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IIZ • <br />Letter to Joseph de Raismes 5 May 3. 1995 <br />City of Boulder's opinion that there "is no reasonable explanation <br />why adequate soil was not set aside so the original terms of the <br />Permit could be met" (the original terms of the permit referred to <br />being the replacement of 6 to 10 inches of soil). In fact, if you <br />review the soils map and soils descriptions contained in the 1986 <br />Jenkins Pit amendment, it is evident that the disturbed area south <br />of Coal Creek consisted of approximately 26 perceent "pre-law" <br />disturbance. Pre-law disturbance is that which occurred prior to <br />regulation under the Mined Land Reclamation Act; topsoil was rarely <br />salvaged or preserved from lands disturbed pre-law. Approximately <br />57 percent of the area disturbed south of Coal Creek ways overlain by <br />Nederland Very Cobbly Sandy Loam (NdD). The A-hori::on of NdD is <br />from 3 to 6 inches thick, and the soil contains from 50 to 70 <br />percent cobble and gravel throughout the profile. Tliis is a poor <br />soil from the stand-point of reclamation potential, anti it was the <br />soil present in the areas that were the focus of gravel extraction. <br />The areas where the high quality Calkins Sandy Loam are: present were <br />not disturbed by excavation, and that soil is still in-situ at the <br />Jenkins Pit. The pervasive occurrence of poor or non-existent <br />topsoil in the area being reclaimed represent, to th~~ Division, a <br />reasonable explanation why adequate soil was not set aside so the <br />original terms of the permit could be met. Please refer to the <br />Division's April 28, 1995 inspection report for a furtY.:er discussion <br />of this topic. The Division conducted an investigation of the on- <br />site topsoil resources during that inspection. <br />7: Item number 5 in your list of concerns states that the: Division has <br />failed to take its enforcement obligations seriously. This is a <br />serious allegation which the Division believes to loe unfounded. <br />Once a complaint regarding the amount of disturbed acreage at the <br />site was filed with the Division, an inspection of the site was <br />conducted in a timely manner, compliance problems were: defined, and <br />a strict compliance schedule was specified. All actions taken in <br />this regard were in accordance with the policies and zequlations of <br />the Mined Land Reclamation Board. You further state tt:at "careless, <br />slovenly" reclamation will not remedy the problem, bui: will make it <br />worse. Two critical components of gravel pit reclamation are: (1) <br />grading so as to create a final topography appropriate: to the final <br />land use, and (2) replacement and spreading of the salvaged topsoil <br />resource. Both of these activities are being completed as part of <br />the compliance program at the site. The third critica:L component of <br />gravel pit reclamation is revegetation of the disturbed areas. The <br />operator has proposed and completed a spring seeding for the site. <br />Spring is not the optimal time to seed the area in que:ation, and may <br />not result in successful vegetation establishment, or may only <br />result in partial success. However, it is important t~~ realize that <br />the operator is required by the reclamation permit for the Jenkins <br />Site, and by the Mined Land Reclamation Act, to establ:Lsh vegetation <br />appropriate for a rangeland end-use. The operator will be subject <br />to the following performance standard, which is codified in Rule <br />