2023-01-04_PERMIT FILE - M2022013 (2)

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rao � 14 6.4.5 EXHIBIT D—Extraction Plan other; as reflected or otherwise updated as part of required 0M1R annual Reports. Under this method, extraction is 'pulsed.' As such, the rate of extraction and subsequent reclamation will slog or quicken according to influences of the markets,weather, and internal logistics. Flexibility-in Operations encourages better outcomes when adapting to changing circumstance or unexpected field conditions, and may involve actively wonting different fields or different parts of the same field as necessary. Generally, flexibility aids integrity of operations and encourages optimizing operational activity- and subsequent reclamation of affected lands. Therefore, any method that accelerates the extraction timeline uill be utilized, and should be encouraged to better engage the unpredictable elements and variables that reasonably affect the capacities of the Operator. Exhibit C-2: Extraction Plan Map, shoes the location and planned extraction limits, general direction of extraction, and related features described above; along uith features made obvious in the included aerial image of the permit location and surrounding lands. Additional information is prodded under D-hibit C-1: Existing Conditions Map.- which sho;%s all lcnmm current and active significant man-made structures located on or mthin 200 feet of the permit boundary detailed under including creeks, roads,buildings, oil and gas facilities [such as tanks,batteries,wells and lines), and pottier and communication lines and support structures, easements and rights-of-way; located over the permitted lands or uIthin 200 feet of the same_ A listing of the adjoining surface o;%mer's names and addresses located within these areas are listed under Exhibit C Text, correlated ;%nth those sho;%m in the afore-mentioned Exhibit C-1: Existing Conditions Map. Division Second Adequacy Comment Rol needs to clarify an apparent contradiction beta een the response to item #17 and the approach to minimizing impacts on wildlife, as required by Rule 3.1.S. On page 15, the response states that "four separate extraction teams" could be used to hasten the extraction schedule. However, the ERO memorandum (August 26, 2022; page 2) describes an incremental approach that 11111 protect mule deer habitat by only disturbing a relatively small area at one tinge. The text in the memo suggests that a maximum size for an active cell is 16 acres. This example illustrates the need to better define the mining and reclamation plans. Raptor Materials Second Adequacy Response The First Adequacy response has been incorporated into the revised Exhibit D (p16, Footnote 4). Also, in revised Exhibit D, the wildlife concern has been 191 Page Correspondence to the Colorado Office of Mined Land Reclamation—Reply to Rob Zuber,EPS—Adequacy Letters of 24 June and S August 2022;in the matter of the Two Rivers Sand,Gravel and Reservoir Project—M2022-013.