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Letter to Kurt Nielsen 6 April 18. 1999 d) e) beneficial use; one of the beneficial post mining land uses selected for this site is wildlife habitat and the establishment of an adequate number of woody stem plants is requisite to the establishment of that use. Also, Rule 3.1.10(1) requires that vegetation established on reclaimed land be "at least equal in extent of cover to the natural vegetation of the surrounding area." This performance standard assures that designated shrub establishment areas will eventually provide habitat equivalent or superior to existing shrub stands in the area. DOW suggests in the enclosed letter that disturbance to areas of higher density canopy within each mine panel be avoided to the extent possible. In accordance with Rule 6.4.20(18)(a), please describe how this DOW recommendation will be implemented. In a related matter, it is not clear from figure J-1 and the narrative provided in the application whether or not the Ponderosa Pine remnant vegetation association will be a zone of no disturbance; please specify. It is stated in Exhibit H to the permit application [hat occasional raptor surveys of the project area will continue at the Piceance Site and that if functioning nests are identified in the immediate vicinity measures would be taken to minimize impacts to the nesting birds. Please specify a minimum frequency for the occasional surveys, describe the qualifications that will be required for persons assigned to conduct the surveys, and commit to documenting the results of surveys to DMG. If raptor nests are identified, American Soda should immediately consult with BLM and DOW, and should report to DMG the measures to be taken to minimize disturbance to the nesting birds. 9. It is not cleaz in the existing permit application what topsoil handling procedures will be employed during road construction and reclamation. Will all road alignments, including minor roads to individual well fields be stripped of topsoil over their entire width, including shoulders? Where will the topsoil stripped from road alignments be stockpiled? 10. With the exception of the topsoil stockpiled from the facilities area, most of the topsoil piles at the Piceance Site will be temporary, relatively small, and scattered in various locations (e.g., the individual stockpiles at each well pad). In order to prevent inadvertent misuse or contamination of stockpiled topsoil, each location where topsoil is stored should be clearly marked. 11. Reclamation Plan issues to be addressed are listed here. a) It is stated in the reclamation plan that grading will restore areas to approximate original topography to the extent possible. This grading standard is appropriate for the majority of the disturbance areas at the Piceance site. However, there are areas where restoration to original topography may not be appropriate. For example, establishment of sagebrush parks on selected drill pads, as discussed in item 8.b. above, may be enhanced if some of the leveled drill pad areas are retained in the reclaimed landscape. Also, when backfilling and regrading in steep slope areas and for reconstruction of stream channels, it is not always appropriate to reestablish original contours, and the goal of the grading plan should be to establish slopes that are not steeper than 3:1 if possible. In accordance with Rule 6.4.5(2)(f)(i), please specify that the maximum reclaimed slope gradient will be 3: l or as shallow as physical constraints allow where