2019-06-17_REVISION - M2001038 (6)

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Albert Frei and Sons, Inc. Page 5 AFS.-Bennett Pit - M-2001-038 June 17, 2019 life cycle of those species which require special consideration(e.g., elk calving, migration routes, peregrine falcon nesting, grouse strutting grounds). Please discuss the measures the operator will use the protect wildlife during the mining and reclamation operation. We believe the Mining and Reclamation Plans do take into the impacts to wildlife. Because it is a continuation of an existing operation and the wildlife are likely acclimated to the noise and human activities. So the continuation of the mine will not increase the impacts already there. The speed limits in the mine, and the mining staff is directed to be aware of wildlife that may enter the mine operating hours and what to do if they find any on the active mining area that came on after hours limit impacts. Using wildlife friendly wire fencing, instead of chainlink allows the wildlife that enter the mine a way to safely leave instead of block their way. The impacts are temporary in nature during the active mining times as the area is open enough of so any wildlife can skirt the active areas or have use of other parts of the property where no activities are taking place. The ERO Resources report discusses impacts to wildlife on the mine and to paraphrase the report, when the vegetation is removed the area will no longer be desirable to wildlife until it is reclaimed. It also noted there are no wildlife corridors or other sensitive species that occur on the site that would be affected by the project. More information is provided starting on Page 6 of the ERO report. ERO Resources made a recommendation to submit an endangered species habitat assessment to the U.S. Fish and Wildlife Service for concurrence with their findings, ERO to file that request on or around June 4, 2019 and once a reply is received it wiII be filed with the Division for the file. They also recommend doing a nest survey one week before disturbing any new area during the breeding season, April 1 to August 31 . AFS will follow the recommendations for not removing vegetation during that time if raptor nests are found. Records of the inspection will be kept in the Company records for inspection, if needed. The speed limit along the main access road and within the mine is limited to 10 mph to help mitigate the truck traffic entering and leaving the mine will have on the larger wildlife species. Prior to startup of daily activities the site is inspected to assure there are no wildlife in the mine that would be affected by the daily activities. Usually the larger animals that over night in the mine leave once humans enter the mine area, if this does not happen they are chased out of the active area. Rule 6.4.12, Exhibit L—Reclamation Costs 17. The cost estimate submitted with the application covers 30 acres of affected land. Based on the proposed mining plan, no phasing of the mining is planned and page 4 indicates a maximum disturbance scenario will be used to allow flexibility for the mine to be developed from both ends of the deposit. If the applicant would like to use a phased 30-acre bonding approach, please revise the mining plan to accommodate this and define the phases accordingly, or provide an estimate for the maximum disturbance scenario. That was not our intent on page 4, it was to allow for a plan that covers the existing and proposed disturbance area of 30 acres. During our review of that plan we realize that we are