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• Division of Wildlife Issues and_ Responses <br />for June 5, 1997 Letter <br />(continued) <br />If topsoil will not be re-applied in certain areas, these areas need to be indicated on a map. <br />Topsoil re-application depths for all other areas should also be clearly represented. The Division <br />will not approve a plan that is "field controlled" by subjective estimates and daily site conditions. <br />With the exception of bedrock outcrops and an occasional extreme slope, it is the Division's <br />observation that topsoil, as defined, exists over the vast majority of the surface mine area. <br />The Division does not agree with the applicant that slopes of 30-35 % are too steep for topsoil <br />salvage. Conversation with equipment manufacturers indicates that topsoil can be easily removed <br />on slopes of 50% and greater, if necessary, using proper care and safety procedures. Equipment <br />manuals also give recommendations for increasing fluid levels for equipment operation on slopes <br />of 100% (1:1). <br />The Division concurs with the DOW concern related to topsoil salvage and re-application and this <br />issue remains inadequate at this time. <br />Response <br />• LCC has revised the topsoil salvage plan to include slopes up to 50 percent. As a result, the <br />replacement depth on all surface disturbance areas will be approximately one foot. Appropriate <br />changes to the mining and reclamation plan have already been made to reflect this commitment. <br />Shrub revegetation Qlan <br />The DOW has recommended that the current land-use of rangeland/wildlife habitat be maintained <br />on the surface mine. The Division believes this objective can be accomplished while also <br />accommodating the landowners desire to reclaim the area to improve cattle grazing conditions. <br />One way to satisfy both parties is to conduct shrub re-establishment efforts in concentrated areas <br />while leaving other areas of open grassland. This not only reduces grass competition but increased <br />edge, improves vertical diversity, allows for development of micro-habitats, and improves chances <br />of successful shrub re-establishment. The DOW has recommended shrub varieties, but has <br />deferred the decision on location and measures to determine success to the Division. Factors that <br />should be considered with regard to location include: <br />* distance from undisturbed edge; <br />* locations in drainages; <br />* location to brush and rock piles; <br />* north vs south aspect; <br />* flat vs steep areas; <br />* proximity to water resources; and <br />. * type of shrub related to area of re-establishment. <br />10 <br />