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In the unforeseen event that the DRMS moves to forfeit the reclamation bond ... forfeited bond monies are not to be <br />used for reclamation of pre-existing abandoned mine waste rock piles and/or conditions that were undisturbed <br />during operations. <br />This is one premise that led Venture Resources to petition the CO Mined Land Board for clarity on whether or not <br />this cleanup activity is or is not a "mining operation" as defined by Mineral Rules and Regulations for Hard Rock, <br />Metal and Designated Mining Operations, Rule 1-Definitions. Ultimately the Board ruled that our proposed <br />operations is a "mining operation" and that is why this application is being made. We were given assurance that <br />pre-existing conditions would not be a negative factor in this process - it just needs to be restated. <br />6.3.4(2) <br />Venture Resources, Inc. has worked closely with an independent, third-party contractor to arrive at cost estimates for <br />reclamation, closure, and post closure work. Doyle Construction, Inc. is a general contractor whom specializes in <br />earthwork and excavation projects in Clear Creek, Gilpin, and Summit counties. They understand the challenges of <br />working in a mountainous environment and the logistics necessary to mobilize labor, equipment, and materials <br />necessary for this reclamation project. They have prepared a letter, attached to this Exhibit D, attesting to the cost <br />estimates made for reclamation. Chris Doyle, President of Doyle Construction Inc. of Dumont, CO, can be <br />contacted at 303-567-1665. <br />As described in 6.3.3(2)(b) Exhibit C and 63.4(l)(c)(ii) within this Exhibit D, phased reclamation shall be part of <br />normal operations. Permanent reclamation and control measures will be installed in 10 feet phased increments <br />(elevation height of one quarter of a terrace - see maps in Exhibit E) which is estimated to occur every several <br />months. Seeding will occur to coincide with the appropriate time of year for proper germination, whether it is closer <br />to spring or fall season. Additionally, as each 40' high terrace is completed, the exposed surface of the terrace will <br />be re-vegetated as described above. <br />Venture Resources wishes to appeal to the DRMS for the ability to approach the reclamation of this project in two <br />• phases by defining a point of Maximum Disturbance at two specific future benchmarks. We desire this <br />consideration based on the economic constraints of an upstart operation in today's stressed economy. It is our <br />intention to provide a Cash Bond for the Financial Warranty. <br />One of these benchmarks shall be established as the completion of Bench #2 of the Tailings Impoundment which is <br />scheduled to occur at a point no sooner than 90 months/7.5 years after beginning operations. We feel this is <br />practical, considering such a small mill output from the Mobile Mill processing equipment of 40-80 tons/day. <br />During this period we may have reached a level in which we may desire to amend this permit to include a permanent <br />400 ton/day mill (as described in the opening summary of Exhibit C as Phase 11). In that event, Venture Resources <br />will need to amend the reclamation costs, anyway. <br />If the aforementioned Phase II amendment does not occur, an adjustment of the standing bond shall be made to <br />reflect continuing existing operations forward of Bench #2 to total build-out, more specifically the completion <br />through Bench #5. This shall be done before proceeding any further past the Bench #2 build-out. <br />Therefore, a point of Maximum Disturbance - Bench #2 shall be defined as follows, acknowledging the phased <br />reclamation described throughout Exhibit D: <br />1. Mobile Mill Site actively processing per the operations set forth in Exhibit C - Mining Plan. <br />a. 0.632 acres <br />2. The largest area of potential non-reclaimed area of exposure within the Tailings Impoundment is the last <br />increment of sloped face of Bench #2 and the resultant level, planar region above it (reference Exhibit E3 <br />and Tailings Impoundment Capacity and Reclamation Cost Schedule in the appendix of this Exhibit D). <br />a. 0.173 acres of/. sloped face on Bench 2. <br />b. 1.43 acres of level area on top of Bench 2. <br />Careful consideration has been made to create a Reclamation Cost Schedule that addresses all elements necessary <br />for reclamation on a unit cost basis. This Schedule is provided at the end of this Exhibit D in spreadsheet form. <br />• Equipment depreciation costs have not been considered due to the relatively short time (two weeks) of duration for <br />the reclamation project.