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~i The presence of beaver in the Dolores River valley are also not mentioned in the wildlife information. The area where the pre-existing drain pipe is said to discharge exhibits considerable evidence of past and ongoing beaver activity. It is not known if noise and vibration from the proposed gravel operations would adversely affect the resident beaver population, but this possibility is not even mentioned in the assessment of mining impact on wildlife. Tlie proposed mitigation for wildlife impacts is stated to be reclamation of all disturbed areas, on- eoineduring [he operation of [he mine. However, the mining plan does not indicate [hat any reclamation will take place until the fourth year of operation (Exhibit pg 11), and further states that it will not be possible to reclaim significant portions of the site until almost all mining is done (Exhibit pg I5). This seems to be at variance with what is stated in the wildlife mitigation proposal. EXHIBIT J -VEGETATION INFORMATION, Exhibit Pg 39 No. 6 -General instructions regarding seeding and care, second paragraph. Mowing seeded areas on or about June I" is recommended to help control weeds, but the recommendation does not state how long (ie one year, five years, ten years) that this practice should continue. Also, this practice will not be affective for controlling bindweed, and will do little to control thistles, unless mowing takes place multiple times during the summer months. Thistles that are mowed simply resprout or form Flower heads on [heir shortened stocks and produce seed. As most thistles are bi- annuals, existing plants need to be kept from reseeding for a minimum of two years to produce any significant reduction in [heir numbers. Mowing of [he areas around [he reclaimed Twin Spruce gravel pi[ by a full-time caretaker has resulted in good control of thistles for most areas, with [he exception of the northern-most pond, the last pit to be reclaimed. It has taken diligent mowing throughout the summer months for a period of at leas[ five years to accomplish this level of control. Efforts by Mountain Gravel to successfully reclaim this gravel mining operation, located approximately 1 mile north of the proposed Line Camp Pit, should be used as a model and standard for all future gravel pit reclamation within the river valley. EXHIBIT L -RECLAMATION COSTS, Exhibit pg 42 The estimated reclamation costs were reviewed by a local contractor (name withheld by request) who specializes in mine reclamation. In [lie contractors professional and experienced opinion, the estimated costs for reclamation are significantly underestimated in several instances. For example, the costs for backfilling from stockpiles and top soil replacement appear to be underestimated by almost two-thirds. A total of 68,000 cubic yards of material are estimated for containment within the soil/overburden stockpiles. Approximately 48,400 cubic yards of this material will be used for topsoil replacement and backfilling (Exhibit pg 12). The total estimated cost for backfilling is $31,300 (Exhibit pg 42), or about 65 cents per cubic yard. Even with an estimated markup of 15%, [his is still less than $1.00 per cubic yard of material. According to [he local contractor [hat reviewed the cast estimates for the Line Camp Pit, a much more realistic cost estimate for backfilling would be $3.00 per cubic yard for materials that are moved a distance of less than 200 feet. In the words of [he contractor, "moving dirt for a dollar per cubic yard went out with Prohibition". Other cos[ estimates are unclear or unstated. Recommendations for revegetation of areas at the edges of the ponds include collecting native willow cuttings from areas along the river and planting them at the interface between the water and land (Exhibit pg 38). Plantings of other native species, such as -7-