2009-06-30_PERMIT FILE - M2009018 (8)

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Varra Companies, Inc. Office of Special Projects 8120 Gage Street Frederick. Colorado 80516 Telephone (970) 353-8310 Fax (970) 353-4047 35. Please see comments under Exhibit D - No. 8. Any future structures (portable or fixed) to be established within the permit boundary will be indicated in a future Technical Revision to the Office. The financial warranty can be adjusted to the extent necessary at that time. Any revision will be made prior to the construction of any fixed structures. Portable structures may be placed but will not be operational until the Technical Revision is submitted and approved by the Office. 36. In. determining the reclamation costs, the Applicant assumes that the average wall depth will be 25± ft. The Mining Plan states that extraction activities will remove aggregate to a mean depth of 49± ft. Please explain this discrepancy. Part of the problem in the applicant's effort to determine warranty costs is matching expectations with the Office and its proprietary software that it uses to establish correlated costs. The attempt was to seek a mid point at the time of failure. Generally, the maximum point of disturbance is an ideal warranty concern seldom attained in the field. Wall depths like areas of disturbance vary and fall short of their maximums. It seemed reasonable to assume a mid point. We understand and respect the concerns of the Office. The Office can utilize the entire wall depth of 49± ft without objection. 37. In determining the reclamation costs, the Applicant has factored in a 1600± ft. additional unreclaimed front from failed concurrent grading and reclamation. Please clarify how this figure was arrived at. Since the plan of extraction and reclamation involves concurrent grading and revegetation behind the advancing front of extraction, the application assumes at the point of failure this front is active and ungraded. The plan has two advancing fronts in the assumption, one at Tract A and another in Tract C. The assumption was attempting some generosity in estimating ungraded lands by providing a 50 percent additional area in the event Tract B were opened during the initial years of operations. 38. The Applicant states that there will be an approximate area of 8.27 acres to reclaim under default. This figure was used to determine the total area requiring vegetation. It is assumed that this figure is based off of the area of reclaimed slopes (4800± linear feet X 75 ft. slope distance = 360,000 ft2 = 8.26 acres). Please explain why the slope area has been used to calculate the total area for vegetation. In general, the lands remaining above the slopes will not be affected in a manor to easily determine the balance requiring revegetation, since the majority may be finished access around ponds, or generally, unaffected. The primary affected land is within the areas of planned extraction which essentially leaves in tact existing roads along ditches and attending grassed waterways. In other words, the principle disturbance is confined essentially to the extraction Varra Companies, Inc. correspondence of 30 June 2009 to the Colorado Office of Mined Land Reclamation 17 (Office) in reply to Office correspondence of 12 May 2009 - Heintzelman Project - M2009-018.