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<br /> <br />Le[ter to Kurt Nielsen 7 Aaril (3. 1999 <br />steeper slopes have been disturbed. American Soda should also provide a statemen[ that <br />disturbance of natural slopes steeper than 3:1 will be avoided wherever possible. <br />b) Examination of figure F-1 included with the application indicates that the road from the test <br />mine facility to the Piceance Site processing facility will remain at the time of reclamation , as <br />will the road from Horse Draw to the processing facility and the relocated Yellow Creek jeep <br />trail. Examination of figure F-L further indicates that all other roads constructed by American <br />Soda will be reclaimed. Is this an accurate interpretation of American Soda's plans for road <br />reclamation'? If so, and in accordance Rule 3.1.11, leaving the roads in the reclaimed landscape <br />must be accepted in writing by the BLM. Otherwise DMG will estimate reclamation costs used <br />to establish the amount of required bond assuming these roads will have to be reclaimed. <br />c) The reclamation plan provided with the application provides detailed revegetation success <br />criteria for reclamation responsibility and bond release. Be advised that the a~ly revegetation <br />success criteria that may be used by DMG for bond release determinations is established by <br />Rule 3.1.10(1), which states: <br />...land shall be revegetated in such a way as to establish a diverse, effective, and long- , <br />lasting vegetative cover that is capable ofself-regeneration without dependence on <br />irrigation, soil amendments or fertilizer, and is at least egaal in extent of cover to the <br />natural vegetation of the surrounding azea. (emphasis added). <br />d) It is stated in the reclamation plan that permanent foundation structures, such as concrete pads <br />and footers may be buried in place. It is DMG's position that any foundation elements that are <br />to be buried in place must be shattered to allow infiltration of rainwater and snow melt. <br />e) It is stated in the reclamation plan that species listed in the proposed seed mixtures may be <br />substituted based on commercial availability and site performance. Please be advised that seed <br />mix modifications must be reviewed and approved by DMG through the technical revision <br />process (Rule 1.9). <br />12. Appendix D to the "Soil Conservation, Erosion and Sediment Control, Reclamation, and <br />Revegetation Plan" included with the application presents a discussion of sedimentation basins. Please <br />be awaze that proposals to construct sedimentation basins at the Piceance Site must be reviewed and <br />approved by DMG through an appropriate permit modification (technical revision or amendment; Rules <br />1.9 and 1. l0). <br />] 3. Once the requirements for monitoring and reclamation of the Test Mine Facility are incorporated <br />into the reclamation permit application for the Yankee Gulch Project and the permit is issued, the <br />prospecting notices American Soda holds for the Test Mine Facility may be terminated. In order to <br />incorporate the Test Ivline into the permit, the following additional information must be provided. <br />(Most of this requested information is in the prospecting notices, but must be restated in a submittal to <br />the permit application due to the confidentiality restriction placed on prospecting). <br />