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~ ~ C• C• Mr. Rodney L. Banks -Z- April 6, 1982 2. Wildlife A review of the wildlife statement enclosed in each application shows it to be a "generic statement" which is identical for a1Z eight pits. Considering the topographic heterogeneity of Teller County, I find it doubtful that one statement can be appropriate for pits located all over the county. I suggest that you seek additional information from the Division of Wildlife that either justifies this "generic statement" procedure or gives a specific review of each separate site. 3. Topsoil a. The section that discusses topsoil in each permit is confusing. gain, it seems as if "generic" information is being given. The soil infor- mation given does not seem to correspond to the general soil types mentioned n the page having information about soils, climate and native vegetation for each pit. The soil types for each pit should be identified and described. b. The depth of topsoil available for use in reclamation should be given. If topsoil is not available for some areas of the pit, and topsoil from another area will be used for reclaiming the entire pit, please clarify this situation. Frhihit R 1. Some of the eight permits mention that vertical highwalls will be left in final reclamation. This is not an acceptable reclamation plan. Vertical aggregate walls are not stable and are particularly subject to wind erosion, water erosion, and mass movement (as well as being a safety hazard). All such slopes should be cut back to a slope that can be practically revegetated. This is a slope of no more than 2:1 and, preferably, 3:I. In this regard, it is unclear in some of the permit applications that do not actually mention vertical walls whether or not some slopes are to be left steeper than 3:1 (notably 82-44 and 82-45). If slopes are to be left steeper than 3: 1, this should be made clear, the planned slopes should be defined, and any special reclamation plans for these slopes should be mentioned. 2. In the case of the Glen Johnston Site )12, the reclamation plan is not acceptable. AZI slopes, whether at 3:1, 2'x:1 or steeper, will have to be reclaimed and revegetated. As mentioned above, vertical walls cannot be left in reclamation. Please reconsider this plan in light of my comments above. 3. Drainage patterns in final reclamation for the pit bottoms should be ~Ce'~ described for all pits (e.g., la slope outward). 4. I note that only one revegetation plan has been submitted for all eight \/ applications. Again, I find it difficult to understand how one such plan (with /`( one revegetation seeding mix) can be applicable to eight separate pits spread all over Teller County• I suggest that you seek additional information from the Soil Conservation Service that either justifies this one, overall revegetation plan, or gives a specific plan for each site (as appropriate).