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The seed mix is approved for use both on the privately-owned and BLM-managed portions of the permit area. The <br />type of mulch to be used and the methods of spreading and anchoring it, for purposes of the Division's cost estimating, <br />will be straw, scattered with a power spreader and crimped. (The Division also recommends it.) The seed will be <br />incorporated by dragging, for purposes of the Division's cost estimating. (The Division also recommends it.) Unless <br />the operator wishes to comment further, this part of the exhibit is considered adequate. <br />It is understood that not all portions of the permitted area will be retopsoiled and seeded. The Division agrees that <br />there has been no written proposal not to revegetate marginal areas. However, during onsite and in-office discussions <br />(at which not all parties were present and thus were perhaps unaware) questions arose about the ultimate fate and final <br />reclamation of various portions of the pit. Therefore the Division sought to have clarified these aspects of the plan at <br />this point in the amendment process: (1) Would there be need to provide different reclamation details for parts of the <br />floor or the road areas? (2) Are there currently structures and features that are not depicted on the mining maps, or that <br />may need to be identified on the reclamation maps as to their removal? (3) If a reclamation map included only some of <br />the roads that were to remain, while others were removed, what presumption was the Division to make concerning <br />buildings? These issues now appear to be settled, and unless the operator wishes to comment further, this part of the <br />exhibit is adequate. . <br />Exhibit F- Reclamation Maps. <br />The newest revisions of the following maps now contain a signature, plus other required changes, and are now <br />adequate: Map F-1, Map F-2, and Map F-3. <br />An explanation of the Division's question in its last letter, regarding topsoil and revegetation, should be made here. <br />The set of reclamation maps, as submitted during the past 15 months, have presented in aggregate numerous depictions <br />of the site. Often, the features on one map or comparing features from two maps, or tracking changes between <br />revisions were not immediately clear. One example is the area on private land, on Map F-8, submitted in April 2009, <br />labeled as "Industrial (shop yard)" and included several buildings. However, there was no clear distinction made <br />between areas to be revegetated and those that would not (though it appears that the Division is safe in assuming that <br />the industrial area will not be revegetated). Thus originated the Division's comment soliciting clarification of the <br />extent of the revegetation. (It should be noted that no distinction was made on the maps in the areas of swales or <br />channels either, though the Division agrees that these areas are unsuitable for topsoiling and revegetation.) Unless the <br />operator wishes to comment further, this exhibit is considered adequate. <br />Exhibit J - Vegetation Information. <br />This exhibit is for providing information concerning the existing vegetation, not for reclamation measures. The <br />operator's comments under this exhibit heading actually pertain to Exhibit E. Please see Rule 6.4.5(1)(d) and <br />6.4.5(1)(f)(ii). <br />Exhibit N - Right-of-Entry. <br />The proper documentation demonstrating right-of-entry has been provided and this exhibit is considered adequate. <br />All technical issues have been addressed satisfactorily. It is the Division's finding that the amendment is adequate for <br />approval. The Division will prepare and send to the operator an amended reclamation cost estimate under separate <br />cover. If an increased bond is indicated, the amendment will not become final until the bond increase has been <br />accepted by the Division. For any questions related to the types of bonds accepted or the bond forms themselves, <br />please contact Elizabeth Merry at the Division's Denver office (see letterhead address above). Her direct phone <br />number is 303-866-3567 ext. 8148. <br />Though it is not necessary at this point, if you still wish to provide written responses to any of this letter, please ensure <br />that you provide two complete (hard copy) sets of all materials to the Division. These may be submitted directly to me