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As you are aware, we met on two previous occasions concerning the preliminary updates <br />and revisions to the reclamation cost estimate (RCE) for the New Elk mine. Proposed <br />changes to reclamation requirements under TR -68 will likely modify the cost estimate, <br />especially with regard to pond reclamation and revegetation costs associated with shrub <br />transplants. In addition, we have provided new permitting text in a new Section 3.0 and <br />in Exhibit 28 to provide more specific detail for input and assumptions to the RCE. We <br />have also included a new cumulative bond schedule that will need to be finalized once <br />the final RCE is determined. <br />Included with this revision is a proposed change to the post mining land use and the <br />revegetation plan, specific to shrub re- establishment on reclaimed lands at the New Elk <br />Mine. Our thoughts regarding the current plan, and the perceived deficiencies and <br />viability of the current plan, were forwarded to the CPW and the Division on December <br />6, 2012. GEC subsequently met on -site with representatives of Colorado Parks and <br />Wildlife (CPW) on January 10, 2013 to discuss the current reclamation plan regarding the <br />post mining land use and the plan for shrub re- establishment, and get their input and <br />feedback with regard to proposed modifications of the plan. Generally, CPW agreed that <br />the current shrub establishment plan is unlikely to achieve success and may not be the <br />best plan, given current industry and government agency experience with shrub re- <br />establishment. GEC's summary of the results of the on -site meeting and an affirmative <br />response from the CPW to move forward with revision to the shrub plan is included as <br />Informational Exhibit A. <br />TR -68 also proposes to retain pond 4, below the DWP, and pond 8 below the RDA as <br />permanent impoundments under Rule 4.05.9. Pond 4 is being kept primarily because of <br />the excellent riparian species that have developed in this over -sized impoundment, which <br />under the current plan, would be eliminated during reclamation operations. Pond 8 is one <br />of the few water sources north of the highway in the vicinity of the mine and would be <br />beneficial as a water source for wildlife that will likely utilize the reclaimed RDA upon <br />permanent closure of the mine site. <br />A major reformatting of the permit text has been done to improve the workability and <br />presentation of the information. Text in section 2.03 and 2.05 has been revised and <br />reformatted in its entirety. Text and tables are now included in the body of the document <br />in a relatively simple format. Headers and footers are used to indicate the section, the <br />revision number, and the page numbers, which now automatically adjust if new text is <br />added to specific pages. This re- formatting should aid in future revisions as well as <br />anticipated use of electronic submittal of revision materials as e- permitting becomes <br />available. <br />12303 Airport Way Ste 200 , Broomfield CO 80021 - Phone: 303.327.1525 . kent @gorhamenergyconsultants.com 2 <br />