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<br />Suzanne Benton <br />-2- <br /> <br />January 11, 1996 <br />............................................. <br />4-b <br />8. 3.1.9 - Topsoiling -Topsoil is a precious commodity. The applicant needs <br />to save as much as possible in order to replace an -S~fifi°inch layer in the <br />disturbed area. The more nutrient rich topsoil that is placed in the <br />disturbed area, the better your chances are of successfully revegetating the <br />disturbance. This could mean an early release of reclamation <br />responsibility. <br />Pursuant to Rule 3.1.9 a vegetative cover or other means shall be <br />employed so that the topsoil is protected from erosion. The applicant <br />proposes to allow the stockpile(s) to "revegetate with weeds" and suggests <br />that, since there is very little rainfall, water erosion will not be a problem. <br />If the applicant allows the topsoil stockpile(s) to revegetate with weeds it <br />may become very difficult to successfully revegetate the disturbed areas <br />aher replacing the topsoil since most weed species outcompete the grass <br />species for water and nutrients. If weeds become a problem then, pursuant <br />to Rule 3.1.10(6), the applicant will be required to initiate a weed control <br />program which, ultimately, could be very expensive. <br />The Division is aware that the San Luis Valley does not receive very much <br />moisture. However, the Division is also aware that, occasionally, parts of <br />the Valley receive a considerable amount of its annual precipitation during <br />a brief summer rainstorm. These 1-3 inch storm events can have an <br />enormous impact on an unprotected stockpile of topsoil. Large amounts of <br />the material can be carried away in just a short time. A properly vegetated <br />stockpile, on the other hand, will not erode very easily due to the <br />protective plant cover (reducing the impact of the rain drops) and the <br />established root systems (binding the material together). <br />It is important that the operator save as much topsoil as possible and to <br />protect whatever topsoil that is saved. Since "vegetating with weeds" is <br />not an acceptable method to protect the topsoil stockpile(s) I suggest you <br />propose "other means" of protection or commit to vegetating the material <br />with one, or more, species of the approved seed mix. <br />~`(/ 10. 3.1.7 -Groundwater -You did not respond to the question "will the <br />mining operation adversely affect groundwater quality?" Please address. <br />12. 6.4.5(2) -Your response to this concern is "Refer to Exhibit G". Exhibit G <br />says "see section 6.4.3(f) on Exhibit C (continued)". Section 6.4.3(f) of <br />Exhibit C speaks of water, water rights, and a recharge pit. Section 6.4.5(2) <br />refers to the reclamation plan and the proposed post-mining land use. The <br />county selected rangeland as their proposed post-mining land use. As <br />noted, this is an acceptable land use. As also noted, the county plans to <br />