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n Ron Bell -2- December 27, 1995 EXHIBIT D -Mining Plan The landowner (BLM), in a letter to the Division dated November 21, 1995, states that restrictions will probably be imposed on when work can be conducted at the pit. The restriction is that the pit would be closed December 1 through April 30. The Division, from statements made by Lynn Lewis of the BLM at the preoperation inspection, understands this restriction to include all activities at the pit. Please correct and clarify this part of your application. You will need to do the same for the reclamation plan -Exhibit E. 2. Your mining plan states that, "material removed from the top of the previously - mined area in the formerly out-0f--bounds region..." The BLM in their November 21, 1995 letter states that, "No mining should occur in the reclaimed area of Phase 1.' Please identify this area on the Mining Plan Map, and address this concern. This should also be addressed in your reclamation plan. 3. The south edge of the mining limits boundary (affected lands boundary) is, in part, in the bottom of a small natural water course. Please move this part of the boundary at least 50.100 feet north to keep equipment from disturbing this drainage. Commit to setting mining limit markers in this area to keep equipment operators out. EXHIBIT E -Reclamation Plan 1. You have included Muttongrass as a revegetation specie and a topsoil stockpile stabilization specie. My references show Muttongrass to be Poa fendleriana for which there may not be a commericial seed source. Please provide evidence of a commercial seed source and an industry recommended seeding rate. If you are • not referring to Poa fendleriana please provide the same information for the specie intended. Make any appropriate changes, if any, needed to the two seed mixes. 2. The Shavano Soil Conservation District's review of your reclamation plan includes • a recommendation that where slopes exceed 3:1 terraces should be constructed to minimize sheet and rill erosion and prevent gully erosion. Your plan addressees measures that may control sheet and rill erosion, after successful revegetation. However, due to the steepness of the reclamation slopes, some erosion of the plant growth medium is inevitable and unacceptable gully erosion may get started. Please address the measures that will be taken to prevent excessive soil erosion. A recommendation of the Division is that reclamation be implemented immediately after smaller increments of land have been mined, rather than waiting until large areas such as all of phases 2 or 3 are mined. The Division suggests that reclamation take place as soon as possible after each succeeding 2-3 acre parcel is mined. With the consent of the landowner, you should consider installing terraces or diversions designed by a qualified entity such as the Natural Resources Conservation Service, or at least commit to do so if erosion indicates a need for such practices. M:~OSS~amm~eell.ldo