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Environment, Inc.Page 4 <br />Adequacy Response #3 June 26, 2020 <br />M-2020-007 <br />greyed out are not used in the Working Bond calculations since they are <br />covered by the Floating Costs or because they would not be needed if mining <br />ended before that cost was needed. So in Phase 1, the total bank armoring <br />is not used in the Working Bond because LGE will be armoring as they go, and <br />the armoring cost is included in the floating costs. In Phase 3, the slurry <br />wall liner is not used because no groundwater will be exposed as long as it is <br />being used as the Plant Site. The data provided for Phases 2 and 2A are <br />not used in the working bond because they will not be disturbed at this time, <br />and not until Phase 1 is nearing completion. Prior to any work in those <br />Phases, LGE will work with the Division to process a bond revaluation. <br />DRMS assumes Phase 3 area will be stripped of topsoil and utilized as the plant area until the <br />last phase of mining. Groundwater will not be exposed in this area for several years; therefore, <br />bonding for surface reclamation will be sufficient at this time provided that the required topsoil <br />is stockpiled nearby. Permittee will need to bond appropriately to install slurry wall and reclaim <br />as lined reservoir prior to exposing groundwater in this area. <br />This is correct, and LGE understands the requirement to bond for the slurry <br />wall prior to exposing groundwater in Phase 3. <br />Line items provided such as: re-sloping working face to 3:1 if required; mob/demob; dewatering <br />costs; and weed control, can be included as-is. Costs for backfilling of cells and replacement of <br />topsoil where required should be based on total CY needed, and push distances from the <br />appropriate stockpile locations should be included. Acreages should be provided for crop <br />planting and revegetation tasks, and for ripping/grading tasks. <br />The bonding costs table labeled "Floating Cost" reflects this idea. Thank you <br />for the suggestion. <br />The required bond for affecting the eastern portion of the permitted area (Phases 4-6) will need <br />to be calculated and posted prior to any mining disturbance in that area. <br />LGE understands this requirement and will provide the necessary information <br />prior to moving in those Phases <br />Additional Information: <br />Any letters from other commenting agencies/entities received by the Division for this permit to <br />date are available for review through the imaged document data link provided below, or through <br />the DRMS website. https://www.colorado.gov/pacific/drms/data-search <br />The response for the Geotechnical Stability analyses is attached.