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Letter to Roger Day <br />these strips, shrub tublings would be planted on 4 to 5 foot centers with a fertilizer pellet and a <br />mesh (vexar) seedling protection tube. The shrub species listed in the seed mixture would be <br />appropriate for planting as tublings, as would sagebrush. For the purpose of estimating <br />reclamation costs for the implementation of these habitat restoration procedures, DMG will <br />assume that 20 percent of the reclaimed acreage will initially be planted with shrub tublings at a <br />rate of 2200 shrubs per acre. However, it may be worthwhile to experiment with seeding (rather <br />than planting tublings) to shrubs on some of the designated well pads to develop a comparative <br />database on the relative success of seeding versus planting. <br />d) A raptor survey must be completed in and around all proposed areas of affected land prior to <br />disturbance. The results of all raptor surveys must be provided to the DMG. Please describe the <br />mitigation measures to be employed if raptor occupancy is indicated through the surveys. <br />12. Reclamation Plan issues to be addressed are listed here. <br />7 June 18, 1999 <br />a) It is stated in the reclamation plan that grading will restore areas to approximate original <br />topography to the extent possible. This grading standard is appropriate for the majority of the <br />proposed disturbances. However, there are areas where restoration to original topography may <br />not be appropriate. For example, when backfilling and regrading in steep slope areas and for <br />reconstruction of stream channels, it is not always appropriate to reestablish original contours, <br />and the goal of the grading plan should be to establish slopes that are not steeper than 3:1 if <br />possible. In accordance with Rule 6.4.5(2)(f)(i), please specify that the maximum reclaimed <br />slope gradient will be 3:1 or as shallow as physical constraints allow where steeper slopes have <br />been disturbed. AmerAlia should also provide a statement that disturbance of natural slopes <br />steeper than 3:1 will be avoided wherever possible. <br />b) It is stated in section E -4 to the application that topsoil stockpiles for roads and pipeline <br />corridors will be linear and located along and generally upgradient of the road or corridor. <br />DMG is concerned that this stockpiling plan may result in loss or deterioration of the topsoil <br />over time and recommends that the topsoil piles be consolidated in locations approximately <br />every 400 feet along a corridor. These individual piles should be signed to identify them as <br />topsoil and should be located in accordance with the standards in Rule 3.1.9. <br />c) It is stated in sections E -5.3 and E -5.4 of the application that concrete will be buried on site at <br />the time of reclamation. Please provide documentation that BLM has agreed to this procedure, <br />otherwise DMG will require adequate bonding for off -site disposal. <br />d) Figure F -2 in the application indicates that road cuts will not be backfilled at the time of <br />reclamation and that 1.5:1 cut slopes will remain in place with no topsoil replacement. While <br />DMG is amenable to inspecting the condition of the road cuts at the end of the life of mine and <br />determining on a site specific basis if certain road segments do not require backfilling, the <br />reclamation bond will be based on the potential need for complete backfilling. <br />e) Figure F -3 in the application indicates that the 2:1 plant site fill slope will remain at the time of <br />reclamation. It is DMG's position that 3:1 slopes may be required to meet revegetation <br />performance standards an achieve the post mining land use, and grading costs to bring the slope <br />to 3:1 will be incorporated into the bond. However, DMG will agree to inspect the site at the <br />