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Mr. Al Amundson Mr. Anthony J. Waldron Environmental Protection Specialist State of Colorado Department of Natural Resources -Division of Minerals and Geology July 19, 2002 Page 2 with the 1061 acres of disturbed area and treat this as an amendment to the permit or modify the disturbed acreage amount as to remain within the originally noticed 895 acres, thereby eliminating the need to amend the application. GCC Rio Grande originally adjusted the boundaries of the mining permit to accommodate the refinements requested by the Division's May 6~' letter. Our understanding is that the adjustments are consistent with the regulatory framework and would not have triggered a permit amendment. However, after discussing the issue with the Division, GCC Rio Grande has decided to amend the mining plan to reduce the currently "disturbed area" to 895 acres. This means that GCC Rio Grande will be approaching the mining operation in two phases. The first phase, which includes the 895 acres of disturbed areas, will involve mining in years 1-35. GCC Rio Grande is requesting a permit authorizing mining activities only in the fast phase at this time. The second phase would involve mining in years 36-50, but only after GCC has initiated operations, assessed the feasibility of proceeding with the operation, and engaged in the full permit amendment process including public participation and reclamation bonding revisions. Attached to this letter please fmd a map labeled Exhibit C-1.5 and narrative description of the phased mining approach on replacement pages C-1 and C-2. These attachments illustrate the requested phased approach and ensure that at this time, GCC Rio Grande is only seeking a permit fora "disturbed"/"affected area" of 895 acres. Thank you again for working with GCC Rio Grande as we work to refine and improve our permit application. We believe the above-noted information and attached replacement page inserts into GCC Rio Grande's permit application address the Division's comments set forth in the July l la' and July 17a` letters. Should the Division have questions or wish further discussion regarding these proposed revisions, please call. Thank you. Sincerely, Brian McGill Environmental Manager (810892}