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the property should be restored to native grasses, shrubs, and/or trees that could be used for rangeland <br />grazing during and after mining. Presently, much of the property in question is covered with cheat grass <br />(Bromus tectorum}, an alien weed with almost no grazing or other value, and which is a significant <br />problem because it burns readily throughout most of the year and spreads rapidly by seed onto adjacent <br />properties. Part of the reclamation plan both during and following the mining period should be to <br />replace the cheat grass with permanent native or introduced pasture. <br />Much of the Mancos Valley (including the McStone Property) lies over Mancos shale which has <br />deposits of crystalline salt that, when leached, contribute unacceptable amounts of salt to the Colorado <br />River system. Mud Creek is an important contributor to the approximately 43,000 tons of salt <br />contributed annually to the Colorado River from the Mancos Valley. Thus, it is essential that Pit <br />management be carefully designed to eliminate (or reduce as much as possible) leaching of salt from <br />shales underlying the mine. This would require, during mining and after reclamation, that; 1) all <br />impounded water be held in ponds with impermeable liners, 2) all irrigation water be applied in ways <br />that only supply the consumptive needs of the target vegetation, and 3) return flows to Mud Creek from <br />natural, irrigation, and industrial waters be by rapid surface flow or preferably piped. We understand the <br />need to reclaim certain amounts of industrial water before releasing it to Mud Creek, but such <br />reclamation should consider the importance of salinity control. In order to meet this need, the <br />reclamation plan as presented in the Application must be modified to remove the barrier to surface flow <br />between the Noland and McStone properties so that no impoundment of water and minimal leaching of <br />salt will occur. Our suggestion is to cooperatively reclaim the Noland Cedar Point Pit, the Mud Creek <br />Pit and the future Simmons Pit so that the entire escarpment of Mud Creek is brought back to the eastern <br />most points of gravel extraction. This will allow establishment of proper drainage and maximize the <br />aesthetics and potential uses of the reclaimed property. <br />The highest quality top soil in the Mancos Valley is typically less than 12 inches thick, underlain by 18- <br />24 inches of lesser quality top soil. It is essential that, because of the extensive area to be reclaimed <br />following mining, that no top soil of any kind be sold during the operation of the pit and that soil stored <br />for future reclamation be fully stabilized to prevent wind and water erosion. <br />The Mancos Conservation District strongly recommends that the reclamation of the three adjacent pits <br />mentioned here be considered together to prevent the formation of any undrained or slowly draining <br />basins as a result of the mining operations. <br />We may have other suggestions as this process moves forward. Please keep us informed of actions <br />taken with regard to this application and feel free to request our services if we can be of help in devising <br />a "best for all" reclamation plan. <br />Sincerely, <br />Jac H. Burk, President ~f/ <br />Mancos Conservation District <br />