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Peter Hays <br /> August 23, 2019 <br /> Page 4 <br /> Reclamation Plan <br /> Based on experience with both prevailing wind conditions and prior reclamation <br /> activities in the Fort Morgan area, Bijou has concerns about the proposed reclamation of <br /> the mining site and how wind erosion will be managed. Bijou has expressed to BMS <br /> concerns that reclamation activities in the area of the mining operations may be difficult <br /> to achieve or will not be effective. Although BMS has proposed a reclamation plan, it <br /> will not be known until after reclamation activities have been initiated whether the plan <br /> will work as intended. The proposed mining operations are for an extended period (35 <br /> years), so reclamation failures could have long-term impacts. Approval of a mining <br /> permit that does not include some type of "reality check" concerning the success of <br /> reclamation operations could result in erosion issues that would create problems for <br /> Bijou and local landowners at Empire Reservoir. <br /> Bijou understands that BMS will be reclaiming a "mined block" immediately following <br /> the mining operations in that block. Under these circumstances, it would be appropriate <br /> to place a limiting condition on any permit approval that would require: 1) BMS to <br /> establish that its reclamation activities on the first one or two mining blocks are <br /> successful (as confirmed by DRMS) prior to BMS initiating any further mining on the <br /> remaining blocks; and 2) that DRMS would need to extend the approval of the mining <br /> permit following its confirmation of the initial reclamation activities before BMS could <br /> do any further mining under the permit. To the extent that the reclamation activities are <br /> not working as intended, the permit would be revoked and BMS would need to submit <br /> a new permit application with an amended reclamation plan that would be subject to <br /> public review and comment. <br /> Bijou would also like to see a condition in any permit approval that requires some type <br /> of immediate protective cover of the topsoil and backfill piles on the mining site (mats, <br /> etc.) while any proposed vegetative cover is established, to ensure stability of the piles <br /> from wind erosion. A similar requirement should be evaluated for the "sand product" <br /> pile that will be maintained at the processing plant. <br />