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In a letter dated March 7, 2003, Henderson revised the amendment AM-004 application to provide for <br />the construction of tree and shrub "islands" on the tailing impoundment. Impoundment areas outside <br />of the tree and shrub islands would be reclaimed by placement of 6 to 18 inches of topsoil (average 12 <br />inches) and revegetation with the approved seed mix. No tree and shrub plantings will be required <br />outside of the islands. The islands will consist of discrete areas where thicker cover (minimum 3 feet) <br />will be placed over the mill tailing, and revegetated in accordance with the seeding, tree planting, and <br />shrub planting plan approved in the original Henderson Mill reclamation permit. In the March 7, 2003 <br />letter, Henderson suggests that the ore surge pile could be used to create the thicker cover for the soil <br />islands, but that if the surge pile were not available, the additional cover material would be imported <br />from off-site or borrowed from the Henderson gravel pit. Since the filing of the Mazch 7, 2003 letter, <br />the DMG has communicated to Henderson that use of the surge pile material would not be approved <br />for construction of the soil islands due to potential for acidity in the plant rooting zones. For the <br />purpose of reclamation cost estimation and reclamation bonding, the DMG will assume that the <br />additional cover material for the tree islands will be borrowed from the tailing impoundment perimeter <br />in the same manner as documented in the DMG reclamation cost estimate for task 09e previously <br />provided to Henderson. The volume of additional cover soil to be borrowed will be equal to the <br />volume of the ore surge pile as documented in DMG's cost estimate for task 09a, which is 166,667 <br />loose cubic yards. This is in accordance with Henderson's March 7, 2003 letter. This volume of loose <br />dirt will settle approximately 11 percent upon placement in the islands allowing this additional <br />borrowed cover soil to be sufficient to construct approximately 46 acres of tree islands. The areal <br />extent of the tree islands was calculated as follows: <br />Surge pile volume: 166,667 loose cubic yazds. <br />Earth loam will settle approximately 11 percent following placement. <br />Three foot minimum thickness required for tree islands; reclamation permit already requires <br />and average of one foot soil thickness over the tailing surface. <br />0.89 x 166,667 loose cubic yards = 148,334 settled cubic yards = 4,005,008 cubic feet <br />4,005,008 cubic feet / 2 feet thickness = 2,002,504 square feet = 46 acres <br />The DMG evaluated the sufficiency of 46 acres of tree islands as follows. Assuming that 92 islands <br />each one-half acre in size were to be installed on a grid over the entire 1,100 acre pond surface, the <br />spacing between the islands would be approximately 525 feet. This would yield a maximum range <br />from cover for wildlife of just over 250 feet, which is more than adequate according to DMG wildlife <br />experts. Evaluation of a grid of identically sized and spaced tree islands is done only for a check on <br />the sufficiency of the cover fill volume proposed by Henderson. For the execution of the tree island <br />plan, the DMG has stipulated that Henderson will provide a technical revision with a plan and design <br />for the tree islands. The plan should have variations on island size, shape, spacing, and cover thickness <br />to maximize the benefit to wild and domesticated animals. The DMG suggests that the largest islands <br />be in the 2-acre size range and that large islands be incorporated at a rate of at least one for every 40 <br />acres. It is further suggested that a variety of island sizes be constructed from one-quarter acre on up. <br />The location and spacing of the various sized islands can be established considering migration, <br />foraging, and predator pathways that should become established on the reclaimed impoundment over <br />time. Also to be considered are the edge effects where the impoundment reclamation will transition to <br />the surrounding reclaimed and undisturbed areas. <br />