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RE: Technical Revision Request for Firestone Gravel Resource, M-1996-052 <br /> Includes changes to Mining Plan, Reclamation Plan, and Reclamation Bond <br /> Reclamation Bond <br /> We have updated the Reclamation Cost analysis and corresponding table to update the bonding amounts to <br /> cover a larger area of disturbed acreage—corresponding with the current and proposed mining and reclamation <br /> plans. The total acreage of disturbance which shall be covered by various reclamation costs is increasing from <br /> approximately 95 acres to 180 acres. The areas of disturbance to be reclaimed consist of 130 acres which would <br /> lie above water and 50 acres below water areas. Please see the Reclamation Cost Revision and table for <br /> details on the reclamation tasks, volumes and revised bond recommendation. <br /> Acreage Corrections— DRMS Incorrect Totals, Release Correction, and Request for Addition <br /> DRMS Incorrect Totals-When revising all the acreages for the maps and timetables, we discovered a minor <br /> discrepancy in the total permitted acres from the 2010 amendment. The discrepancy in acreage is only 0.29 <br /> acres. The total acres the DRMS has in its records for the 2010 amended total acreage is 366.41 acres. But the <br /> total acres should have been 105.29 original acres + 261.41 amended acres = 366.70 total acres. The correct <br /> acreage numbers can be seen in L.G. Everist's 2010 amendment application, and in DRMS's 2010 permit and <br /> bonding approval letters. The first time we see the incorrect total is in the 2012 DRMS Annual Report form. We <br /> had not noticed this minor error until now—when the mistake was causing totals in our 2019 revised timetables to <br /> not add up correctly. It appears to be a minor rounding error, but we wanted to bring it to your attention so that <br /> we are working with correct acreages going forward. (See table below for line-by-line corrections and changes.) <br /> L.G. Everist Release Correction -As mentioned in the Mining Plan and Reclamation Plan sections, the maps and <br /> timetables in this Technical Revision include a slight acreage correction needed due to a small variance between <br /> the permit area and the property's legal boundaries. Our permitting consultant, Steve O'Brian, discovered the <br /> variance when he was revising and updating the maps and timetables. He discovered that we accidentally <br /> released approximately 4.07 undisturbed acres that had not been within the mine permit limits. To explain: in our <br /> October-2018 acreage release, we released 27.98 acres of undisturbed land that is fully described and depicted <br /> as the"L.G. Everist Exchange Parcel" (LGE-Ex-Parcel) in Exhibit A-3 from the Purchase/Sale/Exchange <br /> Agreement(PSE Agreement) between L.G. Everist and the Town of Firestone. There are 4.07 acres of that LGE- <br /> Ex-Parcel that were not in the permit area. When doing this TR, he realized that when we amended the DRMS <br /> permit in 2010 to include new properties, the permit boundary was placed on the road right-of-way (ROW) line <br /> along the borders. However, the outer boundaries of the LGE-Ex-Parcel follow the boundaries of legal property <br /> parcels, which extend to the centerline of the bordering roads (south-CR 26, east-CR17, north-CR26%). So, the <br /> difference of 4.07 acres is that land between the centerlines of roads and inside of ROW lines. On the Mining and <br /> Reclamation maps (and timetables), we have corrected the permit lines and acreages to run along the L.G. <br /> Everist ownership line, which runs 22-25 feet inside the ROW line along public roads, or follows the centerline of <br /> the Side Hill Ditch, with exceptions to this general description as shown on the Mining Plan and Reclamation Plan <br /> maps. (See table below for line-by-line corrections and changes.) <br /> Request for addition—As part of this acreage correction in this Technical Revision, we would like to include <br /> approximately 2.09 acres into the Firestone Gravel Resource DRMS permit area that was not included previously <br /> —but only because L.G. Everist did not own the land. L.G. Everist now owns the 2.09 acres, which is part of a <br /> larger parcel. In December-2018, the ownership of a 12.05-acre parcel - known as the"Town of Firestone <br /> Exchange Parcel" (TOF-Ex-Parcel) in Exhibit A-1 of the PSE Agreement—was transferred from the Town of <br /> Firestone to L.G. Everist. This 2.09 acres has been included in the Weld County USR amended permit since we <br /> amended the county permit in 2011. The 2.09 acres is located south of County Road 26% in the north-central <br /> section of the Firestone Gravel Resource and is surrounded on 3 sides by permitted areas. Because L.G. Everist <br /> now owns the 2.09 acres as part of a larger parcel, the 4th side of the area is now adjacent to land owned by L.G. <br /> Everist. The 2.09-acre area is small enough that all surrounding neighbors, owners of record, and owners of <br /> permanent man-made structures were notified and addressed during the 2010 amendment process. Finally, even <br /> with the addition of this small area, the total acreage is still lower than the 2010 total permitted acreage because <br /> of the much larger acreage release in October-2018. Including this small area would also not change the years of <br /> mining, years of reclamation, or reclamation cost estimate (bond). Therefore, for the reasons listed above, we <br /> request that this 2.09 acres be included as part of this acreage correction in this Technical Revision. (See table <br /> below for line-by-line corrections and changes.) <br /> FIRE-DRMS-TR-MiningReclamationChanges-Jan2019 <br />