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~as Colorado, Inc. (M-99-098) Obje~ns <br />(Page 2 of 2) <br />Re ulation Citation Comment / Ob'ection / Concern <br />6.4.5(2)(c) The plan contains inconsistent information concerning implementation of reclamation. <br /> At one point reclamation is to occur immediately; in another section specific time <br /> frames that could dela such "immediac "ore outlined. <br />6.4.5(2)(d) The plan lacks specificity concerning topsoil segregation, preservation, stabilization, <br /> compaction and grading. Placement of topsoil on cell edges presents problems during <br /> spring flooding as approximately 75% of the proposed mining area is in the 100-year <br /> flood lain. This also raises ri avian corridor nnrrowin issues. <br />6,4.5(2)(d) The rev etation Ian lists ve etative s ecies not conducive to this area. <br />6.4.5(2)(e) The reclamation Ian lacks the s ecificit delineated in this r ulation. <br />6.4.5(2)(f) The plan lacks the specificity required concerning fertilization and revegetation, <br /> particularly types, mixtures, quantities and application timing of fertilizer and <br /> uantities, size and location of trees and shrubs. <br />6.4.6(a) Exhibit F provides no correlation of the expected physical appearance of the affected <br /> land during and post reclamation. There is no indication of revegetative endeavors. <br /> Further, because of the slope in Cell 2, the plan fails to properly portray the height of <br /> the dyke necessary to hold water on the southern border of the upper pond or any <br /> other miti ntin measures. <br />6.4.7(2)(n) The Ian fails to identif all ditches, drain tiles and eddies. <br />6.4.7(2)(c) The plan fails to provide information concerning management of surface waters to <br /> rotect a ainst ollution duain and after the o etation. <br />6.4.8(1)(a) and (b) The plan foils to mention the oxbow in the peninsula area and lacks specificity in <br /> describing the varied types of wildlife indigenous to the area or the seasonal use of <br /> the area b theses ecies. <br />6.4.8(1)(c) The plan fails to mention the Preble's meadow jumping mouse and Ute Ladies'-Tresses <br /> issues. <br />6.4.8(d) The plan fails to recognize the impact of the mining and reclamation plan to wildlife as <br /> described, once again, in the Division of Wildlife letter. There is no data to support <br /> the assertion there may be a possible increase in numbers and species due to the <br /> increase in potential habitat: an assertion that is a dichotomy to the position presented <br /> in the Division of Wildlife letter and realit itself. <br />6.4.11 The plan fails to address a major factor in this area -wind. It fails to adequately <br /> delineate specific measures to control dust blown from the disturbed topogrnphy and <br /> to soil/s oils stock files. <br />6.4.13 The plan asserts other permits and licenses will be obtained, including the Weld County <br /> Flood Hazard Development Permit. Due to the nature of this riparian area and the <br /> residences affected by this plan, the application should not be considered complete <br /> until the hydrologic studies have been submitted and peer-reviewed. In addition, one <br /> home within close proximity to the mining activity was built in the late 1800's and may <br /> have state historic reservation issues. <br />6.4.19 The plan fails to adequately identify all drain tiles. Structural integrity engineering <br /> evaluations for all man-made permanent structures were not submitted with the <br /> a lication; therefore the a licotion is incom lete. <br />