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0 <br />8. The paragraph regarding rock slope entries at the bottom of Reclamation Plan page 62 is <br />apparently now out of date (since construction of the entries is no longer planned). Please amend <br />the page to delete the outdated paragraph. <br />9. In the first paragraph of Reclamation Plan page 66, it is stated that 0" to 9" of topsoil were <br />stripped and will be replaced on the remainder of the West Ridge disposal area ...This conflicts <br />with statements elsewhere in the narrative that indicate 8" to 9" of topsoil were stripped and will <br />be replaced. This apparently is a typographical error, and should be corrected. A plan indicating <br />that 0" to 9" of topsoil would be replaced in a given location would not be meaningful or <br />enforceable, and would not comply with regulatory requirements regarding average uniform <br />replacement thickness. Please amend the referenced statement as appropriate. <br />to. There appears to be missing narrative in our version of the reclamation plan narrative, between <br />page 66A and page 67. Our page 67 (Added 07/13/87/Revised 07/13/87/Revised 10/01/87) <br />begins in the middle of a sentence (the year for construction of the soil berms... ), which does not <br />flow logically from the bottom of page 66A (Revised 10/25/91). Page 66B (Revised 10/25/91) is a <br />diagram, Figure 2.05-8 "Orchard Valley West Mine Livestock Trail". <br />Please provide properly amended pages for the referenced section. <br />11. At the Paonia Loadout Facility, approximately 40 acres were disturbed prior to enactment of <br />SMCRA or associated state reclamation laws and regulations. The area is a "grand-fathered" <br />alluvial valley floor, and topsoil was not salvaged prior to disturbance. The AVF was flood <br />irrigated cropland (apparently fruit orchard) prior to disturbance and the predominant soil type was <br />Aqua Fria stony loam, 3-12% slopes, which NRCS has identified as a soil type that supports <br />"Farmland of Statewide Importance". <br />There are apparently two contradictory plans in the application regarding revegetation of the <br />approximately 40 acres of disturbed land within designated Cropland land use area associated with <br />the loadout facility. One plan is for orchard reestablishment, and a second plan is for <br />establishment of irrigated grass hay cropland. <br />Orchard Reestablishment <br />On page 71 i of the Reclamation Plan (Section 2.05.4(2)(e)(ii)), narrative indicates that selected <br />species of fruit trees will be planted "at the standard orchard density". Notation indicates that the <br />page was amended "02/04". The brief statement is followed by a reference to "Vegetation Report, <br />page 30...in the Vegetation Appendix, Volume 9A". In the Volume 9A Vegetation Appendix <br />report, there is generalized discussion of planting various species of fruit trees, at specified <br />densities and "whip sizes", along with measures to be used to control ground cover between <br />planting rows. The appendix report also includes Westmoreland Orchards fruit crop production <br />data for 1977 through 1980, and reference to possible establishment of success standards based on <br />theoretical fruit crop yields as a function of time. <br />Planting of fruit trees in orchard cropland areas is also referenced in the second paragraph of page <br />82 of the Reclamation Plan. <br />3