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Page 6 <br />Mitch Simmons <br />November 2, 1979 <br />6. In order to successfully reconstruct the Pfann Draw alluvial <br />fifer, it caill be necessary to tie the clay barrier in with the <br />bottom of the undisturbed alluvium, upstream and downstream of the <br />permit area. This will necessitate replacing the alluvium at <br />approximately its original thickness. Information provided in the <br />application indicates that the present thickness of the alluvium in <br />Diann Draw is several times greater than the 5 feet which the applicant. <br />proposes to replace. Please address this concern. <br />7. 1The applicant states on page 21R that "excess water will be <br />mped into sedimentation ponds." My comment of September 7 still <br />applies (pg 5, V e). <br />Design calculations haven't peen provided fur the. 12" culverts <br />© on the mine haul roads. <br />The statement on page lOR, regarding final removal of sedimentation <br />ponds, no longer bears any resemblance to the actual complex system <br />of ponds and ditches portrayed in figure 17A. The applicant should <br />explain the proposed sequence of final reclamation in greater detail. <br />10, The organization of pages 21R, 21A'and 22R, is confusing (especially <br />tfie sentence at the bottom of page 21R). Please correct this. <br />VII. Lildlife <br />Mitigation of adverse impacts on the sage grouse strutting ground <br />(Denmark lek) remains a significant concern to the staff. The applicant <br />is advised that the existing state regulations require that the mining <br />and reclamation plan give special attention to "those species which <br />require special consideration (e. g. grouse strutting grounds)" (Rule <br />6.3 a). Similarly, the federal interim regulations require that, where <br />wildlife habitat is included in the postmining ].and use, the revegetation <br />plan be designed to "fulfill the needs of wildlife" (715.20 e 4). Finally, <br />the federal permanent regulations require that the applicant "minimize <br />disturbances and adverse impacts on fish, wildlife, and related environmental <br />values" (816.97a); and "Locate and operate haul and access roads so as <br />to avoid or minimize impacts to important fish and wildlife species" <br />(816.97 bl) Although the federal permanent regulations do not apply to <br />the Bourg mine at this time, the applicant i.s advised that within a year, <br />this operation will be required to comply either with these regulations <br />or with essentially identical state regulations. <br />(con['d) <br />