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RECEIVED <br /> FEB 19 2021 <br /> DIVISION OF RECLAMATION <br /> MINING AND SAFETY <br /> Greg Lewicki And Associates, PLLC <br /> 3375 W.Powers Circle Phone:(720)842-5321 Fax(303)346-6934 <br /> Littleton,CO 80123 E-mail:info(a'lewicki.biz <br /> February 16, 2021 <br /> Robin Reilley <br /> Colorado Division of Reclamation, Mining, and Safety <br /> 1313 Sherman St, Rm 215 <br /> Denver, CO 80203 <br /> Bunn Ranch M-1990-058 <br /> Technical Revision—Additional Mining Area within Existing Permit <br /> Adequacy Response <br /> Ms. Reilley <br /> Elam Construction is providing this response to the Division's adequacy comments dated <br /> January 8, 2021. Revised components of the currently approved reclamation permit are included, <br /> and listed in the table at the end of this letter. <br /> 1. Please sped what measures are being taken to minimize or prevent injury to existing <br /> water rights both during and after mining of the disturbance proposed in TR4. This <br /> narrative could comprise an addendum to the 1980 reclamation plan on file at DRMS <br /> and be titled: Protection of the Hydrologic Balance. <br /> The Yampa River is currently under appropriated.No active calls are on the river. Elam <br /> Construction has an approved gravel well permit for the currently exposed groundwater lakes <br /> and a water right for the processing based consumptive uses. The gravel well permit is supported <br /> by water rights for the operation are covered by water court case 2015CW3002. <br /> The Colorado Division of Water Resources has informed Elam (via Western Water& Land)that <br /> the Yampa River basin in the area of Bunn Ranch may be designated as over-appropriated in <br /> May 2021. Since it is possible for some portions of future groundwater exposure at Bunn Ranch <br /> to require augmentation water, Elam Construction has begun pursuing an augmentation plan. In <br /> the meantime, a new gravel well permit will be applied for to cover the proposed groundwater <br /> exposure in the revised mining plan. <br /> In order to protect the prevailing hydrologic balance, Elam will do the following: <br /> • Acquire a new gravel well permit from CDWR <br /> • Record 2021 groundwater exposure prior to and after May 2021 <br /> • Provide DRMS with any and all documentation of augmentation water acquired if needed <br /> 2. Please provide an updated Mining Plan narrative. <br /> Bunn Ranch TR t Greg I. icki"d As ialm PIRA' <br />