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• ! <br />RECLAMATION PLAN <br />1 . The approved reclamation plan states that "Backfilling will create at least one island, and as many as <br />two islands, material allowing". This statement clearly indicates that the second island is optional, the <br />first is not. The wording "at least one" would not have been used in this sentence if the "material <br />allowing" applied to both islands. Rick Sherman of the Colorado Division of Wildlife concurs that the <br />island is a very important habitat feature in the originally proposed reclamation plan. Safe nesting areas <br />and safe areas for rearing young are more limited in this area than is open water. <br />The requirement for construction of an island in the West Lake was a commitment made by the operator <br />when they applied to receive a reclamation permit to allow mining at this location, it will not be waived <br />unless the applicant proposes to substitute alternate wildlife habitat enhancement features, or change <br />the post-mining land use. If enough material is not available on site, the operator will be required to <br />import enough material to create the island. <br />2. The Division recommended that the reclamation seed mix be revised to enhance the potential for <br />successful reclamation within a shorter time frame, provide improved diversity of wildlife habitat, prevent <br />erosion of reclaimed slopes, reduce the problems and expenses incurred for control of noxious weeds, <br />and remove a species (Russian olive) from the revegetation plan that is rapidly moving it's way up the <br />list of undesirables for planting in riparian areas. This recommendation was not arbitrary, and the <br />insinuation that any of these comments are arbitrary is not accurate nor is it appreciated. The <br />recommendation was provided, based on past experience, to benefit the operator and help achieve <br />successful reclamation. <br />Rick Sherman of the Colorado Division of Wildlife has recommended that Russian olive be replaced by <br />species such as sumac and native buffalo berry. He has indicated that these species are available <br />through the Colorado State Forest Service. Incidently, the operator has indicated in conversation that <br />they have no problem with replacing Russian olive with these species. <br />The current revegetation plan is not acceptable for use on the proposed West Parcel, as it is neither <br />diverse or effective in establishing stable reclamation conducive to the post-mining land use. Please <br />submit a revegetation plan for this parcel that adequately addresses the requirements of the Rules and is <br />conducive to the post-mining land use of reclamation with emphasis on wildlife habitat. The plan should <br />include species that will provide erosion control and help prevent invasion by weeds. Because grazing of <br />the area by geese has been identified as a problem, the plan will need to include measures to prevent <br />grazing of the revegetated areas until the vegetation becomes established. <br />It is recommended that the seed mix for the East Parcel be revised to include greater diversity of <br />species. The needle and thread proposed in this mix is not recommended for a recreation area, and <br />should be replaced by more desirable species for this post-mining land use. Grazing protection will also <br />be needed on the East Parcel revegetated areas. <br />3. Response adequate. <br />MINING AND RECLAMATION MAP <br />1. Please revise Exhibit L-1, to account for the revisions specified in Comment No. 4 under the Mining <br />Plan heading above. <br />2. Response adequate. <br />