Rationale for Recommendation to Approve 34
<br /> September 29, 2016
<br /> 36. Concern regarding Exhibit E—what is the maximum time topsoil will be exposed? Will topsoil
<br /> be seeded only after all is removed during a particular mining phase?How will the operation mitigate
<br /> dust blowing from topsoil stockpiles along the access road?Since proposing phased reclamation, how
<br /> often will topsoil and fines stockpiles be reseeded?
<br /> (N.Reed)
<br /> Pursuant to Rule 3.1.9(1), if salvaged topsoil is not replaced on a backfill area within a time short enough
<br /> to avoid deterioration of the topsoil,vegetative cover or other means shall be employed so that the topsoil
<br /> is protected from erosion, remains free of any contamination by toxic or acid-forming material, and is in
<br /> a usable condition for reclamation.
<br /> In Exhibit E, the Applicant states that stockpiled topsoil will be seeded following initial removal with a
<br /> temporary seed mixture that will establish quickly and prevent topsoil loss due to wind and water erosion.
<br /> The seed mixture was provided by NRCS, and was revised per recommendation by the Division to replace
<br /> Crested wheatgrass with Western wheatgrass. This revised seed mixture is included in Table E-2 in the
<br /> adequacy review response submitted on August 19, 2016.
<br /> 37. Concern regarding Exhibit E— will woody vegetation be chipped and added to the topsoil pile
<br /> per Rule 3.1.9?
<br /> (N. Reed)
<br /> In Exhibit E,the Applicant confirms that,where practicable,woody vegetation at the site will be removed
<br /> from or appropriately incorporated in the existing topsoil prior to excavation. If this is not practicable, the
<br /> woody vegetation will be chipped to incorporate into subsoils, or used as brush windrows for the project
<br /> storm water management plan. The Division determined that the permit application satisfies the
<br /> requirements of Rule 3.1.9(2).
<br /> 38. Concern regarding Exhibit E — will the applicant add wildflowers to the proposed grass seed
<br /> mixture (Table E-1) to improve aesthetics of revegetated areas?
<br /> (N. Reed)
<br /> The Applicant addressed this concern in the adequacy review response submitted on July 21, 2016. The
<br /> proposed reclamation grass seed mixture was revised (Table E-3 — Permanent Seed Mix) to include a
<br /> wildflower species, Rocky Mountain Penstemon (Penstemon strictus), recommended by the NRCS.
<br /> 39. Concerns regarding Exhibit E -for Douglas Fir/Lodgepole Pine reclamation areas (current
<br /> vegetation more diverse and no Lodgepole Pine exists—so why introduce into the canyon?Could Aspen
<br /> be added to the revegetation plan to improve aesthetics? Application mentions Lodgepole Pine in
<br /> association with Douglas Fir — but there is no Lodgepole Pine within many miles of the site; Blue
<br /> Spruce is mentioned several times — but there apparently are none on site; White Fir/Pine is very
<br /> common in all age groups—but not mentioned at all); Concern that there is no consideration of aspect
<br /> apparent in the revegetation plan (Douglas Fir would have little use on south facing slopes, Pinyon-
<br /> Juniper woodland is fairly extensive—but not in the revegetation scheme?)
<br /> (S. Fentman,J. Townsend, S.Bell,R.Eddy,J.Enderson, W. Baker, M.Baker, S. Firks, W. Sheaves,A. Sheaves,A. Sickels, L. Pecoraro,J.
<br /> Rigdon, K. Rigdon, T. Offutt, S. Diggs, W. Diggs, L. Steer, B. Donahue, H. Sandler, B. Louzon, L. Louzon, G. Cousineau, C, N. Reed,
<br /> Cousineau,P.Ragan, C Ragan, W.Flaharty,J.Flaharty,B.Powell,D.Martin,L.Martin, T.Hight, C Watkins,P. Watkins,J.McFarlane,
<br /> R.Eddy Jr.,M. Heer, C Heer, Raven Rudduck,E.Bransby,S.Boehr,M. Yugovieh)
<br /> 1313 S;ertiia.l Street. Rornr L€5. Dem.e�, CO 8G2D3 P 3r?3.866.3567 F"�•3.832.81+;6 http:'%n-,;n1,i,.stace.co.u,
<br /> Jahn~'.a. Hi keitroper. Ootien}o Robert W R 11a11, Fx cutvc Ci;rl.ctat Vrr,m.i 6rai ton. Dire-tor
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