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f <br />2- <br />Veoetation (continued) <br />3. Unless MCC plans on using a Rotoclear or a chipper to reduce the cleared shrubs to a <br />size conducive to use for mulch, all brush should just be cleared and disposed of. <br />Better yet, MCC could live haul loader buckets of shrubs and transplant them on <br />areas of the coal refuse pile that are due to be reclaimed. Shrub clumps of <br />approximately 2 acres are preferable. <br />Soils <br />1. MCC's permit indicates that most if not all of the proposed disturbed area for TR-67 <br />is within the Absarokee Work Loam Soil Classification Zone. The permit indicates <br />(Table 301 that topsoil salvage depths for Absarokee soils average 20 inches. By my <br />calculations 17.4 acres of disturbance with 20 inch depth of salvaged topsoil should <br />yield 46,880 yds3. MCC indicates a salvaged topsoil volume of 35,000 yds3. Please <br />have MCC substantiate their predicted salvage volume. <br />2. Soil descriptions for this type of soil specify that Absarokee Soils are "subject to <br />packing and irreversible puddling if handled wet". I suggest we restrict MCC. from <br />disturbing any topsoil until soil moisture conditions are conducive to disturbance with <br />minimal compaction and soil structure degradation. A Soil Conservation Service rule <br />of thumb states that topsoil should not be handled when moisture content is greater <br />than 75% of field capacity. <br />3. The best revegetation results are characteristically found on soils that are placed and <br />seeded directly after being salvaged. Better soil structure due to one-time handling <br />and increased soil microbial activity are two of the major contributors to this fact. <br />MCC should be required to direct haul as much of the topsoil salvaged from the <br />TR-67 disturbance as is needed to cover the areas of the coal refuse pile that are due <br />to be reclaimed this year. MCC will need to submit a topsoil balance for this <br />operation. Another benefit from this practice, in addition to improved revegetation, is <br />the reduction of disturbed area due to a smaller or non-existent topsoil pile <br />requirement. <br />Wildlife <br />1. MCC should provide documentation that the Colorado Division of Wildlife and the <br />U.S. Fish and Wildlife Service have been provided an opportunity to comment on the <br />effects, to wildlife, that may be caused by the proposed disturbances related to <br />TR-67. <br />If there are any questions or if MCC wishes to discuss some of my recommendations, <br />have them contact me. <br />/ern <br />M:\oss\ern\westelk.ss <br />