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Page 2 • • <br />create windrows of woody material, that usually is not a serious problem as it is desirable to leave <br />rough, broken woody materials on the surface to help control erosion, provide shade for <br />seedlings, and increase the microenvironmental diversity. It is most likely that this method will be <br />used in reducing the rock content in rocky soils. <br />Concern A, Part 2: Soil salvage volumes. <br />Response: As I am sure you are aware, determining the volume of salvageable soil, <br />especially where there is zonation between desirable and undesirable soils, is an almost impossible <br />task. Soil does not form layers of uniform thickness that lend themselves to easy calculations. <br />Clearly, the Roygorge soil (the smallest volume on the site both in extent and thickness) is hardly <br />worth considering. As stated in the plan and is typical of this series, there may be small pockets of <br />thicker soil that will be saved, but it would be impossible to find those pockets without an inch <br />by inch soil survey of those areas. <br />Because lower horizons in many of these soils contain alkaline materials <br />they would not be desirable to save and could create serious difficulties in the revegetation. These <br />layers are identifiable by a color shift toward a very light color or even white. <br />Therefore, if by "total available topsoil" you mean soil material that is not <br />alkaline in character then Castle is prepared to "commit to salvage all available topsoil in the <br />area." But if you mean the total soil horizon then Castle cannot commit to that as it would greatly <br />reduce the success of the revegetation program. Such salvage would contaminate good soils with <br />soils that have higher salinity, higher pH, and a potentially adverse SAR. That is <br />counterproductive to the purposes of reclamation as it would hinder achievement of bond release <br />and proper completion of the program and would be contrary to the lease. <br />Concern B: Blasting monitoring. <br />Response: Castle does not intend to monitor blasting. First, because the deposit is <br />relatively thin and brittle blasting force does not need to be intense. Second, because the primary <br />product to be created is large rip rap, intense blasting may very well create rock dimensions that <br />are too small to market for those purposes. Third, there seems little need to monitor the intensity <br />of blasting when there are no structures anywhere near the area that might be affected. <br />Concern G Processing and Hauling <br />Response: We agree that the roadway, as it currently exists, is not suitable for large <br />amounts of truck traffic. But this road was specifically built for truck traffic and it was built by <br />Castle Concrete in the late 60's. It has been used in the past by ABI, the latest permittee, and prior <br />to that it was used very heavily by Green Massman when facing rock from here was being hauled <br />to Pueblo Dam. The road is in disrepair because there has been no maintenance for over 15 years. <br />The plan for upgrading the roadway is to simply grade it and resurface <br />portions of it with a base material. The parts that will be resurfaced will only be those areas where <br />the road surface is currently very rocky. Consideration was given to removal of the rocks that <br />now project through the surface, but that was deemed unnecessary by contractors who are <br />bidding on the upgrade work. <br />The road corridor will not be widened, but must be confined to the <br />existing path by agreement with the land owner, the State of Colorado. Although the actual <br />driving surface may be widened somewhat in some areas, it cannot extend into undisturbed land. <br />