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6.4.5 EXHIBIT E -Reclamation Plan <br />Please refer to the mining plan exhibit comments with respect to topsoil salvage and <br />replacement and clarify the amount of topsoil that will be replaced. Under the seeding <br />portion of the reclamation plan, it is stated that azeas "may" be mulched if needed. Given <br />the sandy nature of the soils in this location, mulching or cover cropping will almost <br />certainly be necessary to achieve desirable revegetation establishment. Please include <br />these options in your response and commit to implementing one or the other or both <br />options. Also, if mulch is used it should be stated that only "certified noxious weed free" <br />mulch will be used. <br />With respect to noxious weeds or undesirable plant management, since there aze very few <br />to no such species currently on site, a more detailed accounting of how the listed species <br />will be monitored and/or controlled must be included. This might begin with a <br />commitment to annual or semi-annual site monitoring for the various species listed in the <br />application. Included in the plan would then be an action plan if any of these species <br />were to be observed on site. This might include a commitment to implement aspecies- <br />specific control plan in conjunction with the El Paso County Weed Control District that <br />would include the various treatment options for that particulaz species. By approaching it <br />this way, you can avoid preparing a plan for species that will likely never show up. <br />On the other hand, the species of most concern aze the knapweeds, spurges, and thistles, <br />so the action plan may include immediate control measures to be implemented if one of <br />these species appears on site. Exactly how you tailor the plan it is up to you, however, a <br />cleaz commitment to monitor and manage for invasive species must be included in the <br />application. Furthermore, since the proposed site and the sun•ounding areas are noxious <br />weed free, final bond release will require this site to be free of noxious weeds as well. <br />One native grass species that was observed on site during the pre-operational inspection <br />and is not included in the permanent seed mix is sand bluestem. In addition, sand <br />dropseed and needleandthread are mentioned as dominant native plants in all three soils <br />descriptions but aze not included in the permanent seed mix. The mix should be revised <br />to include these species. Thickspike and streambank wheatgrass could be reduced or one <br />could possibly be eliminated to accommodate this change. At a minimum, sand bluestem <br />should be added and the mix should be adjusted to increase blue grama. <br />Finally, the temporary seed mix to be used in topsoil stabilization includes several <br />introduced grasses. [n your meeting with The Nature Conservancy and the local soil <br />conservation district, you committed to the use of native seed in reclamation. Although, <br />these species aze not being directly seeded on reclaimed azeas, the replacement of topsoil <br />that has been seeded with this mix will inadvertently introduce these species onto the <br />reclaimed azeas. There aze other native species that can be used in place of these species. <br />For instance, blue grama could be substituted for crested wheatgrass, perennial ryegrass <br />and smoth brome and western wheatgrass and sideoats grama could be increased. Please <br />revise the mix accordingly. <br />