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E. Based on the soils information provided to the Division as part of Exhibit I, there appears to <br />• be 10-12 inches of topsoil available which could be salvaged and replaced as growth <br />medium. Please commit to salvaging and replacing all available growth medium with 10 <br />inches to be replaced at a minimum. All topsoil that is salvaged must be protected if it is <br />not going to be utilized for more than 180 days. <br />Response: <br />Soil depths throughout the project area have been found to be variable. CC&V recognizes the <br />importance of suitable growth medium and will endeavor to salvage all available growth <br />medium which is feasible to recover. CC&V would propose to keep the minimum replacement <br />depth at 6 inches as defined and approved in the Amendment No. 8 reclamation plan, as this <br />has been shown to be adequate in all cases for vegetation reestablishment. Regulatory <br />standards for revegetation success will require CC&V to re-establish a permanent and diverse <br />cover on all reclaimed areas suitable to support the post-mining land uses of grazing and <br />wildlife habitat. This requirement established the ultimate bond release criteria for all <br />reclaimed areas. <br />All salvaged growth media will be utilized and deeper soil placement would be achieved where <br />possible. Growth medium stockpiles would be seeded within 180 days after completion of <br />stockpiling or within the next growing season if the seeding timeframe is not within a suitable <br />season. <br />• F. The operator provided two seed mixtures for the site. The list on Table 11-1 is the primary <br />seed mix that is planned to be used. The seed mix on table 11-2 is planned to be used as a <br />substitute. Several species contained in Table 11-1 are not currently found on site according <br />to the baseline data included for the area. However, all the species listed in table 11-2 are <br />found on the site area currently. What criterion will determine when the second seed mix <br />will be used? Why is Sheep fescue used as opposed to Arizona fescue? What is the seeding <br />rate for Cicer milkvetch? This plant is very competitive and it is a useful legume for adding <br />nitrogen to the soil, however, if too much is planted, it may out-compete the other <br />vegetation. CC&V should provide a list of pounds of pure live seed per acre. The quantity <br />of each species should be representative of the current plant species for the site. <br />Response: <br />One of the primary goals of successful reclamation is the quick establishment of ground cover <br />to minimize erosion. CC&V periodically uses third-party consultants to review previously <br />reclaimed areas and document species, diversity, and production from those areas. This <br />information is used to confirm or update the existing seed lists. Some species in Table 11-1 <br />are non-native species and have been included because they establish quickly to provide <br />erosion control. These non-native species typically are replaced by the better adapted native <br />species within a few years. If one compares the two seed mixes with the "Native Grasslands" <br />vegetation zone of the baseline study, you will note that more of Table 11-1 species occur in <br />this zone (which is the primary revegetation zone CC&V is attempting to re-establish) than of <br />• Table 11-2 species. The species of Table 11-2 have been listed to provide substitute species in <br />the event that some species may not be available from time to time, or simply to provide some <br />variability in different areas or vegetation zones. However, as noted, all of the species of Table <br />11-2 do occur in the project area. The current reclamation seed mix already includes two <br />16