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2018-04-09_REPORT - C1981022
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2018-04-09_REPORT - C1981022
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Last modified
4/10/2018 7:07:39 AM
Creation date
4/10/2018 7:00:08 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981022
IBM Index Class Name
Report
Doc Date
4/9/2018
Doc Name
Annual Reclamation Report Adequacy Review
From
DRMS
To
Oxbow Mining, LLC
Annual Report Year
2017
Permit Index Doc Type
Annual Reclamation Report
Email Name
LDS
Media Type
D
Archive
No
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Doug Smith <br />Page 2 <br />April 9, 2018 <br />Mountain Penstemon and Western Yarrow are synonyms for the specified Bluebunch <br />Wheatgrass, Penstemon strictus and Achillea millefolium, respectively). <br />Two of the specified species were consistently missing from the Oxbow seed mix (Silver <br />Sagebrush, and Pacific Aster), and Douglas/Low Rabbitbrush was substituted in for <br />Rubber Rabbitbrush. The lot shipped on August 1, 2017, was also missing Fringed <br />Sagebrush. <br />In future, if species from the approved seed mix are unobtainable, please work with <br />the seed supplier to propose a suitable alternative. <br />Weeds identified as requiring control during 2015 were "thistles, hounds tongue and <br />whitetop". Oxbow employees sprayed disturbed areas with Curtail herbicide, which is <br />manufactured by Dow Chemical and approved for use in Colorado. Curtail is described <br />as "a broad-spectrum broadleaf herbicide providing outstanding control of Canada thistle <br />and other problem weeds in small grains", and is mentioned specifically in the weed <br />control plan in Exhibit 2.05-E6. <br />Reclaimed areas were inspected for rills and gullies deeper than nine inches, but none <br />were identified. <br />* Based on my analysis of Exhibit 1, there are several issues with the data submitted on the ARR <br />form which require your attention: <br />• The sum of the disturbed areas equals 226.99 acres as reported, but the sum of the seeded <br />areas (excluding partially reclaimed) equals 128.85 (not 153.47), of which 27.62 acres <br />were seeded in 2007 or earlier (not 24.26). <br />• There are 40 rows with a green background indicating that reclamation was completed in <br />2017. The sum of the acreages reported in those 40 rows is 43.28, (not 48.6). I am unable <br />to account for the 5.32 acre discrepancy. <br />• For each GVB pad the acreage given includes the spur road. In those cases where the <br />landowner has requested that the road remain, the area of the road should be subtracted <br />from the area reclaimed. For the pads reclaimed in 2017 where the road was left at the <br />landowner's request, I calculate a total length of 6,137 feet. Using 18 feet as an average <br />road width, this gives an area of 110,466 square feet, or 2.54 acres. (I also note that GVB- <br />LW 18-01 B was tagged with "HR ROAD LEFT" but no road length was given — having <br />studied map 2.05-M1.6, together with the aerial image, it appears that the pad was built <br />immediately adjacent to the permanent two track road). This would give a total area <br />reclaimed in 2017 of 40.74 acres (43.28 - 2.54) <br />• A similar situation occurs for four pads reclaimed before 2017 (GVB-LW 10-05, 12-03, <br />16-04 and 16-05). For these four I calculate a total road length of 5009 feet, giving an <br />area of 90,162 square feet, or 2.07 acres. This would give a total area reclaimed prior to <br />2017 of 83.50 acres (128.85 - 43.28 - 2.07) <br />
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