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Page 2 of 3 <br />establishing a protective vegetative cover unreasonable. However, without adequate vegetative <br />cover, long-term erosion control within the industrial area needs to be addressed. The text <br />states that erosion caused by water will be controlled by "restoring the land to the approximate <br />original contour [which] will minimize or eliminate erosion" because the "existing berms <br />contain most of the precipitation that falls on the industrial area." Erosion due to wind is not <br />addressed in this section. Please reference Rule 4.17 - Air Resource Protection and the <br />appropriate measures that will be implemented to control wind erosion and air quality. Section <br />2.05.6(2)(a)(ii) states that the evaporation ponds will be covered with 6 inches of clean fill. <br />Please give a description of the fill material and how the wind erosion potential of the site will <br />be minimized. Also, Rule 4.15.1(3) is cited incorrectly in the text. The correct rule is <br />4.15.10(3). Please fix this typo. <br />71. Item Resolved <br />72. Item Resolved <br />73. See comment 70 above. <br />74. The language used to describe the woody plant density standard is confusing and it is not clear <br />if a reference area or technical standard will be used for comparison to show success. The <br />Division suggests use only the approved greasewood reference area as a standard and achieves <br />90% woody plant density of the approved greasewood reference area sample mean at the 90% <br />confidence level. <br />75. In the baseline vegetation survey, inland saltgrass (Distichlis spicata) was the only species of <br />grass that contributed to plant cover. The Division suggests adding inland saltgrass (Distichlis <br />spicata) to the reclamation seed mix. For the diversity success standard, the Division believes <br />that it is appropriate to include a native perennial grass. Please add to the diversity standard on <br />page 2.05-38 that one perennial grass will contribute at least 3% relative cover. <br />76. Item Resolved <br />77. Mike: I do not have any comments about this bullet. CDPHE documented that there are not <br />any conditions that require remediation. My comment to 87 is approaching this issue from the <br />wildlife perspective by asking about the safety of the water if sediment ponds retain standing <br />water <br />Rule 2.05.6(2) Fish and Wildlife Plan <br />85. The applicant committed to using best management practices to protect the watershed, <br />including the batch weigh system for loading rail cars minimizing coal spillage into Reed Wash <br />and the use of silt fences and/or straw bales during construction of the rail bridge. Please <br />discuss other protective measures that will be implemented to protect the watershed such as a