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<br />DATE: September 190', 2008 / <br />TO: Berhan Keffelew ? <br />FROM: Jared Ebert <br />RE: Revegetation Revie Cripple Creek and Victor Gold Mine, file number M- <br />1980-244, AM09. ine Life Extension <br />The Division has conducted a review of the Cripple Creek and Victor Gold / Cresson Project <br />response from the Divisions Adequacy Review for amendment (AM09) for their Mine Life <br />Extension project. <br />General Plan (Project Description section 11.3): <br />A.) Topsoiling: According to their response, they have committed to endeavoring to salvage as <br />much topsoil as they can, and this varies throughout the site. They still want to <br />keep the minimum replacement depth at 6 inches. As long as they have <br />committed to salvaging as much topsoil as it available and they intend to spread <br />it evenly, the minimum replacement depth of 6 inches is acceptable. However, it <br />is their responsibility to re-establish a diverse and long-lasting vegetative cover <br />over the mine site that correlates with the post mine land use. They will not be <br />released from their reclamation responsibilities if this is not achieved. <br />Also, CC&V has committed to seeding the topsoil stock pile to stabilize it with <br />vegetative cover. They do not specify what seed mix they will use to accomplish <br />this. <br />B.) Seeding: On page 16 of the adequacy review response under item "F." it states that CC&V <br />is primarily trying to re-establish the "Native Grasslands" vegetation zone. It is <br />assumed that they are referring to the "Natural Grassland" zone as it is titled in <br />the Arcadis "Baseline Technical Report". It is understood why the operator is <br />using some non-native species in their seed mixtures. Several off these species <br />will establish quickly to help stabilize the disturbed areas, in time these species <br />should be replaced with native plant cover. <br />If the operator's primary purpose is to re-establish the Natural Grassland <br />vegetation zone, why are many of the dominant grass species that were found in <br />that zone not included in the seed mixture. According to Arcadis "Baseline <br />Technical Report for Soils and Biological Resources, Cresson Mine Life <br />Extension Project Area", on page 11, under section 4.1.5 it lists the Dominant <br />species found in the "Natural Grassland" vegetation zone. These species are; <br />Parry's oatgrass (Danthonia parryi), junegrass (Koelaria macrantha <br />Kentucky bluegrass (Poa pratensis), mountain muhly (Muhlenbergia <br />montana), squirrel tail (Elymus elymoides), western wheatgrass <br />(Pascopyron smithii), bearded wheatgrass (Elymus trachycaulus ssp <br />trachycaulus), and Arizona fescue (Festuca arizonica). A few of these <br />species are represented in the two seed mixtures, and they plan on adding <br />Arizona fescue, but many of these species are not represented in the two <br />seed mixtures, like junegrass for example. It would seem that if the