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Mr. Dave Canning <br />Page Eight - <br />April 15, 1982 <br />4.15.3 Seeding and Planting <br />A seed mix has been proposed on page 184 for "all affected land that <br />has not been excluded". It is unclear what areas will receive this <br />mix and what mix is proposed for the other areas. If the mix discussed <br />under 4.15.2 is proposed, please state this in the reclamation plan. <br />With respect to the proposed seed mix; which bluegrass and needlegrass <br />species are proposed? The Division recommends sandburg bluegrass <br />(Poa secunda) and green needlegrass (Stipa viridula). Additionally, <br />the seed mix should include native forbs, particularly a nitrogen fixing <br />legume such as mountain lupine (Lupinus alpestris), silky lupine <br />(Lupinus sericeus) or birdsfoot trefoil Latus corniculatus) if the lupines <br />are unavailable. Other appropriate forbs are: arrowleaf balsam root <br />(Balsamorhiza sagittata), blue flax (Linum lewisiil, Rocky Mountain <br />penstemon Penstemon strictus) and other available native forbs. <br />4.15.4 Mulching and other soil stabilizing practices <br />The Division recommends using native hay at a rate of 3 tons/acre on <br />the slopes and 2 tons/acre on the flat areas. The mulch should be <br />disced or tacked down to prevent loss due to wind. <br />4.15.5 Grazing <br />The applicant states grazing will not begin until the vegetation becomes <br />established. This should be expanded to say grazing will not commence <br />until Sunland Mining Corporation has demonstrated to the satisfaction of <br />the Division, that the vegetation is adequately established and could be <br />expected to withstand grazing. <br />The regulations also require the openasor to demonstrate that the vegetation <br />can withstand grazing equivalent to that which will be practiced after <br />mining for at least 2 years prior to bond release. Therefore, a grazing <br />plan must be incorporated. <br />4.15.7 Determining Revegetation Success <br />Pursuant to Rule 4.15.7(2)(vii), Sunland Mining Corporation has requested <br />the Division [o set standards based on local environmental conditions <br />and available data for similar sites. The Division has reviewed the <br />information submitted by Apex giving a qualitative description of the <br />permit area and is making recommendations based on pre-mining data from <br />similar communities provided by Energy Fuels Corporation and Pittsburgh <br />and Midway for their mine located nearby. No quantitative data was <br />provided by Apex. <br />