2011-02-15_REVISION - C1980004 (2)

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Corey Heaps McClave Canyon Mining, LLC February 15, 2011 Page 15 65. Please define what the topsoil redistribution thickness will be throughout the various areas of the mine. Based on the stockpiled soil volumes, calculate the depth of topsoil replacement and specify the average depth of topsoil replacement for each area. If uneven replacement is proposed, clear justification should be presented based on the volume of topsoil stockpiled. 66. In the first paragraph, MCM states that they will replace soil on select regraded areas in an approximate uniform, stable thickness. Please explain what is meant by select,regraded areas in the narrative and if necessary on a map. Rule 2.05.40(e) Reve etation PIan 67. The application, states that a schedule of revegetation for the majority of the disturbed area is not possible to predict and the time frame for revegetation could take from 5 to 10 years. Section 2.05.4(2)(a) of the application states that revegetation will take place in the third and fourth year after the coal reserves are depleted. Please clarify this timeline with a detailed timetable for the completion of each major step in the reclamation plan. 68. The Juniper Woodland seed mix (Table 3.4-1a) does not include juniper in the seed mix. If CAM intends to replace the Juniper community, the Division believes that Juniper needs to be included in the seed mix or in a planting plan. 69. The seed mix proposed to be used for the Juniper Woodland (3.4 -1 a) and Greasewood (3.4 -1 c) both contain sagebrush seeds, winterfat seeds, and mountain mahogany which have very different textures. The Division questions whether these three seeds can be mixed in the drill seeder at the same time and that the seed mix will be evenly distributed across the reclamation area. Please provide details on the seeding plans and methods. 70. All seeded areas will be mulched with certified weed free grass hay or straw. Approximately two tons of mulch will be used on each acre seeded. On drilled sites the hay or straw will be crimped with a serrated disc or other appropriate equipment. How will the mulch on broadcasted areas be anchored to the soil as required by 4.15 -4(2)? 71. Noxious weed plan — MCM explains that cheatgrass has become established on the topsoil stock pile and will be periodically treated with roundup. Pleas provide detail on the treatment schedule and how the roundup will be applied for the cheatgrass. 72. After the cheatgrass is treated with roundup, the Division suggests that the topsoil pile be reseeded with the temporary seed mix to hinder reinvasion of cheatgrass. 73. Please include a plan for continued monitoring and managing of other pests and weeds found on the site but not mentioned in 2.05.4(e)(v) but listed in Appendix U, Noxious Weeds, page 6 and Appendix V, 7.1 Noxious Weeds, Table 16, page 44. These include species that are on the Garfield County and Colorado Department of Agriculture weed Iists.