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In order for our office to properly evaluate the potential mining impacts and accurately calculate the reclamation liability amount, we must know the exact extent of the proposed disturbance area. Bank mining requires more extensive reclamation planning and it is also more costly due to the additional regrading, topsoiling and revegetation required. If bank mining is proposed, it is likely that the reclamation bond will be larger than the $5,000.,00 currently proposed. An alternative to delineating these areas now is that if a large deposit of gravel is discovered during the creek bed mining that would make it feasible to conduct bank mining, the permit and associated liability bond could be revised at that time to accommodate the mining and reclamation of such an area. Either way the permit will need to be revised to remove the bank mining language, or the maps and acreages will need to be adjusted to clearly show the proposed bank mining areas. EXHIBIT E- RECLAMATION PLAN Under item E of this exhibit it is stated that phased reclamation is not needed since bank disturbance will be minimal. For the active creek channel this may be true, however, any vegetated bank areas that are disturbed should be reclaimed as soon as possible to prevent excessive unraveling while the rest of the area is being mined out. This is particularly true in this situation since the mining area is so long and as mining progresses there will be a rather lengthy section of Surveyor Creek unreclaimed. Another reason for conducting some phased reclamation is to contain the size of the reclamation bond needed to cover the reclamation liability. If no reclamation is completed prior to the end of mining, the entire affected area will be bonded. However, if the reclamation is completed in a phased approach, the size of the bond will be commensurate with the proposed phases. In addition, if reclamation is carried out shortly after mining has occurred, it may be possible to release a sizeable portion of the reclamation bond immediately at the completion of mining rather than waiting several years for vegetation to establish. Phased reclamation is discussed further in Exhibit L which addresses reclamation costs. EXHIBIT F- RECLAMATION PLAN MAPS No Comment. EXHIBIT G- WATER INFORMATION The statement that this mining operation does not directly affect surface water systems seems to be incorrect given that an active drainage channel, albeit one that only runs during significant precipitation events, is being mined. Clearly, approval of this mining permit will directly affect the surface water system, however, the overall impact should be minimal especially after the site is properly reclaimed. At the very least, the application