_REVISION - M1981302 ‎(119)‎

• Permit No: M1981302
• IBM Index Class Name: Revision
• Doc Name: AFFIDAVIT OF WARREN R KEAMMERER PH D
• Type & Sequence: AM2
• Media Type: D
• Archive: No

• changes in the status of Ute Ladies Tresses Orchid or in the general condition
of the vegetation.
(ArR,A. M. 1995. The genetics,demography,and conservation
management of the rare orchid Spiranthes diluvialis. Ph.D.dissertation.
University of Colorado, Boulder. 170 pp.)
o The proposed change would not create as much potential habitat on the
reclaimed areas for this species.
While pond margins surrounding created ponds provide wet soil conditions;
they do not apparently provide suitable habitat for Ute Ladies Tresses
Orchid. I do not know of any existing populations of this species that have
developed on any gravel mined lands in the Boulder Valley. Therefore, it is
not likely that Ute Ladies Tresses Orchid would naturally colonize the
margins of the ponds created as part of the existing reclamation plan.
o If the proposed change does not provide enough topsoil, their the planted
species would not be successful and the site would become covered with
weed species. These weeds would then expand onto adjacent properties and
thereby impact Ute Ladies Tresses Orchid.
If the site is inadequately reclaimed,that is,the topsoil is inadequate to
support self-sustaining vegetation,then the Division of Minerals and
Geology would not deem the reclamation to be successful and the
reclamation bond for the property would not be released. Western Mobile
would then need to alter their reclamation procedure in order to establish
self-sustaining vegetation on the mined lands. Also,Western Mobile will
develop a weed control/management plan that will assure that any noxious
weed species that develop on the reclaimed lands are kept under control.
Noxious weeds [most notably diffuse knapweed (Centaurea dii fusa) and
Canada thistle (Cirsium arvense)]are abundant on open land throughout
Boulder County, and numerous individuals and public agencies are actively
working to control these species. The techniques used by these agencies can
be incorporated into a weed management program for the reclaimed areas.
Western Mobile already has a weed control program in effect that has been
used to control Canada thistle on lands that have been reclaimed at the Deepe
Farm Pit.
5. The Division ofMinerals and Geology has recommended approval ofAmendment
001 for the Deepe Farm Pit with the condition that "...Western Mobile provide a soil
testing plan that would verify the replaced plant growth media's ability to support the
plant species to be established in reclamation." This plant must be provided in the
form of a revision to the permit and must be received no later than 30 days after final
action by the Mined Land Reclamation Board on Amendment 002 and must be
approved no later than 45 days after initial submittal.
Western Mobile will develop a soil testing plan that will examine the nutritive
qualities of the topsoil material that has been stockpiled on site. The plan will
include, at least in part,the collection of samples from all topsoil stockpiles. These
samples will be sent to the Colorado State University for analysis relative to standard