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WL-PM-E/Letter to: DRMS Subject: Response to Comments <br />• 1. The Operator is responsible for reclamation of all surface disturbances on public lands that are <br />related to activities conducted under previous contracts issued to C and J Gravel. Interim and <br />final reclamation must be initiated at the earliest economically and technically feasible time. <br />Interim reclamation will be initiated when an area will not be used for a minimum of three years. <br />Interim reclamation will consist of maintaining surfaces in a stable condition which will not <br />erode. Surfaces will be vegetated with a seed mix that is approved by the BLM. Final <br />reclamation will be implemented when an area will clearly not be used for operations in the <br />future. Final reclamation will consist of recontouring disturbed surfaces to natural contours and <br />re-vegetating with a BLM-approved native seed mixture. The operator would repeat seeding as <br />needed to meet BLM vegetation standards. Revegetation would be considered to be complete <br />when a permanent, reproducing plant community has been established that meets long-term use <br />goals. <br />2. During final reclamation, all disturbed areas would be re-contoured to blend as closely as possible <br />with the natural topography, and to blend visually with adjacent natural textures and colors of <br />rocks, trees, and surface materials. Final reclamation should include "roughing up" slopes and <br />"footing-in'' salvaged trees and rocks onto slopes to develop natural appearing course texture and <br />to create precipitation catchment areas to establish perennial vegetative growth. <br />3. Topographic screening, including berming and retention of existing natural exterior slopes until <br />late in the development process, will be utilized to reduce visual effects from the Highway 160 <br />corridor and along the Sale Barn Trail. <br />4. The pit edge will be a minimum of 100 feet from the edge of the Sale Barn Trail, in order to <br />• screen views from the trail. Some adjustments, plus or minus, may be made by BLM landscape <br />architect, depending on vegetation and topography. <br />5. C and J Gravel will collaborate with the BLM to develop and implement reclamation techniques <br />for barren Mancos Shale slopes visible from KOP 4.3 in order to visually blend with adjacent <br />course textured, sparsely treed, natural slopes. This will entail modification of approximately 50 <br />percent of the visible slope face by developing an appearance of a coarse texture through <br />earthwork placement of boulder and woody debris salvaged from the proposed action area, and <br />appropriate reclamation plantings. <br />6. A berm will be constructed along the top of the pit wall. The profile of existing and proposed <br />berms will be varied, where feasible, to reduce negative visual effects as viewed from area trails, <br />to appear more natural, and aid in slope stabilization. <br />7. Rocks and trees removed from the expansion area will be salvaged for use on existing pit slopes <br />to assist with interim and final reclamation and soil stabilization in those locations. Tree root balls <br />can be footed-in to slopes to aid in stabilization. <br />b. Future revisions may also be required for other matters as discussed below. We <br />understand that these revisions may require a technical revision to be submitted to <br />DRMS for review and approval. <br />c. If the slopes in the eastern portion of the site (including the new and old access <br />road) cannot be adequately reclaimed within five years after implementation, we will <br />be required to submit a revision to the reclamation plan with alternative methods of <br />• reclamation. We understand that the progress will be closely monitored. (Please note <br />that BLM will be monitoring operations, including reclamation, a minimum of four times <br />per year, in addition to DRMS monitoring.) The applicant/operator proposes <br />PROJECT: Montoya Pit M-1980-146 AM-4 15 July 2010, Page 2