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MMRR Quarry, M-2004-067 <br />Response to Jan. 21 Adequacy Review <br />March 23, 2005 <br />Page 20 <br />site. The blasting plan will conform to DMG standards regarding peak <br />particle velocity. <br />2.) The project engineer's attached memorandum notes that plans have <br />been revised to include benching in the noted entry drive and <br />processing areas. <br />3.) The applicant shares the DMG's concern that bonding must be <br />adequate to fulfill the applicant's commitment to bench the quarry walls <br />to a stable configuration when reclaimed. The applicant also shares <br />the DMG's belief that benches at the perimeter of the proposed ten- <br />year mining area are the best estimate of the maximum extent of <br />mining and reclamation that must be examined for the purposes of <br />bonding. <br />We believe that forfeiture of the bond at this quarry should not <br />necessarily require the DMG to implement the final benching <br />configuration shown topographically on the Reclamation Plan Map, <br />Exhibit F. For example, if the bond were to forfeit after only five years <br />of operation, the area of disturbance and/or depth of mine are likely to <br />be substantially less than the extent of impact accounted for on the <br />Reclamation Pian Map. Practically speaking, the DMG would be <br />forced to act as an agent of additional land disturbance and sell or <br />otherwise remove large quantities of rock from the site to implement <br />benches in the exact Exhibit F configuration. This is contrary to the <br />intent of the Reclamation Act and this specific Reclamation Plan, which <br />is to restore the site to a condition as viable wildlife habitat as soon as <br />possible after the cessation of mining. It should therefore be allowable <br />to reclaim slopes and highwalls to a stable configuration as close as <br />possible to the limits of disturbance at any stage of mining. A note has <br />been added to Exhibit F to reflect this understanding of necessary <br />flexibility in the Reclamation Plan. <br />In terms of reclamation costs for highwall areas, at no time will <br />highwalls exceed the stable configuration noted in the report of Dr. <br />John Abel, P.E. and carried through in the Mining and Reclamation <br />Plan Maps for this proposal. The mining plan involves blasting <br />benches to a stable configuration as each face is worked. Drilling and <br />blasting work on each face of rock will be complete once the area is <br />mined, and reclamation will involve replacement of subsoil (fines) and <br />topsoil and establishment of vegetation. As suggested in the <br />adequacy comment, the applicant therefore commits to operating the <br />quarry such that final reclamation benching for each aspect of the <br />