2011-09-09_APPLICATION CORRESPONDENCE - C2010089 (2)

Home Browse Search

C- 2010 -089 PAR No. 2 New Horizon North Mine 9- Sep -2011 Page 20 of 25 DRMS: WFC responded that NH2 apparently is the only mine in Colorado required to salvage A horizon separately for B horizon soils. The Keenesburg Mine salvaged A horizon soils in separate lifts from the B horizon soils. This mine is no longer salvaging topsoil, but the operator replaces topsoil in separate lifts. Please provide a discussion that demonstrates to the Division that salvage of topsoil and subsoil in one combined lift so that "all areas affected by surface coal mining operations shall be restored in a timely manner to conditions that are capable of supporting the uses which they were capable of supporting before any mining or to higher or better uses achievable under criteria and procedures of 4.16" (Rule 4.16.1(1)). 2.05.4(2)(e) — Revegetation plan 1. Response accepted. 2. Response accepted. 3. Response accepted. 4. Rule 4.15.7(3)(b)(iii) requires that reference areas selected for reclamation success comparison should approximate the vegetation characteristics which reflect reclamation plan objectives. The permittee must demonstrate that the reference area selected reflects proper land management and is representative of the ecological site conditions for the reclaimed area as determined by pre- mining inventories and the reclamation plan. The operator must demonstrate that the management of the reference area is under the permit's control and, will remain under the permittee's control throughout the performance bond requirements of 3.02.3. The Division questions the applicability of the Dryland Reference area located at the Hopkins Field Airport as representative of the pre- mining dryland pasture land use. The soil of the proposed dryland pasture reference area is primarily Barx fine sandy loaml -3% slope. The Montrose County soil survey does not provide expected productivity values for dryland pasture on this soil mapping unit. The proposed dryland pasture reference at the Hopkins Field has a considerable shrub component. The post- mining land use for areas on the proposed permit area is dryland pasture. Shrubs should make up a minor component of the dryland pasture "community ". Soils mapped in the proposed mining area do not include Barx soils. The Division recommends that WFC locate a representative Dryland pasture reference area that will remain under the operator's control. It is desirable and highly beneficial to use a reference area that can be incorporated into the permit area. DRMS: The Division accessed the Soil Resource data through the NRCS Website. The Division was indeed looking at the correct soil survey. This portion of Montrose county soils information is titled "San Miguel Area, Colorado, Parts of Delores, Montrose, and San Miguel Counties ". Interestingly, WFC was able to find production values in the printed copy of this soil survey that were not readily locatable on the NRCS website. The production data reported by WFC for the Ecological Sites provides important potential soil productivity information. The Division concurs that Barx soils do exist as minor inclusions to the NRCS mapping units. If no other comparable locations are available for use as a vegetative reference area, the Division will accept the Hopkins Field site. Response accepted.