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The great majority of the wetlands on the project site are located topographically above the mining ce[Is and <br />derive their waterfrom un-impacted sources (i.e. theponds or irrigation waters which are hypothesized as the <br />source of the seep wetlahds). These wetlands cannot be impacted by the scope of the proposed project. Of <br />the remaining wetlands, the oxbow wetland segment between cells 3 and 4 derives its water from the ponds <br />above. Therefore, this wetland is not likely to be impacted by mining. The wetlands along the toe of the <br />terrace scope have not been impacted, as determined by the empiricat conditions on-site to date (mining has <br />already occurred downgradient). With reclamation of these cells, water table levels will rise topre-mining <br />conditions. <br />5. There is a concern about the quantitative measure of wetland species for parts of the mitigation (which <br />involves the transplant of existing wetland topsoils to another area). It is requested to have a quantitative and <br />qualitative description with which to monitor the success of the mitigation. <br />A special condition will be implemented involving success of greater Than 50% of wetlands species and 40% <br />total vegetative cover to ensure success of the mitigated wetlands. See the specific explanation ofspecies in <br />the comment responses letter dated October 17`", 2003. <br />6. Since the existing oxbow has a heterogeneous configuration, it is uncleaz how the mitigation oxbow will be <br />configured and success criteria should be implemented. <br />According to the applicant, the proposed mitigation oxbow configuration has greater sinuosity than that of <br />the oxbow segments to be disturbed. While the design identifies the size parameters for the construction, it is <br />common for actual "as-built" conditions to vary slightly from the design. If the concern is that the low jlow <br />channel is too uniform, the applicant can ensure that some variability is built into the oxbow channel in the <br />field. Of paramount concern is that the oxbow drains properly so as not to impound or artificially increase <br />evaporative losses. The overall width of the proposed oxbow channels varies from 30 to 50 feet for the <br />wetland portion of the channel, again providing variability. <br />7. Has the loss of lineaz feet of oxbow resource type have been completely compensated for? <br />The length of the oxbow wetlands proposed for disturbance is 2150 feet. The preferred alternative proposes <br />creating 2750 linear feet in the primary oxbow feature and 600 linear feet in the secondary oxbow feature. <br />This plan is considered sufficient in functions and values to compensate for lost oxbow wetlands. <br />8. The Applicant proposes to install two piezometers at the proposed mitigation site. The Corps should <br />determine if this is an adequate number of wells to monitor ground water to support successful wetland <br />mitigation when the impacted site is so hydrologically diverse. <br />The Corps has established that two piezometers are sufficient for monitoring ground water on the site at this <br />time. If it is discovered that this is not su~cient, appropriate measures will be taken. <br />9. The wet meadow and drainage Swale seed mix contains introduced species such as Red Top. Only native <br />species should be intentionally planted. <br />The applicant proposes to substitute Redtop with Corps approved native species(such as prairie cordgrassJ, <br />which are FAC or FACW A change will be made to the plant list attached with the mitigation plan. <br />10. The avoided wetland azeas and the mitigation wetland areas need to be placed in a conservation easement. <br />The applicant has contacted the surrounding municipalities and private organizations that hodd conservations <br />Project: Green & Croissant Aggregate Mining Applicane Lowland Ready Mix, lnc. Pg 14 of 53 <br />Corps File No: 200180205 Waterway: Big Thompson Wetlands Weld County, CO <br />