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Grand River Park Project, M-2006-046 <br />Response to Adequacy Letter of August 1, 2006 <br />6 September 2006 <br />Page 9 <br />Should salvageable topsoil prove deficient to meet the preferred minimum depth <br />of 6 inches, the operator will provide a minimum depth of at least 4 inches, as <br />previously stated. In this circumstance, as well as a general practice to improve <br />the plant growth medium, the operator may use fines material to amend the soil <br />in backfilled areas. This plan will provide a plant growth medium at least as <br />productive as the existing condition and appropriately suited to meet reclamation <br />performance requirements. <br />13.On page thirteen of the application, in the first paragraph under <br />revegetation, the applicant commits to implementing the recommendations <br />of the NRCS with respect to revegetation of the site. However, in the <br />second paragraph under revegetation, the applicant states that "The site <br />will be seeded in the fall or at any time of year..." This statement conflicts <br />with the NRCS recommendations, which specify planting dates. Please <br />clarify what time of year seeding will take place. <br />As stated in Exhibit E of the application, the applicant intends to follow NRCS <br />guidelines regarding time of year that seeding will take place. The NRCS letter <br />provides for seeding at all times of year, with the exception of dates from May 1 <br />to June 14 and again from July 16 to October 14. The referenced quote <br />concerns mulching practices, which may vary from NRCS guidelines in the fall, <br />when the climate is cool and runoff is less intense. Nonetheless, the operator <br />has, as noted in a full reading of the quoted passage, the option of mulching at <br />any time of year, and the operator will, in any event, be required to achieve a <br />satisfactory land cover prior to release from reclamation. <br />14. Note 4 on the Reclamation Plan Map indicates that the temporary <br />landscape features will be either removed or maintained at the option of <br />the owner. The Division requests that the operator commit to either <br />removing the features or leaving them in place with adequate vegetation <br />established to provide adequate protection from erosion. Please respond. <br />The landscape berms include vegetation for screening as well as seeding to <br />stabilize the soil for the duration of their use. It is reasonable to assume that, at <br />the time of final reclamation, the berms will qualify for release according to any <br />Construction Materials standards related to their stability and role in the post- <br />mining use. Based on the applicants review of applicable standards, there <br />appears to be no rational basis for the Division to disallow vegetated berms in the <br />reclaimed condition. Likewise, it is common practice to remove topsoil stockpiles <br />and reseed in their footprint. <br />There is no evident basis for disallowing either of these alternatives. The <br />applicant will therefore provide a bond for the marginally more costly of these <br />