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PERMFILE45544
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PERMFILE45544
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Entry Properties
Last modified
8/24/2016 10:47:55 PM
Creation date
11/20/2007 12:23:50 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2004067
IBM Index Class Name
Permit File
Doc Date
5/25/2005
Doc Name
Objections to Amended Appl
From
Hayes Phillips Hoffmann & Carberry PC
To
DMG
Media Type
D
Archive
No
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Ms. Katie Fendel May 25, 2005 <br />Leonard Rice Engineers Page 3 <br />and may adversely affect the growth of native species. The costs of these <br />amendments should be included in the cost estimates. <br />• Erosion control methods should include hydromulching with tackifier, and use <br />of a variety of erosion control blankets. <br />• The xeric seed mixture is generally acceptable, although it may need to be <br />altered to be more site-specific. The xeric mixture includes big bluestem, a <br />species that requires a lot of moisture. Also, the mix does not include many <br />rhizomatous grasses such as western wheatgrass. 12hizomatous grasses have <br />root systems that help stabilize steep slopes and would be especially desirous <br />on the steep slopes of these sites. <br />• The applicant plans to seed using hydroseeding, which is not the most <br />appropriate method for seeding dry sites. For hydroseeding to be successful, <br />the site must have enough water to keep the seeds moist; as a general rule, <br />hydroseeding is unsuccessful in areas receiving less than 20 inches of <br />precipitation a year. The average precipitation in this area is between 9 and 12 <br />inches a year. <br />• Because of the dry and steep conditions of the area, portions of the site may <br />need to be reseeded several times, especially if hyrdoseeding is used. <br />• Many of the upland shrub species such as mountain mahogany are difficult to <br />establish. These slow-growing species will probably require supplemental <br />watering, protection from browsing, miccorhyzal inoculations, and other <br />techniques to encourage successful establishment. <br />• The stated planting medium of 2 or more feet of fine materials with a very thin <br />layer (2 to 4 inches) of topsoil may not be an adequate medium for growth of <br />the shrubs and trees described in the plan. <br />• The reclamation cost estimates (March 23, 2005) are very low for topsoil <br />placement, grading, seeding and planting. These cost estimates are not <br />adequate for the successful establishment of wildlife habitat. For example, a <br />CDOT project in Black Hawk in 2000 had a seeding bid of $1,600/acre; the <br />MMRR quarry project reclamation plan is estimated at only $400/acre for <br />seeding. The average bid for deciduous shnab costs for planting and <br />installation on CDOT projects in 2000 was $21.88 per shrub, which is much <br />higher than the $4.35 to $8.80 cost proposed for this quarry project. <br />• This reclamation plan does not address noxious weed control. Noxious weed <br />invasion could detrimentally impact the stated goal of re-establishing the pre- <br />existing wildlife habitat. Also, the Colorado State Noxious Weed Control Act <br />requires weed control for particulaz species. <br />• This reclamation plan does not include monitoring to determine if wildlife <br />habitat has been established. Success criteria should be established for <br />percentage of native species cover establishment and native shrub survival. <br />The site should be monitored annually to determine if the success criteria <br />outlined in the monitoring plan has been met. Also, noxious weed species <br />cover should be monitored, and methods for weed control should be outlined. <br />Consultants in Natural Resources and the Environment <br />
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