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<br />• The DOW requests that the applicant conduct water quality monitoring on a monthly basis <br />at the upstream and downstream sites of the Purgatoire as well as at the mouth of <br />Lorencito Canyon. The applicant has modi£ed the monitoring plan to conduct montlily <br />flow and field monitoring and quarterly water quality sampling at these sites. The <br />Division considers this response adequate. <br />Lack of topsoil <br />The applicant predicts that due to steep slopes and azeas of bedrock exposure, a deficit of topsoil <br />will exist at the conclusion of surface mining. The DOW requests that the applicant import <br />topsoil to the site to address this shortage. <br />The Division would like the applicant to further investigate topsoil replacement options. The <br />Division is concerned that valuable topsoil is proposed not to be salvaged in certain azeas. <br />Topsoil is defined by Rule 4.06.2(2)(6) as soil horizons on the surface prior to mining that will <br />support plant life. The reclamation plan calls for .7 feet of topsoil to be distributed over 901 <br />acres of the surface mine. However, the Division is confused by permit text on page 2.05-35 <br />which states "reapplication may be limited to south-facing slopes where revegetation conditions <br />will be more difficult". If .7 feet is to be re-applied over 901 acres, why does the permit text <br />indicate approximately 1(2 of the surface mine azea will be reclaimed without topsoil? <br />Information needs to be consistent between what is represented in the various tables and <br />calculations and what is in the permit text. <br />• If topsoil will not be re-applied in certain azeas, these azeas need to be indicated on a map. <br />Topsoil re-application depths for all other azeas should also be cleazly 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% aze 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 />Shrub reve etationplan <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 he accomplished while also <br />accommodating the landowners desire to reclaim the azea 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 azeas of open grassland. This not only reduces grass competition but <br />increases edge, improves vertical diversity, allows for development of micro-habitats, and <br />