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Mr. Rick Mi11s - 2 - September 10; 1987 <br />approximately 170 acres of the Wadge disturbance area, in order to <br />enhance shrub reestablishment. <br />The benefits of reduced topsoil depth with respect to woody plant <br />establishment have been suggested by some researchers, but no conclusive <br />demonstrations have been made within aspen and mountain shrub habitats <br />typical of the proposed revision area. An area to be reclaimed within <br />the Eckman Park Area 9/10 this fall should provide an opportunity to <br />compare shrub establishment on 10" versus 18" of topsoil depths, but <br />several years will be required before differences in vegetation <br />establishment can be evaluated. <br />Alternative topsoiling practices might be appropriate as an experimental <br />practice, but the performance standards of the regulations disallow <br />approval of the plan as presented. Specifically, Rule 4.06.2 requires <br />that topsoil be removed from areas to be affected by surface coal mining <br />operations. Specific variances from topsoil salvage are allowed for good <br />cause shown under specific circumstances, but the variances would not <br />apply to the proposed Wadge Mine area, and as a result the plan as <br />proposed is not approvable: <br />3. The topsoil redistribution pla <br />Page 2.05-52 is not consistent <br />handling tables. <br />n for the Wadge area as presented on <br />with other sections of the text or topsoil <br />Backfi111ng and Gradi <br />4. Insufficient detail has been submitted regarding the area of undulations <br />proposed for the Wadge area to allow us to evaluate the impact to <br />adjacent reclaimed and undisturbed areas: The proposed area extent and <br />location of the features should be depicted on the post-mining topography <br />map, appropriate cross sections should be developed and any diversions or <br />other erosion Control measures associated with the undulations should be <br />described and depicted on appropriate maps or drawings. <br />5: We are concerned with the wording regarding rill and gully stabilization <br />on Page 2.05-48: The final sentence on the page is too open to <br />interpretation to be enforceable, and the sentence should be deleted. <br />Specific deadlines for completion of the annual rill and gully survey and <br />necessary repair work should be included in the plan. <br />6. A permanent gully identification and stabilization plan should be <br />included in the application. <br />Revegetation <br />We are concerned with the deletion of woody plant density monitoring from <br />the vegetation monitoring plan on Page 2.05-69, given the importance of <br />reestablishing woody plants and the reliance on live topsoil handling in <br />the LMC area. Please see comments number one and two of our May 13; 1987 <br />letter regarding soil sampling and vegetation monitoring at Eckman Park. <br />These comments would also apply to the Little Middle Creek reclamation <br />plan: <br />