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<br /> <br />Mr. Mark Heffner - 4 - June 5, 1989 <br />Item 2: No additional response is necessary; however, as you have recently <br />mentioned in telephone conversation that as much as 25% of the proposed <br />affected area will not be receiving replacement topsoil, be prepared to <br />discuss this item with the Board at the Formal Public Hearing. <br />Item 3: No additional response is necessary. Thank you. <br />Item 4: No additional response is necessary. Thank you. <br />Item 5: No additional response is necessary. Thank you. <br />Item 6: No additional response is necessary. Thank you. <br />Item 7: Please incorporate the Antelope Bitterbrush into your seed mixture as <br />recommended by the Colorado Division of Wildlife for wildlife habitat <br />improvement. You state that this species experiences difficulty establishing <br />due to intensive browsing. However, as the operator is proposing concurrent <br />reclamation, it is likely the high level of ongoing activity will discourage <br />overgrazing. Please adjust your proposed bond amount accordingly. <br />Item 8: Please incorporate the addition of backfilled wildlife escape ramps <br />for benches with lengths greater than 250 feet. Although you state that these <br />are not necessary because of the proposed short bench lengths, some of the <br />lower-elevation benches exceed the 200-300 foot length that the DOW recognized <br />as possibly detrimental to wildlife. Discuss how these will be revegetated, <br />and adjust your proposed bond amount accordingly. <br />Item 9: As you state that "if a particular seeding produces about 3 or fewer <br />plants per square foot, a secondary seeding would be done", no additional <br />response is necessary. Thank you. <br />Item 10. To respond to your statements "for the most part, the assessment of <br />success will be done on a visual basis. That is all we believe the law calls <br />for or was intended to require.", Rule 6.5 requires, among other things, a <br />vegetative cover replaced at least equal in extent of cover to the natural <br />vegetation of the surrounding area. It would be in the operator's best <br />interests if a quantitative, pre-disturbance vegetation survey of the Phase <br />III area were provided as a baseline for species composition, cover and <br />denisty. This will be especially beneficial to Castle Concrete as, according <br />to your response, they have committed to a quantitative vegetation analysis <br />prior to requesting bond release. Please address. <br />Item 11. It is possible to leave twelve-foot highwalls upon reclamation. <br />This can be accomplished by mining highwalls to a maximum height of twenty <br />feet and backfilling eight feet as you propose. Achieving the 4H:IV slope you <br />have committed to would require minimum bench widths of only 32 feet, which is <br />not significantly different from the revised mining plan. Please address. <br />Item 12: No additional response is necessary. Thank you. <br />Item 13: No additional response is necessary. Thank you. <br />