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r <br /> executed, but has not yet been mailed to Western Slope. Western Slope has since filed a <br /> Motion/Petition to re-open the hearing record for presentation of the defense case. <br /> 2. Nonetheless, Western Slope engaged its soils and irrigation expert David Fox to prepare a <br /> reclamation plan. Division was informed of progress on the draft plan, and that an <br /> updated seeding mix was being obtained from the CSU extension service; a vacation by <br /> the key CSU contact delayed this aspect of the plan for several days. <br /> 3. The draft reclamation plan was submitted to Division on September 19, 2019. A <br /> comment/deficiency letter was received from Division on September 25, 2019 raising a <br /> series of questions and possible issues with the plan. Those comments were relayed to the <br /> expert and a response/action plan is being developed. <br /> 4. It is likely that the reclamation/pipeline removal plan will be submitted as a proposed <br /> Technical Amendment to the Permit, as Western Slope does not wish to re-do or modify <br /> its existing reclamation plan for the mining site. <br /> 5. Division has established a new date for submitting an approvable plan of October 14, <br /> 2019. As the initial compliance date was Board ordered, approval of any extension <br /> would appear to need Board approval. Western Slope will submit a modified version of <br /> the reclamation plan prior to October 14, but does not control Division's approval of the <br /> plan as submitted. <br /> 6. In its Order, the Board established an implementation date of November 1, 2019. <br /> Insufficient time will exist after plan approval to implement the plan, which involves <br /> removal of designated irrigation facilities, site leveling and reclamation work, and re- <br /> seeding, including the use of heavy equipment. <br /> 2 <br />