2003-03-31_REVISION - M1977344 (2)

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Division of Minerals and Geology March 31, 2003 Page 14 of 17 downstream. The DOW believes that the diversion of the creek will result in the removal of all wetlands/riparian habitats, which will severely impact the wildlife resource on and adjacent to the property. Bear Creek provides excellent potential habitat for Arkansas Darter (State Threatened) and Southern Red Belly Dace (State Endangered). The DOW suggests that mining occur in increments, to allow proper reclamation of affected lands before moving on to the next area. The DOW also suggests designation stream crossings for mining equipment and areas of impact to minimize the influence of mining to Bear Creek and the Arkansas River. The DOW suggests that reclamation efforts provide the same form, function, and value that existed previous to mining operations. The DOW is not in formal opposition to the proposed amendment. We suggest that Holcim contact Casey Cooley of the DOW at 719-277-5100 and discuss with him what Holcim is proposing to mitigate the destruction of wetlands and riparian habitat. Holcim, after talking with Mr. Cooley, may want to consider revising the mining and reclamation plans to include the restoration of Bear Creek. Provide your response to the DOW concerns in this exhibit. Response As discussed above in the response to Item 29, the mining of the lower Bear Creek watershed will disrupt the present hydrogeologic system. Once reclaimed, even if the Beaz Creek channel would be re-established to its current alignment, it is unlikely that the channel would be recharged and become the gaining stream it currently is. Wetlands would therefore not be sustainable. In recognition of this, Holcim has worked with the Army Corps of Engineers to mitigate the lost Bear Creek wetlands through establishing replacement wetlands along the Arkansas River adjacent to Hardscrabble Creek, located to the west of the Holcim plant site. On January 31, 2003, Holcim communicated with Mr. Cooley of the Division of Wildlife, and discussed the site, the pre and post-mining hydrology, and the 404 Permit wetlands mitigation plan. A copy of the conceptual wetlands mitigation plan was forwarded to DOW on Februrary S, 2003. A copy of the transmittal letter is attached to this response. Exhibit L-Reclamation Costs Item No. 33 DMG: The regulations, at Rule 6 Section 4.12, require that the application include all information necessary to calculate the costs of reclamation and that the information must be submitted and broken down into the various major phases of reclamation. The information provided by the operator/applicant must be sufficient to calculate the cost of reclamation that would be incurred by the state. The Division will want to review reclamation cost information based on the worst case situation, which will most likely exist when the topsoil attd overburden are removed from the cut 2 and 3 areas. At that time, the pit in the northwest corner will most likely still be open with vertical highwalls and it is the Division's understanding that the overburden from cuts 2 and 3 will be located on the west side of Bear Creek. Provide the information necessary to complete backfill operations; site grading to approved reclamation slopes; topsoil replacement to the required depth and revegetation including soil tillage operations, seed and seeding operations, fertilization, mulching and weed control in accordance with your reclamation plan. Provide volumes of material remaining to be blasted plus blasting costs to reduce highwalls to 3h:ly slopes. Provide the volume of material to be hauled to pit backfill sites and the haul distances. Provide this same information for topsoil hauling and placement. For all structures in the permit area to be removed upon reclamation, provide Holcim Response to Amrndmrnt Adequacy Review.doc