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MMRR Quarry, M-2004-067 <br />Response to June 30 Adequacy Review (as amended) <br />August 19, 2005 <br />Page 12 <br />land, as soils will be thicker and amended as appropriate for plant establishment, <br />and the topography will be conducive to slower runoff and higher levels of soil <br />moisture. The proposed seeding and planting regime will enhance forage <br />opportunities for the diversity of wildlife found within the regional context. Cliffs <br />and more acreage with a north aspect may also create new opportunities for <br />nesting and breeding of certain species at the site. <br />Elk have been noted as a wildlife species known to range through the site. <br />However, the site is not preferred elk range due to its proximity to a busy <br />highway, lack of water, and limited forage. The reclamation plan will improve the <br />suitability of the site for elk range and wildlife generally found in Gilpin County <br />through improvement of plant growth conditions (relative to the current <br />impoverished soil conditions) and resulting forage potential. In addition, cliffs and <br />flatter topography present new opportunities for special niche habitats. For <br />example, a number of raptors and other bird species may be attracted to <br />reclaimed highwalls. <br />33. The applicant has specified that they will replace topsoil at a thickness of 2-4" for areas to be <br />revegetated. The Division recognizes there is minimal topsoil available for salvage and use in <br />reclamation; however, for best re-vegetation success we suggest the applicant consider a <br />minimal soil cover of at least 6" for areas to be reseeded to a grass mix, and a soil cover of at <br />least 24" for areas to be planted with tree and shrub transplants. (Up to T S" of the 24"soil cover <br />may be comprised of subsoil and/or plant processing fines). With these considerations, the <br />applicant may want to prioritize areas for topsoil use where grass, and tree and shrub growth is <br />desired. Please respond. <br />Consulting the various Rules pertaining to reclamation and reclamation <br />performance standards, the application of a minimum 6" topsoil requirement to <br />the entire disturbed area of a given site does not appear to be required, directly <br />or indirectly. Rule 6.4.5(1) calls for flexibility in such quantitative requirements, <br />and the successful implementation of a reclamation plan is guaranteed by Rule <br />4.17.1(1) and the various warranties executed .by an applicantloperator. The <br />purpose of the Construction Materials Act, as implemented through agency <br />Rules, is to promote revegetation and other conditions prerequisite to post- <br />mining land use through whatever appropriate measures may be taken by the <br />operator. A prescriptive approach is not indicated, and a 6" uniform topsoil layer <br />is also not indicated by analysis of site-specific conditions at the MMRR Quarry. <br />The MMRR Quarry site, and its environs generally, are dominated by poorly <br />developed soils.. The 2-4" layer currently called for, applied across the site, will <br />provide an enhanced plant growth medium relative to existing conditions. <br />Nonetheless, the objective of this reclamation plan is to enhance wildlife habitat, <br />and the primary mechanism to do so is by enriching the biological capacity of the <br />site by enhancing its plant growth potential. The operator will therefore commit to <br />a range of topsoil thickness from 2-8" in depth, with an average depth no less <br />than 4". In general, this plant growth medium will be more than sufficient to <br />