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. - ~_ <br />DATE: November 9, 1992 <br />TO: Harry Ranney <br />FROM: Tony Waldron <br />~ iii iiiiiiiiiiiiiiii <br />999 <br />RE: Carbon Junction Mine (C-82-054) Soils and Vegetation Review <br />As requested, I have completed my preliminary adequacy review of the Carbon Junction <br />Mine's Mining and Reclamation permit application. As you know, we met with Darry <br />Ferguson of Carbon Junction to discuss any potential shortcomings or problems that may <br />arise. Following is a list of my concerns and question about the application, some of <br />which are reiterated from the meeting. <br />1. On page 4-16 there is reference to quantitatively describing the Mountain shrub and <br />Pinon-juniper vegetation communities occurring within the permit area. Apparently <br />this was done so the text needs to be raised to indicate where this information is at <br />when it was accomplished. <br />2. On page 4-17 (2) the narrative describes some convoluted logic about the difficulty <br />of using reference areas without identifying what success standards will be utilized <br />over the majority of the permit area. Please have the operator expand on this logic <br />or delete this portion of the narrative and add reasonable success standards. Also, <br />the cropland success standard is 19 bushels/acre of wheat production. Are there <br />any conservation compliance measure for crop residue? For instance, based on any <br />crop subsidies or other Department of Agriculture programs, the operator may need <br />to leave a certain amount of residue on the surface of the soil. This information <br />should also be provided. <br />3. Page 4-18(5) refers to a lack of prime farmland. A letter from the local SCS office <br />confirming this will need to be submitted and should also be added as an exhibit. <br />4. As we discussed, runoff from topsoil stockpiles or other disturbed areas which does <br />not flow into a sediment pond will need to have approved SAE demonstrations. <br />5. Page 5-28(2)(el(ii) and liii) makes reference to deciding how many woody plants <br />will be replaced. This should be updated to describe how many actually will be <br />replaced. 1,000 live stems/acre is the normal minimum standard. They need to <br />describe in detail how many shrub clumps or islands will be planted, how the will <br />be planted, where the will be planted, etc. A map with location would be nice. <br />