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

Home Browse Search

2022, necessitating a reply according to its respective item numbers from the Review, iterated in a graphical box, with our comments in blue following: Prologue The permit application has been prepared as a holistic document. We believe it would be inconsistent with the intent of the Rules and Regulations or good practice to approach it otherwise. Mining must be designed from the outset and operated through the life of the mine with closure in mind. To different degrees then, all the elements of the application are interwoven and form a narrative about the development, operation and ultimately closure of the mine. Naturally the Rules and Regulations must be segmented to at least address different elements of this process, but where the context of a discussion suggests certain discussions be combined, we have done this. There comes a point when the review will so put into fractions for purposes of style as to make the application fundamentally difficult to navigate or perform as a useful tool for compliance by the Operator. To cross reference every subject or element of the application would make the document both unwieldy and likely harder to understand and comprehend, rendering it less likely to be useful to either the operator or regulator. For example, while some information in Exhibits D and E addresses soils and vegetation, there is another exhibit completely devoted to the same. Similarly, there are independent exhibits intended to satisfy parts of Exhibit H - Wildlife Information, which may also add to the understanding of I/J Soils and Vegetation and other data. Soils and Vegetation are grouped because they are so contextually close and difficult to regard separately, so keen are their influences. This is not new and is also consistent with how we access established information of the same from SCS (NRCS) reports and data, as provided under Exhibit I/J: Soils and Vegetation Information, and maps. The vegetation, being typified according to soils, shown on the maps, fully complies with a map-based description of vegetation as it may naturally occur absent man caused modifications like agriculture or natural events like flooding or wildlife impacts, clearly evident in the aerial photographs used to enhance maps. Consequently, there are extensive references to Exhibit I/J throughout this application, in large part because soils are so integral to every aspect of the project, and it would be ungainly to repeatedly end every paragraph touching on the subject in Exhibits D, E, or others with redundant references. The same logic applies to Exhibit G: Water Information, which may also have other 2 � Page Correspondence to the Colorado Office of Mined Land Reclamation—Reply to Rob Zuber,EPS—Adequacy Letters of 24 June and 5 August 2022;in the matter of the Two Rivers Sand,Gravel and Reservoir Project—M2022-013.