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planted densely enough, the weed seeds will invade, choke out, and reclaim the land for <br />themselves. Due to the intense summer heat, lack of precipitation, and high winds prevalent in <br />Pueblo County, Rio Grande must account for how it will manage noxious weed growth to <br />prevent them from overtaking seedlings, and implement a monitoring plan to ensure strong and <br />proper new growth of the revegetated area with the intended natural grasses. <br />The company has never had access to the amount of water it said it needed for all its <br />operations, even when it expected to need less than half as much as it presently estimates. Rio <br />Grande actually needs more than the current estimates of 470 acre feet/year in order to do the <br />reclamation properly. Rio Grande has reapplied for well permits to meet some of its need. <br />However, the State Engineer found when it had previously approved Rio Grande's well permits, <br />which the company allowed to expire, that to sustain a 100 year aquifer life, Rio Grande could <br />only appropriate 111 acre feet of water. At that time, Rio Grande only wanted to appropriate 291 <br />acre feet, which the State Engineer found was an amount greater than that available to Rio <br />Grande. The Division should not approve Rio Grande's permit until it has successfully obtained <br />the necessary water for its operation, including additional water needed for irrigation to fully <br />establish the newly reclaimed areas. <br />II. Topsoiling: <br />Rio Grande's Plan does not designate how the topsoil it removes will be "segregated from <br />other soil." Additionally, the Plan does not specify how long the removed top soil will stay piled <br />up, and whether the time will be short enough to avoid deterioration of that soil, or whether the <br />company will use a vegetative cover to protect it from erosion. <br />Especially since it will be contaminated with blasting agent from the adjacent strips, a <br />plan is need to determine how the topsoil will be tested to prove that it remains free from <br />"contamination by toxic" material. The blasting will be done in a plot immediately adjacent to <br />the topsoil storage. How are they going to stabilize it? <br />The minimum thickness of A and.13 horizon soil application is 12 inches. What Rio <br />Grande is implying is that it will add 12 inches of topsoil. However, there are not 12 inches of <br />topsoil to use in reclaimation anywhere on that land. If there were, there would be more existing <br />vegetation and far more varieties than are mentioned. Rio Grande does not specify where it will <br />obtain this topsoil. Will it be trucked in from another location? <br />Replacement of a few inches of topsoil will not be sufficient to support revegetation. <br />Unless topsoil is covered or stabilized, it may blow away and not be available for revegation in <br />the original quantities (see paragraph 4 of Exhibit E). No explanation is given of how they <br />intend to keep this mound of loose dirt from blowing away. The plan outlined in Exhibit E states <br />that they are going to place a minimum of 12 inches of soil over the overburden in the area to be <br />reclaimed by loader and haul truck. Where will they be able to find (a minimum of) 12 inches of <br />topsoil?