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DHR <br />Fc, <br />January 24, 2017 <br />COLORADO <br />Division of Reclamation, <br />Mining and Safety <br />Department of Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Mr. David Felderhol <br />Zephyr Gold USA Ltd <br />1959 Upper Water St. <br />Halifax, Nova Scotia B3J 3N2 <br />Canada <br />Re: Dawson Gold Project, DRMS NOI File No. P-2013-002; <br />Second Notice of Deficiencies for NOI Modification, Revision No. MD -3 <br />Dear Mr. Felderhol: <br />On January 11, 2017 the Division of Reclamation, Mining and (Division) received your response to the first <br />notice of deficiencies (NOD) for your Notice of Intent to Conduct Prospecting Operations (NOI) Modification <br />(MD -03). Based on these responses, the Division has the following additional deficiencies. Please address <br />the following items: <br />Application: <br />1. Project Description Items III.12.F and G, pages 4 and 5. Based on the proposed drill road cross <br />section on Figure 2 of the response, the Division is compelled to consider the full section of the road <br />cut as disturbance; including the cut slope and cast off material (shown as a 30 -foot width). The <br />Division used Google Earth to measure the disturbance width of the 2016 drill roads and found them <br />to vary between 30 and 50 feet in width, with a typical width of about 40 feet. As such, it is appropriate <br />to assume a 40 foot width of disturbance for the entire 9,722 feet of proposed new drill road. This <br />amounts to an estimated disturbance of 388,880 sq. ft. or 8.9 acres. This is significantly more than the <br />proposed 2.23 acres as well as a significant increase in the cumulative road cut disturbance to date, <br />a. Pursuant to Rule 3.1.5(3), All grading shall be done in a manner to control erosion and siltation <br />of the affected lands, to protect areas outside the affected land from slides and other damage. If <br />not eliminated, all highwalls (also inte/preted as deep road citts) shall be stabilized- Please <br />provide a detailed reclamation plan for the road cuts that will satisfy this Rule. Please include <br />method(s), proposed equipment, and a detailed cost estimate. <br />b. Please revise Items III.12.17 and G, pages 4 and 5, accordingly. <br />Agency Comments: <br />2. The response labeled No. 3 under Agency Comments indicates mud pits are to be included in the road <br />cuts. The MD -03 application indicated there would be no (zero) mud pits. Please clarify: <br />a. Whether mud pits are planned (in or outside the road cuts) and how many, and <br />b. How the mud pits will be reclaimed (including the source of backfill material and what <br />equipment is to be used). <br />oF' CO1a <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.statel.Co.us <br />John W. Hickenlooper, Govemor I Robert Randall, Executive Director I Virginia Brannon, Director <br />*187 <br />