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ERO Resources Corp. uT EXHIBIT 19 <br />1842 Clarkson Street ~~ <br />Deriver, CO 80218 <br />(303)830.1188 <br />Fax: 830-1199 <br />Denver .Boise <br />www.eroresources.com <br />e ro@eroresou rces~com <br />November 11, 2005 <br />Ms. Katie Fendel <br />Leonard Rice Engineers <br />2000 Clay Street, Suite 300 <br />Denver, Colorado 80211 <br />RE: Review of MMRR Quarry Reclamation Plan <br />Dear Ms. Fendel: <br />As you requested, I reviewed the proposed MMRR quarry mine permit application <br />(File # M-2004-67) for potential reclamation issues. Based on the review of the <br />reclamation plan, I have the following comments: <br />General Reclamation/Wildlife Habitat <br />The applicant has not addressed Denise Larson's May 25, 2005 comments regarding <br />the inadequacy of the restoration plan (revised Exhibit F and C-2C) dated March 23, <br />2005 (Plan) in ensuring the Plan's the stated intent: <br />"...To return the MMRR Quarry site to apost-mining condition as wildlife <br />habitat. Replacement of a plant growth medium and species selection is based <br />on the objective of emulating or improving upon the general condition of the <br />site vicinity as wildlife habitat..:' The plan also states that it will restore the <br />ephemeral streams to "...establish important habitat for flora and fauna of the <br />area." <br />In the applicant's August 19, 2005 responses to the June 30 adequacy review (as <br />amended), the applicant states: <br />"The existing conditions on the site are of limited wildlife value and will be <br />enhanced through the reclamation process:' <br />As described in Denise Larson's May 25, 2005 memorandum, the existing wildlife <br />habitat on the site consists of "dense shrubs (200 to 500+ per acre) and scattered <br />trees." Larson further states, "The existing xeric shrublands at the site contain more <br />shelter, and more complex vertical vegetation structure, more varied ecological niches <br />and other important wildlife features than the proposed grassland. The applicant's <br />stated intent is to improve upon the general condition of the site vicinity as wildlife <br />habitat, but the restoration plan proposes revegetation that would result in lower <br />quality wildlife habitat. Specifically, the plan proposes to: <br />• Plant 20 trees and shrubs per acre. <br />Consultants in Natural Resources and the Environment <br />Ilfile-serverlcupportldocumenfslf f B261hOf lero exhibit f 9.doc <br />