Laserfiche WebLink
The Plan states that Rio Grande will use a geotextile mesh containing a cover seed mix <br />and fertilizer "or equivalent" means to revegetate the disturbed areas. However, the Plan fails to <br />clarify what types of "equivalent" means Rio Grande will use if it does not use the geotextile <br />mesh method. Moreover, the mine site currently contains a variety of plants. Rio Grande's Plan <br />will not meet the criterion of a "diverse" vegetative cover if it only revegetates using three kinds <br />of seed (see Exhibit E, E-2). <br />Rio Grande plans to use only a total of 16 lbs. of pure live seed per acre. Mr. Jim Knopf, <br />a landscape architect specializing in Rocky Mountain Xeriscape design, and a consultant to <br />regional water boards, states that the grasses Rio Grande proposes to reintroduce should be <br />sowed in at least 2-3 lbs. per 1,000 square feet. That means that the minimum grass seed per acre <br />necessary to properly reclaim the site would be 86-129 pounds per acre. The Denver Water <br />Department recommends these amounts. Rio Grande's plan must result in "the greatest <br />probability of success." To reach this result, Rio Grande's permit must take into account <br />biological factors such as appropriate seeding to accomplish a stable and diverse ground cover. <br />The regulation states that the Operator must "consider environmental factors such as <br />seasonal patterns of precipitation, temperature and wind; soil texture and fertility, slope stability, <br />and direction of slope faces." In dry years only 9 inches of moisture may fall, and that may be in <br />the form of snow in the winter. Exhibit K. on Climate, omits any mention of the severe winds <br />that are prevalent in this area, especially in the winter and spring. These winds will cause erosion <br />unless planned for, and will blow away seeds broadcast on the site before they can germinate. <br />Rio Grande's Plan includes no methods for preventing wind erosion during revegetation. This is <br />a particular problem that will occur between the times of replacing the surface soils, which will <br />occur throughout the year, including fall and winter, and the time of revegetation, which will <br />most likely occur in spring and summer. Fall and winter are times of tremendous wind in Pueblo <br />County. Finally, Pueblo does not have "moist" air, and average humidity is not 35%. <br />Temperatures often vary in extremes from high to low. This area is subject to glaring sun, a lack <br />of trees to break the wind, and high summer heat. Average weather can result in 100% <br />evaporation of summer rainfall in this and climate. <br />Even though Rio Grande intends to plant native grasses that_will ultimately subsist on <br />rainfall, to get them established it must apply water. Otherwise, the plants will not germinate, <br />although noxious weeds will have no trouble invading the area. Without water applications as <br />needed until plants are established, Rio Grande's plan is the equivalent of "no plan," and will <br />result in dust blowing from an ever-enlarging area. The regulations require that the Operator use <br />methods of weed control for all prohibited noxious weed species. Rio Grande's plan does not <br />address weed control at all. Without suitable weed control, noxious weeds will likely threaten <br />the continued development of the desired vegetation, and will spread to newly reclaimed land or <br />land in the first stages of reclamation, preventing seeded species from maturing. <br />Exhibit E, paragraph 8, states that "revegetation with native species immediately <br />following a disturbance lowers the risk of noxious weed occupation." This is true only if the <br />seed is seeded in heavily and has total germination which depends on adequate soil quality, <br />moisture, and a time to get established before the weed seeds do. If the native grass is not