2017-05-08_PERMIT FILE - M2017007

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sle�e 0,Brian 1017 Pare 2 of'4 EXHIBIT C-Pre-mining and Mining Plan Map(s) of Affected Lands(Rule 6.4.3)• No clear distinction has been made in the permit application or submitted maps between the permitted area and affected area as defined by Rule. Therefore, DRMS will not allow the northern permit boundary to be defined as the "center of the Huerfano River". Not only would this be impossible to mark and maintain appropriately,it directly conflicts with the statements in the mining plan,reclamation plan,and other required pen-nits exhibits(pages 11, 17 and 55)that no U.S.Anny Corps of Engineers 404 pen-nit is necessary,as there are no water bodies on the site or wetland areas that will be disturbed by mining or reclamation. The applicant will be required to set an appropriate northern permit boundary, out of the course of the river, which will be able to be pennanently marked and maintained. The permittee may also make a clear distinction between pen-nit boundary and affected area, and clearly delineate the affected area within the application and all appropriate figures. There is also no documentation provided,such as a wetland delineation study,to support the assertion that no wetland areas will be disturbed - even though the permit boundary as submitted includes approximately 6.5 acres of riparian corridor along the south bank of the Huerfano River. If the permittee wishes to include the riparian corridor in the affected area, they will need to provide sufficient documentation to demonstrate that sensitive environments will not be impacted. It also appears that the east-west roadway that traverses across the northern part of the site(labeled "private road"on the submitted maps and presumably intended to be removed during mining)may actually be County Road 615 — see attached map. This issue will need to be clarified with supporting documentation and appropriately addressed in the application(Exhibit S). Any changes made to the currently submitted permit boundary or affected area will need to be reflected appropriately on all figures and text submitted in the application. EXHIBIT G-Water Information(Rule 6.4.7): It is DRMS's understanding that the current mine plan intends to "daylight" the excavated area by mining down the elevation of the existing terrace along the north side of the permit area. The application states that "..Ave expect the floor of the mine to be at lease (sic) 3 feet above the bank of the river." If no berm will remain to separate the pit from the river, DRMS will need a commitment to a well-defined elevation for the pit floor and appropriate documentation that the proposed final pit configuration will not adversely impact the flood plain management of the Huerfano River. If the final elevation of the proposed pit floor will be within the 10-year floodplain,and the pit floor is exposed to the river, the permittee will need to include appropriate measures to prevent excessive erosion during a flood event and to insure long tern stability of the reclaimed area. EXHIBIT L-Reclamation Costs (Rule 6.4.12): DRMS will detennine the reclamation bond based on the provided information when all adequacy issues have been finalized. EXHIBIT M- Other Permits and Licenses(Rule 6.4.13): As long as the permitted/affected area includes the Huerfano River, it is likely that the applicant will be subject to U.S.A.C.O.E.permitting requirements.