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�v <br /> RECEIVED <br /> Date: March 23, 2018 <br /> MAR 2 9 2018 <br /> DMSION OF RECLAMATION <br /> To: Michael A. Cunningham, Environmental Protection Specialist MINING AND SAFETY <br /> Colorado Division of Reclamation Mining and Safety <br /> Department of Natural Resources <br /> 1313 Sherman Street, Room 215 <br /> Denver, CO 80203 <br /> Re: City of Golden, Empire Pit No. M-1977-534-AR01 <br /> Technical revision, Empire pit, Reclamation permit number M - 1977-534 <br /> Uear Mr. Cunningham: <br /> We have three comments and questions in an effort to help in the successful Reclamation of the <br /> Guanella Pit Area. <br /> 1. Is the definition of"Inert" neither acid or alkaline, free of foreign materials, stones greater <br /> than one inch, concrete, cinders, brick, asphalt,weeds, or noxious materials? Last time <br /> some type of manure was brought into the area and spread and was a possible source <br /> of weed seeds. Inert soil does not mean sterile and incapable of sustaining plant <br /> materials, insects, earthworms, arthropods,fungi, bacteria and other microbe species. <br /> 2. How will the resulting soil be tested for biological life? To have thriving life above ground <br /> there must be thriving life below ground. The amount of life below the surface soil <br /> should be greater than the life above the surface. The total weight of living matter in an <br /> acre of mineral soil should be a minimum of 5,000 pounds. An acre of healthy soil <br /> should have more than a ton of bacteria and more than a ton of fungi, 445 pounds of <br /> earthworms and 830 pounds of insects and arthropods. There could be between 10,000 <br /> and 50,000 different microbe species in 1 gram of soil. The fungal hyphae help create <br /> fine roots to pick up and absorb nutrients and water. They unlock the chemical bonds on <br /> potassium, sulfur and nitrogen to release or solubilize nutrients and make them available <br /> for uptake. Soil amendments help feed the microbes and fungi but do not make soil <br /> without microbe life.According to"The Nature and Properties of Soils" Buckman and <br /> Braddy, Cornell University, College Text of Edaphology.° <br /> 3. What is the criteria for determining that the reclamation was successful? Is it based on <br /> the soil surface being stable (no wind or water erosion), revegetation has a plant cover <br /> value of 75%of the local vegetation type, and 90%of the plants in the seed mix have <br /> germinated and are viable? There should be at least two monitoring periods at 2 and 5 <br /> years, and a plan to mitigate problems or areas that did not revegetate. <br /> Sincerely, <br /> 'S &Z'�-j T—LAX��� <br /> Sally Buckland <br />