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<br />4 <br /> <br />18. Response to Adequacy Item 18 is inadequate. <br /> <br />In accordance to Rule 3.1.10(1) and Rule 3.1.10(4), please provide a technical <br />justification that the rate of 25 PLS is acceptable for a broadcast seeding method <br />specifically when the seed is not further incorporated into the ground. <br /> <br />RESPONSE: CC&V commits to doubling the seeding rate to 50 PLS if the seed <br />mixture is broadcasted and not further incorporated into the growth medium. <br /> <br />19. Response to Adequacy Item 19 is inadequate. <br /> <br />In accordance to Rule 3.1.10(5), please provide a technical justification that mulch will <br />not be needed and provide evidence that better reclamation results are obtained when <br />no mulching is performed. <br /> <br />RESPONSE: Mulching is included in the CC&V reclamation cost estimate and will <br />be applied in all seeded reclaimed areas. <br /> <br />21. Response to Adequacy Item 21 is inadequate. <br /> <br />The response to Adequacy Item 21 states that approximately 1,056,000 gallons of water <br />will be purchased to irrigate transplanted aspen trees for the first two growing seasons. <br />Pursuant to Rule 6.4.12, please verify that the cost to purchase and deliver this water is <br />accounted for in the Exhibit L reclamation cost estimate or provide an updated cost <br />estimate. <br /> <br />RESPONSE: CC&V has verified the cost to purchase and deliver water to irrigate <br />transplanted aspen trees is accounted for in the Cripple Creek and Victor Gold <br />Mining Company reclamation cost estimate (Page 84 of Appendix11) submitted in <br />support of Amendment 11. <br /> <br />22. Response to Adequacy Item 22 is inadequate. <br /> <br />Pursuant to Rule 6.4.12, please verify that the cost to backfill the North Cresson and <br />East Cresson mine areas is included in the Exhibit L reclamation costs. <br /> <br />RESPONSE: The cost to backfill the North Cresson and East Cresson Mine areas is <br />not included in the reclamation costs in Exhibit L because it is considered an <br />operational cost occurring during life of mine. If CC&V is unable to backfill the <br />designated areas a modification will be made to the reclamation cost estimate. In <br />addition, a six foot high chain link fence is planned for the North and East Cresson <br />areas as provided in Response 49 in this document and Drawing F-1(revision 4). <br /> <br /> 23. Response to Adequacy Item 23 is inadequate. <br />The response to Adequacy Item 23, states that the footprint of the Squaw Gulch <br />Overburden Storage Area will not be increased. In accordance with Rule 6.4.5(f)(i),