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M-2016-030,Response to Adequacy Letter <br /> 8 November 2016 <br /> Page 7 of 10 <br /> The Division recommends the Applicant contact the local weed control authority to assist with the <br /> weed control plan. <br /> The scope of Rule 3.1.10, including Rule 3.1.10(6), is understood to encompass revegetation as part of the <br /> Reclamation Plan. Reclamation activities will not commence until Year 2, at the earliest (and this may initially <br /> only include backfill and grading). All areas revegetated for the purposes of reclamation will be monitored in <br /> accordance with Rule 3.1.10(6). <br /> In addition, the operator will generally comply with noxious weed control protocols, as required by Colorado <br /> law. A noxious weed control plan addressing the Division's comment in item 11 is attached for your <br /> reference. <br /> 12. The Applicant states a SWSP will not be required until the groundwater is exposed. Please commit to <br /> providing the Division a copy of the approved SWSP when available. <br /> Upon issuance of an approved SWSP,the Applicant/Operator will timely provide a copy to the Division. <br /> 13. Please commit to obtaining a Gravel Pit Well Permit from the Colorado Division of Water Resources <br /> prior to exposing groundwater and to providing the Division a copy of the approved well permit when <br /> available. <br /> As represented in Exhibit M, the Applicant/Operator will obtain a gravel well permit from the Division of <br /> Water Resources/State Engineer's Office prior to exposing groundwater in the affected area. Upon issuance <br /> of such gravel well permit,the Applicant/Operator will timely provide a copy to the Division. <br /> 14. The Applicant states any wells in the mining area that will not be used will be abandoned per State of <br /> Colorado regulation. Please commit to providing the Division copies of the abandonment reports for <br /> all abandoned wells in the mine site. <br /> The Applicant/Operator will comply with all applicable rules and regulations concerning the abandonment of <br /> wells. To the extent that existing wells, controlled by the operator and inside the permit area, are abandoned <br /> as a result of mining or reclamation activities, the Applicant/Operator will provide a copy of abandonment <br /> reports to the Division. The Applicant/Operator believes that other abandoned wells may already exist on or <br /> near the affected lands; however, it is outside the scope of applicable rules for the Applicant/Operator to <br /> commit to researching and documenting such other abandonment reports. <br /> 15. The Division estimated the cost to reclaim the site based on the information submitted by the <br /> Applicant at$873,550.00. A copy of the bond estimate is attached for review. <br /> The Applicant acknowledges the Division's work to develop a detailed reclamation cost estimate. In general, <br /> this estimate appears to effectively capture the scope and cost of reclamation at a time of peak impact. As <br /> discussed above in item 9, we believe that conversion of the affected area to the proposed industrial post- <br /> mining use will be relatively rapid, making it unlikely that the peak impact scenario will remain an accurate <br /> estimate of reclamation costs once the reclamation process is substantially underway. <br /> Using the example in item 9, if mining operations and post-mining grading is complete on a portion of the site, <br /> a lease or sales transaction, potentially coupled with zoning/building approval (if needed), would provide <br /> more than adequate assurance that certain development standards(e.g., appropriate to pad sites, rather than <br />