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DRMS Response #2, M-1980-146,29 October 2009, Page 2 <br />However, the major concerns are (1) the availability and suitability of material for <br />backfill, and (2) BLM requirements to mitigate visual impacts and protect trail areas (as <br />discussed in item a). <br />At present, based on the agreement between C&J and LaPlata County (and as accepted <br />by BLM) to daylight operations between the Montoya Pit and Crader Pit, we appear to <br />have adequate materials to achieve the desired 3H:1 V slope on all portions of the <br />perimeter (this was not the case when the EA and amendment application were originally <br />prepared). In order to achieve 311:1 V slopes in most of the area, based on material <br />availability in the future, it may be necessary to submit a revision to the reclamation plan <br />to allow for limited areas of slope with much steeper grades which would be stabilized by <br />methods other than revegetation. This may also be necessary in order to meet BLM <br />conditions as discussed in item a. As with the other areas discussed above, we <br />understand it will be necessary to closely monitor progress. <br />Exhibit F: <br />Again, these maps have been revised in the same manner as Exhibit C, for the same <br />purposes and for the purpose of showing desired post-reclamation slopes. As discussed <br />in Ref 1, the assumption as to which areas will be revegetated is correct, with the addition <br />that BLM may require some areas NOT be revegetated or be revegetated in specific ways <br />in order to meet the requirements of the mitigation measures described in Ref 2. As <br />discussed in Ref 1, the topography shown in maps in Exhibit F is "conceptual" regardless <br />of the scale of the maps, either in hard copy or electronic form. See Maps F2, F3, F4, F5, <br />F6, and F7. <br />4. Exhibit N: <br />We are still trying to resolve the issues with BLM to ensure that Section 4 is included in <br />the lease agreement which forms the basis for the right-to-enter. As discussed above, the <br />maps in Ref 2 show the areas correctly, but the "contract area" in Section 1 of Ref 3 does <br />not identify that portion in the SE GL (1/4) of Section 4. <br />5. Exhibit R: <br />Thank you for your assistance in this. <br />6. Geotechnical Stability Exhibit: <br />a. It is correct to assume that the methods identified on Sheets GTSC-2a and 2b represent <br />the possible range of proposed methods of controlling erosion, controlling sedimentation, <br />and stabilizing the slope; and are not intended to represent any redundant or conflicting <br />practices. We understand the use of additional methods in the future may require a <br />technical revision. <br />b. In keeping with the above assumption, the engineer will determine which methods are <br />necessary at the time of backfill; and a copy of the engineering inspection report and <br />recommended methods will be provided both to the DRMS and BLM prior to <br />implementation. We understand that failure to attain stability will require a revision to <br />authorize other methods of achieving that stability. <br />c. CDOT, LaPlata County, and private construction in the immediate vicinity of the <br />permit area done both in the past and currently under construction to CDOT <br />specifications and designs support and demonstrate that revegetation has been and can be <br />successful with average slopes of greater than 2H:1 V, through a combination of various <br />slope-stabilizing methods (as listed), and planting and maintenance of newly-planted <br />vegetation until established (as listed). BLM concurs in this, as demonstrated in the