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Tabetha Lynch, DRMS <br />Page 2 <br />June 8, 2016 <br />2.04.11 (1)-(4) Fish and Wildlife Information <br />No adequacy review comments. The Threatened and Endangered species discussed in the permit are <br />accurate and up to date. <br />2.05.4(2)(b) — Reclamation Cost Estimate <br />I have conducted a reclamation cost estimate for the site and found that the liability to reclaim the <br />Keenesburg Strip Mine to be $1,183,605:84. The required surety and currently held surety is <br />$1,197,459.85. Given this, the bond held is adequate at this time. Attached is a copy of the reclamation <br />cost estimate conducted, it includes a Cost Summary, Task Summary and CIRCES task sheets. Please let <br />me know if you or the operator have questions. <br />2.05.6(2) Mitigation of Impacts of Mining — Fish and Wildlife Plan <br />No adequacy issues noted. <br />4.03.1(7), 4.03.2(7), 4.03.3(7) — Road Reclamation <br />Page 103 indicates the main access road to the site will be a permanent feature. Page 106 indicates all <br />roads within the disturbed area by mining and reclamation will be removed. However, the Appendix Q-1 <br />Map shows the final Reclamation Contour and Drainage Plan for the site and several of the interior access <br />roads are depicted on this map. Portions of the interior access roads that travel north and west around the <br />A-3 topsoil stockpile and, south and west around Area 25 and the Long Term Spoil Pile are depicted on <br />the Appendix Q-1 Map. Given the permit text on Page 106 and this map, it is unclear if CEC intends to <br />reclaim these interior roads. In accordance with Rule 2.05.4(2), CEC must have a reclamation plan for <br />the roads at the site. This reclamation plan for the interior access and light duty roads needs to comply <br />with Rules 4.03.2(7) and 4.03.3(7). I recommend the following adequacy item be addressed: <br />• The operations plan indicates the interior access roads will be removed and reclaimed (page 106 <br />of PAP), however the Appendix Q-1 map depicting the reclamation contours at the site depict <br />portions of these road remaining after site reclamation. Please update the Appendix Q-1 Map to <br />depict the post mine topography of the site with the interior access roads reclaimed. <br />4.06.1 to 4.06.5 — Topsoil <br />The site is in final reclamation and all topsand removal has occurred and the remaining topsand at the site <br />is stockpiled and is slowly utilized for reclamation as B -Pit is slowly backfilled and graded. Section 2.05 <br />of the permit contains details on the amount of topsand available for reclamation in each topsoil stockpile <br />and specifics on the uniform topsand depths to be replaced on the affected areas of the site. I have no <br />adequacy concerns at this time. <br />