2016-05-17_REVISION - C1982056 - Laserfiche WebLink

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designs which include freeboard of no less than 0.3 feel for the proposed diversion ditches or provide a justification to the Division discussing the reason designs without freeboard meet the requirements of Rade 4.05.3(7)(b). Response: In talking with our consultant who completed the SEDCAD runs, they did include the required freeboard as one of the input parameters for the runs, however, it was not reflected in the design documentation. We have also specified significantly more freeboard in the project scope -of -work for the contractor who will construct the ditches. We are providing revised design documentation with these responses reflecting inclusion of adequate freeboard. 2.05.3(5) — Topsoil 7. Please revise the narrative regarding topsoil on proposed revised page 2.05-84.14 and Table 49A; if necesscny, depending on the soil resources identified within the proposed disturbed area bused own your response to the soil resource inforinatnon adequacy' revnerk' nssate cited m section 2.04.9 of this review. Likewise please revise the topsoil ananrative in the mine facilities section of the permit regarding the proposed 9 East Borehole on proposed revised page 2.03-45.30 if necessury. Response: The discussions of soil material handling and volumes in the revised permit text, and Table 49A have been reviewed and revised, as appropriate, to reflect the site-specific soils information referenced in the previous response to Item 5. Copies of revised text and table accompany these responses. 2.05.4(2) — Reclamation Plan 8. It appears the pre -mine land use of'the proposed affected area is pustureland based on Map 3 of the permit. Proposed revised page 2.03-106 1 indicates that the affected area will be seeded with the rangeland seed mixtaare. According to section 2.05.5 of the permit, TC will reclaim the affected area to the premine land uses. Given this, it wouldseem the pastureland seed mixture would be wore appropriate for use. Please revise this page accordingly. 9. Proposed revised page 2 05-106.1 does not follow the preceding page. Please review this section and insure the pagination, orgaraa�ataon and tcXt follows the preceding page and following pages. Response: As indicated, Map 3 shows the premining land use for the project area as "Pastureland". This map also shows the premining land use for much of the Mine Permit Area as "Cropland". As discussed in the permit text (page 2.04-2). the definition of "land use" is generally related to management practices rather than vegetation types or communities. At the time the permit was issued, the defined premining land uses were based on historic management practices. Over the intervening period of over 30 years, those practices have changed, and as noted in the permit text (page 2.04-3), "At the time of Permit Revision No. 99-05, cropland was no longer the dominant land use within the Permit Area." This is reflected by the most recent update of the Premining Land Use Map, Map 313 (12/93). Given that land use patterns and practices are dynamic and may change over time, the premining land use for a given location may most appropriately be defined as the use existing at the time of mining -related disturbance. Rule 1.04(71)(6) defines Pastureland as lands, "actively managed for grazing, browsing, or for occasional hay production" and Rangeland as lands, "on which plant cover is principally valuable for forage". While there is not a strong distinction between pastureland and rangeland, the permit text (page 2.04-4) indicates that rangeland differs from pastureland, '...primarily as management is only achieved by regulating the intensity of grazing and season of use, rather than improvements (fertilization, interseeding, etc.) which may be implemented above and beyond grazing management." Given this clarifying statement. the current (premining) use of the lands within the project area would most appropriately be identified as rangeland. The referenced page has been reviewed and revised for continuity. Copies of revised text accompany these responses.