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Adequacy Review (AM-11) – Elliott Russell <br />July 21, 2016 <br />Page 3 of 6 <br /> <br />17. Please explain how the seedbed will be prepared for seeding. Please provide information regarding the <br />number of tillage operations and type of equipment to be used. Types of various equipment to achieve an <br />ideal seedbed may include a ripper, chisel plow, disk and offset disk harrows, springtooth harrow, spike <br />harrow, chain drags, cultipacker/roller harrow packers, etc. <br /> <br />18. On page 12-3 of Volume I, the applicant discusses that reclaimed areas will be broadcast, drilled, or <br />hydroseeded, all at 25 PLS and may be further incorporated into the growth medium by using a rangeland <br />harrow, slope chain, or equivalent equipment, as necessary and feasible. The seeding rate is appropriate <br />for drilling and hydroseeding, as well as broadcasting as long as the seed is further incorporated similar to <br />as proposed above. Please commit to doubling the seeding rate to 50 PLS if the seed mixture is <br />broadcasted and isn’t further incorporated. <br /> <br />19. On page 12-3 of Volume I, the applicant states that broadcast or drill seeded areas generally will not be <br />required to be mulched. Please explain why these areas will not generally need to be mulched. Please <br />specify the type and rate of areas where broadcast or drill seeding occurs and are needed to be mulched. <br /> <br />20. On page 12-7 of Volume I, the applicant states that 400 mature aspen stems will be transplanted as a part <br />of the North Cresson Mine Area Viewshed Conservation Plan. Please clarify what a mature stem is. <br /> <br />21. Please explain the source and approximate amount of water that will be required for irrigation of the <br />transplanted aspen trees for the first two growing seasons, as discussed on page 12-7 of Volume I. <br /> <br />22. On page 12-8 of Volume I, the Applicant states the amount of backfilling required on the Schist Island <br />and Globe Hill portions of the North Cresson Mine area, the East Cresson Mine area, and portion of the <br />Main Cresson Mine area is dependent on potentially changing economic conditions. Please clarify how <br />these slopes will be graded to 2.5H:1V if backfilling is not completed. <br /> <br />23. The Applicant states, on Page 12-8 of Volume I, that when the maximum footprint of the Squaw Gulch <br />Overburden Storage Area is reached, the outslopes will be graded to final overall grades of 2.5H:1V. <br />Please clarify if the footprint will be increased in size or the height of the dump will be increased to <br />accommodate the grading of the outslopes. <br /> <br />24. On page 12-8 of Volume I, the Applicant states that sections of varying steepness will be formed within <br />this overall outslope of the Squaw Gulch Overburden Storage Area to generate irregular landforms. <br />Please clarify the maximum slope of these irregular landforms will not exceed 2.5H:1V. <br /> <br />25. On page 12-9 of Volume I, the Applicant discusses that that reclaimed slopes of the Squaw Gulch <br />Overburden Storage Area may be plated with rock to protect against storm water runoff erosion and to <br />emulate historic underground development rock piles in the Mining District. Similar to adequacy issue <br />#14 above, please clarify the maximum size of a rock-plated area of the Squaw Gulch Overburden <br />Storage Area and indicate these areas on the Exhibit F Reclamation Plan Map (Drawing F-1: <br />Approximate Post Mining Topography). <br /> <br />26. On page 12-10 of Volume I, the Applicant states that discrete slopes on surface mine backfill areas may <br />vary in steepness within the overall 2.5H:1V slope to generate irregular landforms. Please specify the <br />proposed steepest section of these overall slopes. <br /> <br />27. On page 12-11 of Volume I, the Applicant states that a portions of the Main Cresson mine area will be <br />backfilled at an approximate 2H:1V slope. Please provide a technical justification for the increase in slope <br />steepness compared to other reclaimed areas at the mine site. The Applicant also states that where <br />