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<br />Operator has made no provision for reclamation irrigation. Vegetative cover <br />for range land and hay meadow are substantially different, so the reference <br />to Exhibit J as embracing all vegetative cover is insufficient. <br />(b) Six to twelve inches of plant growth medium is insufficient. <br />(c) Reclamation should immediately follow mining in each area. <br />That is, as each area is mined in turn, contemporaneous reclamation should <br />be commenced on that land. <br />(d) Again, sites for stockpiling of topsoil and overburden must <br />be agreed upon by Landowner, as required under the 1974 lease. <br />(e) The comments of the Division's adequacy letter of September <br />30, 1983, with respect to Exhibit E are incorporated here by this reference. <br />(f) The Landowner has no need for, nor does the Landowner <br />desire, any ponds on the property after mining. This area must be reclaimed <br />as hay meadow. <br />(g) There have been complaints from downstream landowners <br />regarding channelization of the river. There are substantial questions as to <br />the location of the river, increased depth and rate of flow, erosion <br />(particularly with regard to proposed mining area 4) and disturbance of <br />irrigation diversion structures which should be answered by Operator before <br />a reclamation plan is approved. Specifically, before mining began, the river's <br />course was through the area now occupied by the sedimentation ponds. <br />Increased rip-rapping has resulted in increased depth and flow rate of the <br />river and lower riparian owners have complained to Landowner about resulting <br />erosion and related problems. Landowner demands to be held harmless by <br />Operator for any damage caused by alteration of the river channel. <br />Exhibit E. <br />(h) There is no statement of the reclamation of areas 3 and 4 in <br />(i) Natural conditions of the pillar rock have topsoil and <br />overburden above the rock outcrop. This results in avegetation-sustaining <br />bench above the pillar rock, which should be restored by reclamation. <br />(j) Drainage in the hay meadow should be in a generally <br />down-stream direction, rather than to allow drainage directly back to the <br />river. <br />(k) Roads require discussion. The second "access road" does <br />not cross the river other than by footbridge. How is access to be gained to <br />area 4? How does this access road relate to the existing access road to the <br />manager's house? The road to manager's house was a residential use easement <br />only, acquired from the Landowner. Again, Landowner`s consent will be <br />required for any new road construction. Most importantly, how does Operator <br />intend to reclaim the roads? <br />(1) No adequate timetable is shown for reclamation. <br />-3- <br />