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<br />._ , ; <br />Seneca II-W Prelim. Adequacy - 3 - March 5, 1985 <br />Additionally, Table 9-6 indicates that only 6" of topsoil will be <br />salvaged from the Binco Clay Loam and Abor Clay soil types (mapping <br />units 11C, 11D, and 4D), even though the B horizons with a thickness of <br />21 - 22 inches appear salvageable. For all of the above listed soil <br />types, the applicant must provide sufficient justification for limiting <br />topsoil salvage from these areas or provide information in accordance <br />with 4.06.2(4) regarding the use and suitability of selected overburden <br />materials to be used as a substitute for topsoil. <br />Vegetation and Revegetaion - Rule 2.04.10 and 2.05.4(2)(e) <br />1. All of the reference areas for the Seneca II Mine (aspen, mixed brush, <br />sage brush, low sage, and wheat) are located outside of the permit <br />boundary for the mine. The applicant needs to demonstrate to the <br />satisfaction of the Division that they have surface control for the <br />life-of-mine for areas within which the references areas are located. <br />This is to insure that the reference areas receive the same management <br />as they have in the past. <br />2. The applicant should supply a table of the total number of disturbed <br />acres for each vegetative community during this permit term and during <br />the life-of-mine. <br />3. It has been determined that the sagebrush, aspen, and meadow <br />communities; when compared with their respective reference areas are <br />not comparable. For all these communities reported cover and woody <br />plant densities of the reference areas are higher than those of the <br />affected area. The productivity of the reference areas is reported as <br />much lower. This presents a dilemma with regard to the productivity <br />parameter. The applicant and the Division will have to determine <br />whether new references areas need to be established or whether an <br />alternative solution can be agreed upon. <br />4. The applicant needs to further explain the use of cover crops on <br />reclaimed areas. The Division has reservations regarding the approval <br />of cover crops, since many areas in northwest Colorado have abandoned <br />cover cropping due to the inherent problems with natural reseeding of <br />the cover crop, competition from the cover crop with perennial <br />revegetation species, and moisture depletion by cover crops. <br />5. With regard to the proposed seed mixes, the applicant should remove <br />alfalfa and pubescent wheatgrass from the mixes and substitute other <br />preferred species in their place. <br />6. The applicant should submit a statement in the application that any <br />species substitutions will be approved by MLRD in writing prior to <br />their use in the seed mixes. <br />