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Ms. Erica Crosby, Division of Minerals and Geology ~~ <br />April 15, 2005 [ C`/ <br />Page 2 of 5 <br />CIVIL RES~URCES,LLC <br />The legal right to enter is attached <br />5. Mining Plan Map 3 of 7 depicts a recharge well east of Area 19 on property owned 6y Hunt <br />Brothers Properties, Inc. This area was not included in the permit area as were the other proposed <br />recharge wells. Please submit fega/-righf-of-entry for the properly fhat includes fhe recharge well and <br />include this area within the permit boundary. <br />Per our phone conversation, the Hunt Brothers do not want to be included in the permit area. As a result, <br />we have relocated the proposed recharge well onto the SW TKO properly. <br />6. The applicant stated that legal right of entry documents were previously submitted for the Hunt <br />Brothers Properties, Inc and the Robert P. 8 Dean VillanoNillano Brothers Properties, Inc. The legal <br />right of entry information you included was for SW TKO fo obtain additional information about the <br />well. The information would include reviewing initial drilling information, measurement of the static <br />water level in the well and possibly installing a data logger in the well. It did not include language to <br />enter the property to construct an injection well or other mitigation feature to minimize impacts to the <br />hydrologic balance. Please provide the necessary documents to obtain legal righf of entry for the <br />Hunt Brothers Properties, Inc., the Robert P. 8 Dean VillanoNillano Brothers Properties, Inc. and the <br />Steve Brancucci property for the area related to the location of the injection wells. <br />As explained in response no. 5, we no longer need a legal right to enter for the Hunt Brothers property. The <br />other well owners had stated strongly to us that they felt the information that we submitted to you would <br />suffice for legal right to enter. Per your request, additional legal-right-to-enter letters are attached. <br />7. A few of the exhibits submitted to the Division continue to state, "Conceptual Plan." Please be <br />aware that any changes to the proposed operation or maps in the future may need to be filed as a <br />revision to the permit Therefore, please remove this language from the relevant exhibits (Sheet 1 of <br />7,2of7,3of7,4of7,and8of7). <br />We have deleted "Conceptual Plan" from the maps. <br />Rule 6.4.4 Exhibit D-Mining Plan <br />8. The operator contends that all mining related structures on site are portable and are assets <br />owned by the operator. In addition, if the operator ceased operations and the Division was forced to <br />reclaim the site, the operator would remove the conveyors and other mining related structures. The <br />Division does not consider structures that require a concrete pad and footings to be "portable" <br />strucfures. The Division considers portable sructures to be portable screening conveyors and in <br />some cases asphalt batch plants. Removing beams, siding and concrete pads to bring down a <br />structure does not define the item as "portable". In addition, the structures may be in place for 20 <br />years or more, and at the end of mining may no longer have arty value to the operator. <br />The operator notes numerous 112 permits that the Division has approved within the last few years <br />where structures have not been included in the reclamation cost estimate, however no specific sites <br />are mentioned. The Division can point out manysites where all mining related structures are <br />included in the reclamation cost estimate (i.e. King Mountain Ranch M•1978-314, Lafarge's East <br />Ridgen Pit M-1979-097, CEMEX Lyons Pit M-1977-208). <br />