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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 <br />