2018-10-16_PERMIT FILE - M2018039 ‎(2)‎

• Permit No: M2018039
• IBM Index Class Name: PERMIT FILE
• Doc Date: 10/16/2018
• Doc Name: Adequacy Review Response
• From: Blue Earth Solutions
• To: DRMS
• Email Name: JLE
• Media Type: D
• Archive: No

Mr. Jared Ebert
RE:Lamb Lakes Site M-2018-039
October 15, 2018
The replacement of consumptive uses will be accounted for in a new SWSP administered
by the SEO. Sources of replacement water include reusable municipal return flows from
the East Larimer County Water District. Additional sources of replacements may include
water rights owned or leased by the City of Greeley or the Tri-Districts in the Cache la
Poudre basin.
Rule 6.4.9—Exhibit I—Soils Information
11. As described in the response to Adequacy Review Comment #3, it is believed that
approximately 8 inches of topsoil was replaced following initial site mining and
reclamation activities. It is also assumed that no significant overburden was replaced
prior to topsoil placement. It is anticipated that only 4 to 6 inches of topsoil is
recoverable from the majority of the site.
Rule 6.4.10—Exhibit J —Vegetation
12. The 1987 Home Office Pit Amendment by Sterling Sand & Gravel Company indicates
that revegetation of the Lamb Lakes Site included seeding upland areas with a mixture of
Western wheatgrass, Switchgrass, Big bluestem, Inland saltgrass, Indian ricegrass, and
Sand dropseed. The amendment also specifies that, in the moist, low lying areas adjacent
to the ponds, revegetation would include Reed canarygrass, Inland saltgrass, Alkali
sacaton, and Sand dropseed. In general grasses across much of the proposed Lamb Lakes
site have become well established.
Although a detailed vegetation cover and identification study was not performed, an
additional site investigation was performed in early October 2018 to better define
vegetation on the site (see Attachment Q. Further evaluation indicates that the major
grasses populating uplands on the site are wheatgrasses, Big bluestem, and Smooth
brome. Although Smooth brome was not included in the original reclamation seed mix, it
was in the seed mixture used to stabilize soil stockpiles. In more moist areas,
switchgrass, upland saltgrass, Alkali sacaton, and various species of rushes and sedges
dominate. Mowing is still being used on-site and appears to have minimized growth of
nuisance and unwanted weeds. Near the permit boundaries and lake edges, however,
mowing is not performed and the grasses grow tall. Kochia is most prevalent adjacent to
the unimproved roads where disturbance still occurs. In moist areas where mowing does
not occur, sporadic thistle grow was observed.
Currently, the vegetation cover serves to stabilize slopes and lake shorelines. In areas
that receive regular mowing, bunch grasses are more dense than in areas where mowing
is not performed. However, with or without mowing, coverage appears to be from 30 to
40 percent in upland areas. In areas not covered by upland grasses, the ground is covered
with a layer of organic detritus. In moist areas, vegetation cover is almost 100 percent.
The exception areas are adjacent to, and on, the unimproved roads where rock and soil
are still exposed. In upland areas, especially adjacent to the permit boundary, shrubs and
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