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i <br />Memo to Christine Johnston -2- January 19, 1994 <br />3. It appears that the reference area discussion in MCC's permit application has been revisited <br />on several occasions and subsequently has been brought into compliance with <br />Rule 4.15.7(3). I believe this section is adequate. <br />4. I believe that the species included in the permanent seed mix do meet the requirements of <br />Rule 4.15.1(2)Idl. I have included some suggestions below that should enhance diversity and <br />wildlife preference for reclaimed areas. <br />Additional Comments <br />1 ~/Please have MCC clarify the wording in paragraph 2 of page 3-80, Exhibit 54. I do not <br />believe that "treatment," as implied by the last two words of the paragraph, is an option <br />under the circumstances described. <br />2. a) / Please have MCC provide average topsoil stripping depths used in each of the soil types <br />S 56,E Su. ~~~ indicated on Map 41 and the areal extent to which each area was stripped. It appears <br />i~ that they have much less topsoil salvaged than is expected, given the information e <br />w ~~' provided in Exhibits 27, 28 and 29. i ~ : ( G' <br />b) ,/ Map 41 needs to be updated to include all areas currently disturbed (coal refuse pile) <br />and any areas that are proposed to be disturbed in the remaining five-year permit term. <br />Average topsoil salvage depth for each soil type should be included on this map. <br />c) ~~ The December 1, 1993 Envirocon map submitted by MCC during the recent topsoil <br />balance revision does not coincide with permit Maps 56 -Topsoil Removal Plan, and <br />57 -Topsoil Replacement Plan. Please have MCC clarify which maps are correct and <br />adjust their topsoil balance and other reclamation figures accordingly. If the Envirocon <br />map is accurate, MCC should submit a revision to replace Map 57 with the Envirocon <br />map and include justification of each area of discrepancy between that map and <br />approved permit Map 57 and any figures calculated from the Envirocon map. <br />Note: My calculations, using approved maps from MCC's permit, show that an average <br />thickness of only 10.2 inches of topsoil is available for reclamation of approximately 76 <br />disturbed acres, not 15 inches for 52.2 disturbed acres as MCC states. Study of aerial <br />photos and permit maps and conversation with MCC Environmental Department <br />personnel lead me to believe that the Envirocon map topsoil replacement areas are <br />somewhat understated. <br />3. a) To enhance wildlife habitat quality and species diversity of reclaimed areas, a couple of <br />highly palatable non-wheatgrass species of grasses should be added to those indicated <br />as "always included in seeding mix." Of these two grasses, one should be a sod former <br />and the other a bunchgrass. Native or "approved introduced" species are acceptable. <br />b) Page 2.05-59 correctly states that reclaimed area standards for woody stem density are <br />1000 stems per acre. Unless I missed something, all I can find for woody stem <br />revegetation is MCC's plan to plant seedlings at a rate of 900 stems per acre on <br />30 acres. The acceptable rate would be: <br />1000 stem/acre x 110 acres which equals 3667 stems/acre in shrub clumps <br />30 acres of shrub reclamation <br />