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Page 5 of 8 <br />25. The Applicant states the registered alluvial wells within 600 feet were identified based on SEO records. <br />Were field inspections conducted to identify ALL wells within 600 feet? Will any wells beyond the 600- <br />foot radius be affected by the mining operations? <br />26. The Applicant needs to describe how the drawdown of the pit and any shadowing/mounding effects <br />will impact the structural integrity of the surrounding wells, surface water drainages, activities which <br />rely on ground water in the vicinity of the site, and vegetation on or near the site (including the <br />cottonwood trees in the riparian area near the Cache La Poudre River and the wetland area adjacent to <br />the pit). The Applicant must also describe any mitigation measures to be implemented and trigger <br />points that would put mitigation measures into effect. <br />27. The mitigation section of the application states mitigation measures would be implemented after <br />receipt of an owner complaint and confirmation of the two foot trigger point. The Applicant should be <br />aware that mitigation measures should be implemented once the two foot rigger point is confirmed <br />during two sampling events. If the Applicant desires, a separate set of mitigation measures to be <br />incorporated once the two foot trigger is reached without an owner complaint may be proposed, the <br />Applicant may submit these to the Division for review. <br />28. The submitted information also indicates that there are other potential impacts to depression of the <br />groundwater elevation, specifically with regard to vegetation in the area. It appears there may be <br />cottonwoods located adjacent to the river which would be impacted by the drawdown from <br />dewatering the pits. These trees are likely critical winter roosting habitat for raptors, the Applicant <br />should submit information to the Division committing to measures to protect these trees from the <br />impacts of dewatering. Additionally, the Applicant should submit information to the Division regarding <br />other areas that may be negatively impacted by drawdown of groundwater, for example, any sub- <br />irrigated pasture in the proposed cone of depression, and measures it will take to mitigate these <br />effects. <br />6.4.12 Exhibit L - Reclamation Costs <br />29. The Applicant states 29.1 acres of land will be revegetated with the upland seed mix. In Exhibit E, the <br />Applicant provided a seed mixture for the transitional zone/water's edge. Please provide the <br />estimated acreage to be reseeded with the transitional zone seed mixture. <br />30. The proposed mining and reclamation plans for the site includes dewatering of the pits, the bond <br />calculation for the site should include costs related to dewatering of the pit to account for the costs <br />incurred by the state if water had to be removed from the pit in order to establish the proper <br />reclaimed slopes along a pit wall. Please include an estimate for the dewatering activities in the <br />financial warranty estimate. <br />31. The Division will estimate the cost to reclaim the site based on the information submitted once the <br />Applicant addresses the concerns noted in this letter.