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<br />mine bench that does not drain into the rock check/silt fence control area. The <br />small lower road topsoil stockpile located east of the coal waste disposal site is <br />another small area exemption, with vegetative cover sediment control. <br />All of the various existing small area exemption sediment control features <br />will be eliminated by reclamation operations. The revision plan will need to <br />include amended small area exemption sediment control plans for the <br />reclaimed portal bench area and reclaimed lower road topsoil stockpile area, <br />including appropriate maps, narrative, and modeling to demonstrate the <br />effectiveness of proposed control measures. <br />4. The current reclamation schedule is described in the narrative on page 3-1, and <br />the timetable is presented in Table 3.7-2. Given CAM's decision to initiate <br />reclamation as soon as 2007, the reclamation timetable will need to be amended, <br />to the extent that there would be changes to the schedule specified in the current <br />plan. We would request that "Year 1 ", "Year 2", etc. be revised to specify 2007,- <br />_ 2008, as appropriate. <br />Preliminary discussions indicate that CAM may desire to complete the entire <br />reclamation project in a single field season (or at least the reclamation of the <br />portal bench, canyon section of the access road, and the coal waste disposal area). <br />This may present certain reclamation sequencing and access problems associated <br />with revegetation. The plan requires broadcast seeding, followed by straw <br />mulching, and application of tackifier by hydro-mulcher. If all the regrading and <br />topsoiling work associated with the mine bench and access road is completed <br />prior to initiation of seeding, it maybe impossible to access upper segments of the <br />road and the portal bench with seeding and mulching equipment. As such, it may <br />be necessary to keep the seeding equipment on site for significant periods of time <br />during the on-going grading operations, so that seeding/mulching can be <br />periodically undertaken as logical and accessible areas of dirtwork and seedbed <br />preparation are completed. In this way, grading and seeding could be <br />accomplished more or less concurrently as work proceeds down the road from the <br />portal bench. Coordination of this process with the approved seeding seasons <br />(March/April, July IS-August 30, and October 15-December IS) may present <br />some difficulties. Additionally, if BLM places restrictions limiting reclamation <br />activity between December I and May 1, scheduling maybe further complicated. <br />Equipment access to the portal bench area may be difficult following reclamation <br />of the access road (without causing signifcant re-disturbance). Some repair of <br />channel and hillslope erosion, grading associated with repair of minor slumps or <br />settling cracks, and similar maintenance activities are commonly warranted in the <br />first couple years following reclamation, particularly on steep slope sites. For <br />this reason, it may be prudent to delay reclamation of the access road until a <br />stabilizing vegetation cover has become established on the portal bench reclaimed <br />area. <br />