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Ms. Katie Fendel May 25, 2005 Leonard Rice Engineers Page 2 • Wetland Findings -This would require at least a wetland delineation of the CDOT right of way. If wetlands are found, a Wetland Finding describing measures taken to avoid and minimize impacts to wetlands, and a mitigation plan would be required. • ArcheologicaUPaleontological Clearances -Archeological and paleontological studies must be conducted to determine the presence and location of cultural and paleontological resources. Based on my review, these studies have not been conducted. Additionally, CDOT may require additional documentation such as a noxious weed management plan. Reclamation Requirements The restoration plan (revised Exhibit F and C-2C) dated March 23, 2005 is inadequate to ensure the stated intent: `...To return the MMRR Quarry site to apost-mining condition as wildlife habitat. Replacement of a plant growth medium and species selection is based on the objective of emulating or improving upon the general condition of the site vicinity as wildlife habitat." My concerns are based on a roadside review of the property and aerial photographic interpretation and are as follows: • The applicant plans to restore the site to strips and patches of grasslands with a few shrubs and trees (20 per acre). This is not the pre-mining wildlife habitat of dense shrubs (200 to 500+ per acre) and scattered trees (see attached photo). The existing xeric upland shrublands at the site contain more shelter, a more complex vertical vegetation structure, more varied ecological niches and other important wildlife features than the proposed grassland. • The terraced sideslopes separated by 50-foot vertical cliffs provide less valuable wildlife habitat than the existing shrub-covered hillsides. • The applicant proposes to restore the ephemeral streams to "establish important habitat for flora and fauna of the area." The permanent diversion ditch A, which is either in bedrock or is rock lined, does not meet this goal. The plans show now no attempt at any restoration along this ditch. • Additionally, the meandering channels in Exhibit F only show a small channel with a very few trees and shrubs planted along the edges. We recommend planting more riparian trees and shrubs (such as wild rose and common snowberry) on the banks of the stream channel to improve wildlife habitat. • The applicant states that topsoil maybe imported but does not describe the source location. Depending on from where the topsoil is salvaged, hauling topsoil may be cost prohibitive and import noxious weed seed. • According to the applicant, inorganic and organic amendments maybe added to the fines. We recommend using only stow-release organic amendments such as Biosol; otherwise, the amendments would only promote weed growth Consultants in Natural Resources and the Environment