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i ~ • <br /> <br />J.E. Stover & Associates -24- May 31, 1996 <br />Bowie No. 2 Mine <br />17, Premining Topography, it appears that there will be <br />several culverts which will be installed by the operator <br />which will be left as permanent structures after <br />reclamation. These culverts appear to be associated with new <br />and old road construction. It appears that some of these new <br />roads also will remain as permanent structures. According to <br />Rule 4.03.1(7)(a), these roads and culverts can be retained <br />as permanent structures only if the structures are <br />compatible with the intended postmine land use. Also, the <br />consent of the landowner is needed if these new roads and <br />culverts are to remain as permanent. Therefore, please <br />provide a statement that demonstrates that these new roads <br />and culverts can support the approved postmine land use. <br />Also, please provide the necessary landowner consents, if <br />applicable, for retention of these structures. <br />2.05.4(2)(e) Topsoil Redistribution <br />The topsoil redistribution plan is very vague with respect to <br />what depths of topsoil will be reapplied. This is somewhat <br />understandable since the soil survey can only provide a <br />reasonable estimate of the topsoil resource and many unforseen <br />activities can cause this number to change. The Division is <br />therefore planning to stipulate the permit to require that a <br />revision be submitted which clearly defines how much topsoil will <br />be redistributed upon completion of salvage operations. Based on <br />the available information, this will should be between 24 and 30 <br />inches of suitable soil on average over the entire disturbed <br />area. <br />2.05.4(2)(e) Reveqetation Plan <br />The use of yellow sweetclover is not recommended for use in <br />either interim or final reclamation as it is considered somewhat <br />of a nuisance plant in some areas. Therefore; <br />73. Yellow sweetclover should be replaced in seed mix 1 and 2 <br />with another clover such as alsike or red clover or even <br />another leguminous forb. <br />74. No species diversity standard was proposed for the area that <br />will be reseeded with the upland seed mix. BRL should <br />submit a diversity standard that is reflective of the <br />diversity in the baseline communities, keeping in mind that <br />the reclaimed community will not nearly mimic the baseline <br />community. It should probably include at least three <br />dominant graminoids and one forb. <br />The Division realizes that comparing the anticipated reclaimed <br />community (mostly grasses and forbs and a few small shrubs) to <br />