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4. Revegetation: The request letter indicates that the MRCS Mountain Area seeding recommendation for the <br />site was provided with the request letter and that the DMG seed mix (presumably the mix used in the original <br />bond calculation) does not match the recommended mix. In reviewing the mix used in the bond calculation, <br />the only differences between the NRCS Mountain Area seeding recommendation and that used in the bond <br />calculation are the inclusion of Tufted hairgrass and Strawberry clover in the NRCS mix, which was excluded <br />in the Division's calculation. The letter refers to costs per acre for this mix from a Pawnee Butte quote. The <br />Division relies on the CIRCES bond calculation program for seed costs, as it is assumed that the costs entered <br />into the bonding program are those that the Division would be required to pay should the state perform the <br />reclamation. The request letter also indicates that discing is not necessary since seeding will occur <br />immediately afrer contouring of the floor of the pit (and presumably immediately after ripping of the plant <br />area and access road). The letter indicates that only 195 pounds of fertilizer are required per acre -based on <br />NRCS -rather than the 250 pounds used in the cost calculation. The NRCS specifications indicate that 195 <br />pounds of available nitrogen, phosphorous, and potassium are required. To achieve the required amounts of <br />these products requires the application of 2.29 times the amount of phosphorous and 1.2 time the amount of <br />potassium, due to the form these elements occur in the fertilizer compound. These amounts, added to the <br />required amount of phosphorous actually requires the application of 600 pounds of fertilizer per acre. The <br />request letter indicates that rather than 2 tons of mulch per acre, as was calculated by the Division in the first <br />bond calculation, the NRCS requires only 1.5 tons per acre of mulch. The Division used straw in its original <br />calculation, whereas the NRCS requires the use of weed-free hay. The Division has recalculated the costs for <br />revegetation to include the Tufed hairgrass and Strawberry clover in the seed mix; to exclude discing costs; <br />to include 600 pounds of fertilizer per acre and to replace 2 tons of straw with 1.5 tons of weed-free hay per <br />acre. The resulting revegetation costs actually increase to $13,923.00. The Division believes that the seed <br />mix recommended by the NRCS may contain more seeds per square foot than necessary and may be higher <br />than necessary in the amount of fertilizer used. This calculation uses the amounts and figures proposed by <br />the Operator. If the Operator is able to establish that the NRCS will accept a reduced revegetation seeding <br />and fertilizer plan, the Operator may propose this change to the permit by submission of a technical revision <br />to the Division. <br />The total calculated bond amount, including the changes according the above issues, equals $32,591.00, a reduction of <br />$2,834.00 from the original bond calculation. The Division will approve this reduction to the original bond amount. <br />If you have any questions, please do not hesitate to call me at (970) 259-5861 <br />Sincerely, <br />Kate Pickford <br />Environmental Protection Specialist <br />