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Mr. Ary and Ms. Bellantoni <br />Page 4 <br />October 7, 2013 <br />phase of the operation. As such, the Division requires the area disturbed by mining activities <br />be reclaimed to a beneficial use within five years of the completion of each phase of mining_ <br />The purpose of the following comments is to ensure the Division and the Operator have a <br />clear and common understanding of when and what reclamation is required throughout the <br />life of the mine and that a beneficial use can be attainable within the five -year time frame. <br />11. The proposed reclamation plan lists "Open Space" as the interim reclamation for Parcels <br />1, 2, 3, and 5; further designating the seed mix presented in Table 2 for the interim <br />vegetation. The only species discussed for final reclamation are wetland species. <br />a. Please provide some discussion clarifying whether or not non - wetland plants are <br />planned for anywhere (e.g., lake perimeter slopes, etc.) during final reclamation. <br />b. In order to estimate final reclamation liability, the Division requires specific <br />seed mixes (quantity of each grass and forb species as pounds of pure live seed <br />per acre, or number of stock plantings per acre). Please provide specific rates or <br />quantities for final wetland reclamation. <br />12. Please provide additional information to clarify when interim reclamation will be <br />initiated and when final reclamation will be initiated, keeping in mind that reclamation as <br />a beneficial use is required within five years of the completion of mining operations for <br />each phase of the project. This information is critical to developing a phased bonding <br />approach and the Division can ensure adequate bond is held during the life of the mine. <br />13. The proposed interim reclamation for Parcel 4 and Phase III is unacceptable. Pursuant to <br />Reclamation Performance Standard Rule 3.1.10(4), revegetation is required to stabilize <br />slopes. Furthermore, the Division does not allow slopes steeper than 3H:1 V for final (or <br />interim) reclamation. (Note, pursuant to Rule 3.1.5(7), all slopes shall be no steeper than <br />a ratio of 2H:1 V, except from 5 feet above to 10 feet below the expected water line where <br />slopes shall be not steeper than 3H:1 V). Please revise the reclamation plan for Parcel 4 <br />and Phase III to: <br />a. Be seeded, mulched, etc. in a similar fashion as Parcels 1, 2, 3, and 5. <br />b. Be sloped no steeper than 3H:1V. <br />14. The proposed final reclamation plan is inadequate. In order for the Division to ensure <br />adequate bond is available, quantities for earth works stockpiling and grading, reservoir <br />lining, revegetation, reservoir appurtenances, riprap protection for banks and /or <br />spillways, etc. need to be provided. The Division acknowledges that it is likely infeasible <br />to provide this information at this time. However, if the Operator wishes the Division to <br />approve water storage as the final reclamation, it must be provided. Other acceptable <br />options might be: 1) changing the proposed interim reclamation plan to final reclamation <br />and eliminating the water storage aspect for final reclamation, or 2) propose the interim <br />reclamation plan (with the above required changes) for now and provide the Division <br />with consent to commit to submitting a technical revision application to address the <br />specifics required for water storage when they become available. <br />a. Option 1 would allow the Division to release the Operator from reclamation <br />liability once satisfactory reclamation is achieved. After which, the landowner <br />cold pursue the water storage option without oversight from the Division. <br />