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2022-05-13_REVISION - M1977300
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2022-05-13_REVISION - M1977300
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Last modified
5/16/2022 8:45:14 PM
Creation date
5/16/2022 8:56:16 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
Revision
Doc Date
5/13/2022
Doc Name
Adequacy Review Response #2
From
Colorado Legacy Land
To
DRMS
Type & Sequence
AM6
Email Name
AME
MAC
Media Type
D
Archive
No
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COLORADO LEGACY LAND <br /> estimate for topsoil replacement.Please be advised,the reclamation bond must include costs for <br /> retopsoiling any areas to be revegetated for reclamation.Therefore,please add retopsoiling costs back to <br /> the bond estimate.In order for the Division to calculate the bond estimate for retopsoiling disturbed areas, <br /> additional information is needed.First,please clarify whether the operator intends to borrow topsoil from <br /> undisturbed areas within the permit area and/or create a growth medium from a combination of on-site <br /> materials.Second,please specify exactly where on site the operator intends to obtain the growth medium <br /> required for reclamation.Third,please describe how the operator will verify the on-site material is suitable <br /> for revegetation.Fourth,please provide an average depth of growth medium placement(that is no less <br /> than 6 inches).Lastly,please clarify the total amount of disturbed lands to be retopsoiled is 12.7 acres. <br /> e.The line item for Seed Mix covers seeding 12.7 acres with the grass/wildflower mixture approved in AM- e. Yes,the seed mix shall be planted on all disturbed areas. Please note the correct acreage is 12.5,not 12.7. This has been <br /> S.Below this task,there are separate line items for planting trees and shrubs in disturbed areas above and corrected on Figure F-1. <br /> below the cutoff wall.Please clarify the grass/wildflower mixture will be planted on all disturbed areas, <br /> and the tree and shrub mixtures would be planted in addition to the grass/wildflower mixture in the areas <br /> specified. <br /> f.The line items for Trees(planted above the cut-off wall)and Willow Stakes(planted above the cut-off f. CLL expects that the trees and willow steaks will be planted in the same 4-acre area. As described in Exhibit E,a site- <br /> wall) each state that approximately 4 acres will be planted with the species specified for that line item. specific planting plan shall be prepared after the alluvial valley excavation project is complete. This plan shall define the <br /> Please clarify whether the same 4 acres will be planted with each of these mixtures or if 4 acres will receive extent of disturbed lands that need to be reclaimed and specific exact quantities and locations for mitigation planting. <br /> the tree mixture and a separate 4 acres will receive the willow mixture.In other words,will a total of 4 or 8 The planting plan shall be submitted to USFW,USACE and DRMS to ensure all applicable regulatory requirements are <br /> acres above the cutoff wall be planted with these mixtures?(Note the Division is requesting the specific satisfied. <br /> seed mixtures in Exhibit F,as the seed mixture approved in TR-23,which is referenced in this estimate, <br /> does not include trees and shrubs.) <br /> g.The line items for Trees(planted in reclaimed valley below cut off wall),Shrubs(planted in reclaimed g. CLL expects these shall be planted over a 6-acre area. <br /> valley below cut off wall)transported as 1 gallon pots,and Shrubs(planted in reclaimed valley below cut <br /> off wall)transported as 5-gallon pots each state approximately 6 acres will be planted with the species <br /> specified for that line item.Please clarify whether the same 6 acres will be planted with each of these <br /> mixtures.In other words,will a total of 6,12,or 18 acres below the cutoff wall be planted with these <br /> mixtures?(Note the Division is requesting the specific seed mixtures in Exhibit F,as the seed mixture <br /> approved in TR-23,which is referenced in this estimate,does not include trees and shrubs.) <br /> h.Please explain why the total quantity of Trees(planted in reclaimed valley below cut off wall)went from h. The previous version of this table inadvertently referenced an incorrect value. This error has been amended.The 89 <br /> 147 down to 89 in the revised estimate. trees shown in the Table L-1 match the maximum number of trees required for reclamation in the Biological Opinion that <br /> was submitted to USFW. A summary of this information has been added to Exhibit E for clarity. <br /> i.The line item for Hydro mulching includes no costs,because it is"only required on 2H:1V and steeper i. The operator is not proposing to apply any mulch. The approved language in Exhibit E does not require mulching in <br /> slopes,which are not present in the valley".The Division understands the disturbed areas in the valley flatter(less and 2HAV)areas. <br /> proposed for revegetation are flatter than 2HAV.However,there are no costs included for conventional <br /> mulching in these flatter areas.Is the operator proposing to not apply mulch on areas in the valley that will <br /> be seeded/planted for reclamation?If a mulch will be applied,please add a line item for this task including <br /> the type of mulch,application rate per acre,and application method. <br /> j.If the operator intends to incorporate any amendments into the growth medium for reclamation,please j. Previous on-site reclamation work has been successful without amendments and therefor the operator does not expect <br /> include costs for this task.Additionally,please specify the type of amendment(s)to be used and the or intend to incorporate any amendments into the growth medium for reclamation. <br /> proposed application rate <br /> Exhibit L-Reclamation Costs(Rule 6.4.12): <br /> The Division has the following comments specific to the Environmental Monitoring section: <br /> 21 <br /> a. In its adequacy item#36(a),the Division required the operator to adjust the Surface Water a. Revised as requested. <br /> Monitoring costs to cover quarterly sampling over a full 10-year period.In its response,the <br /> operator stated"revised as requested".However,the revised cost for this item does not cover <br /> PAGE 8 OF 12 <br />
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