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2020-10-27_PERMIT FILE - M2020035 (3)
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2020-10-27_PERMIT FILE - M2020035 (3)
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Last modified
1/9/2025 4:17:34 AM
Creation date
10/27/2020 10:00:33 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M2020035
IBM Index Class Name
Permit File
Doc Date
10/27/2020
Doc Name
Adequacy Review Response
From
Greg Lewicki & Associates, PLLLC
To
DRMS
Email Name
ACY
THM
Media Type
D
Archive
No
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Exhibit E <br /> The Division would advise against the use of irrigation in support of vegetation establishment <br /> for reclamation, Rule 3.1.10(1). Irrigation can lead to salt accumulation in the soils, leach out <br /> soil nutrients leading to the need for fertilizer, and favor less drought tolerant species which are <br /> unable to sustain once irrigation ceases and outcompete those species that would have <br /> naturally thrived in the and climate.A potential alternative may be an upland dry rangeland <br /> mix then a less and rangeland mix for the fringe areas. <br /> DRMS advice is appreciated. <br /> 13. Typo on page E-1. Should it be 31.8 acres? <br /> The typo has been corrected. Please see the revised Exhibit E. <br /> 14. Page E-2 states overburden volumes are based on 5 feet. Section 3 and 7.2 of Exhibit D <br /> assumes 6 feet of overburden for calculations. The same volumes are given but different <br /> input values are utilized. <br /> Six feet of overburden is the anticipated average thickness. Please see the revised Exhibit E. <br /> 15. Provide the total overburden and topsoil volumes needed for Area I and Area 2 <br /> individually rather than the project total amount. Table E-2 <br /> Additional information has been added to Table E-2 to show the Area based breakout of topsoil <br /> and overburden volumes needed. <br /> 16. Section 2.2 on page E-3. Clarify how many acres of each land type will exist in each <br /> mining area. <br /> Table E-1 has been expanded to break out the land types by Area. <br /> 17. The Division does not feel that the seed mix provided in table E-2 is appropriate for the <br /> site. Please contact the NRCS for guidance. Specifically Common reedgrass is listed as <br /> a `watch species'on the Colorado Department of Agriculture Noxious Weed Lists. Also <br /> Snowberry is not an appropriate species for the site. Pursuant to Rule 3.1.10(1) a <br /> variety of warm and cool season with an emphasis on natives species is necessary to <br /> achieve diverse, robust and long lasting reclamation. <br /> See the revised seed mix in Exhibit E. It incorporates further feedback from NRCS regarding <br /> species selection. <br /> 18. Page E-2 be more explicit as to what is a `favorable season"for seeding. <br /> Please see the revised Exhibit E. <br /> 19. Provide more detail on the reclamation phases and schedule.And address the timing of <br /> reclamation of Areas I and2. <br /> Mining of both Areas will take place roughly simultaneously. Area 2 may begin mining ahead of <br /> Area 1 to create space for Area 1 overburden. See the revised Table E-4. <br /> 23 114 West Pit 4 <br /> October 2020 <br />
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