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<br />i,/ \\ • III IIIIIIIII IIII III • <br />Pitkin County <br />~~ ECEIVED <br />JUL 14 1999 <br />13 July, 1999 , :;~~ c.i thinerals & Geolo9Y <br />VIA FACSIMILE (303) 832-8106 and <br />FEDERAL EXPRESS OVERNIGHT <br />Carl B. Mount, Senior Environmental Protection Specialist <br />Division of Minerals and Geology <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />Re: Avalanche Creek Marble & Alabaster LLC, White Banks Mine, <br />File No. M-99-042 <br />Dear Mc Mount: <br />Please let this letter serve as Pitkin County's written comments on the 110(2) <br />Reclamation Permit Application of Avalanche Creek Marble & Alabaster LLC. County staff has <br />reviewed the Application submitted by Avalanche Creek Marble & Alabaster LLC and Pitkin <br />County has the following objections. <br />6.3.4(1)(c)(iii), page 2 of Exhibit D of the Application, Species to be Planted. Pitkin <br />County objects to the use of Climax Timothy and Smooth brome for reclamation because both <br />species aze non-native and invasive. We recommend eliminating Climax Timothy altogether and <br />replacing Smooth brome with Mountain brome instead. <br />6.3.4(1)(, Estimate of Actual Cost of Reclamation. Pitkin County objects to the <br />estimated cost of reclamation as being too low for the following reasons. First, the County <br />Wildlife Biologist has visited the site and based upon existing vegetation, feels that twenty (20) <br />seedlings per acre and five (5) trees per acre is inadequate revegetation. Thirty (30) seedlings per <br />acre and ten (10) trees per acre is more consistent with existing vegetation in that area. The <br />seedlings should be 50 gallon shrubs and the trees should be at least 72 inch Engelmann spruce <br />or lodgepole pine, the two species currently existing in the permit area. The sizes are <br />recommended to increase the likelihood that the trees and shrubs will survive. The County's <br />research into costs indicates that spruce trees cost $38.00 per foot. Thus, for 14 trees at a height <br />Administration County Commissioners County Attorney Finance and Use Tax <br />530 E. Main, Suite 301 Suite 301 Suite 302 530 E. Main, Suite 201 <br />Aspen, CO 81611 530 E. Main Street 530 E. Main Street Aspen, CO 81611 <br />(970) 920-5200 Aspen, CO 81611 Aspen, CO 81611 (970) 9205220 <br />PRINiE00N FAX 920-5198 <br />® (970) 9205150 (970) 920-5190 FAX 920-5230 <br />REGYCLE~P~PER <br />