1997-06-05_REVISION - M1981302 (12)

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THEREFORE I request that additional data and analysis of the proposed topography on groundwater, rare species and their habitats, and related effects be submitted. NON-NATIVE SPECIES 13) The currently approved seed mix includes non-natives that are detrimental to establishment of natives. Mr. Carl Mount wrote a 5/16/86 letter discussing this. THEREFORE I request that the seed mix be modified to include only natives. INSUFFICIENT TOPSOIL IS PRESENT ON MUCH RECLAIMED LAND AND IS REQUIRED TO ATTAIN THE END USE 14) I have documented and discussed the insufficiency in my letters of 4/20/97 and 7/15/96. The DMG expectation that 6-8 inches of topsoil depth is being replaced is confirmed in its correspondences; e.g. the 11/14/89 inspection report of Daniel Hernandez and the 4/30/97 letter from Mr. Gregg Squire to Mr. Michael Hart. Both the vegetation description in the 1981 permit application and the Soil Conservation Service data for the soil map units indicate that much of the site contained ample topsoil or overburden or to begin with (contradicting Mr. Michael Hart's 5/14/97 letter). THEREFORE I request that CMLRB uphold its own requirement that revegetated areas be topsoiled to the committed 6-8 inches minimum depth. WITNESS: I am knowledgeable about and can be a witness addressing the above topics. I would prefer to have the City and/or County of Boulder and other citizens address these first, particularly the first three issues, and then I would appreciate having an opportunity to add comments that were not already covered. EXHIBITS: I incorporate into this statement all the letters I have submitted to the Division, with all attachments; including 7/15/96, 9/18/96, 4/20/97, 5/12/97, and 5/13/97. I assume that all Division letters to the mine operators or which are part of the files are also incorporated. I endorse the exhibits proposed to be submitted by the City and County of Boulder and other objecting parties. Other exhibits- - State of Colorado Executive Order 8491: Evaluation of Flood Hazard .... - Letter of 9/30/96 from Professor Gilbert White to Chancellor Roderic Park - Presentation to Boulder County 10/15/96 by Jane Bunin, PhD, Ecologist - Reclamation plan maps submitted to Boulder County for the Deepe Farm Pit in 1981 and 1988 (too large to copy for distribution). - A map showing the locations of rare plants and animals and management areas in the vicinity of the Deepe Pit, prepared by City of Boulder or Jane Bunin. RXEBunin, y yoy�rs, J PhD Ecologist