence of Fish Creek in the <br />Northern Mining District found that ranching was not precluded or diminished on <br />the affected area. <br />b) The proposed mining operation will not cause material damage to the quality and <br />quantity of surface and groundwater that supply the alluvial valley floor. Additional <br />Foidel Creek Mine 28 February 25, 2016 <br />