2012-08-21_REVISION - M1980244 (32)

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6.4.21 EXHIBIT U — Designated Mining Operations Environmental Protection Plan 32. Pursuant to Rule 6.4.21(17)(c), the Operator is to provide for each soil map unit, in tabular form, all data from analyses of representative samples of surface and subsurface soil units as to soil pH, texture, electrical conductivity, and sodium adsorption ration. Alternately, the Operator may provide a plan of experiments to determine the type, form and amount of any soil amendments that may be necessary to fulfill the requirements of the Reclamation Plan. Please provide the Division with this information (see comments under No. 15). RESPONSE: As noted above, during the removal and stockpiling of growth medium at CC &V, there is significant mixing of the various soil units as specified in the Arcadis report, because "in- the - field" separation of soil units is not practical, nor does it have a substantive effect on the quality of the reclamation. In addition to detailed soils report prepared by Arcadis, CC &V's standard practice is to sample growth medium source as it is delivered to the reclamation site. The practice is to collect materials in plastic bags, send them to a local soil laboratory, and analyze them for key parameters such as pH, acid -base- accounting, nitrogen, potassium, phosphorus and organic matter. Using these analyses, it will be determined what, if any, soil amendments will be required. Moreover, soil analyses will occur when the growth medium has been delivered to the site where it will be used, and not in the stockpile location. Previous experience indicates that one composite soil sample for every five acres will be collected and analyzed for the parameters mentioned above. This has been the approved sample frequency, as stated in previous amendments to Permit M -1980- 244. Although difficult to "ensure" the samples are representative of the growth medium materials, past experience and revegetation success indicates CC &V's reclamation practices (i.e. one composite sample for every S acres of reclaimed area) are working. 33. The Arcadis Baseline Technical Report concluded that project activities will likely result in the loss of critical habitat for mule deer and potentially nesting habitat for raptors. Pursuant to Rule 6.4.21(18)(a), please adequately describe mitigation measures to ensure there is no overall net loss of important wildlife habitat. RESPONSE: As also discussed in the Arcadis Baseline Technical Report habitat management and creation should be directed towards encouraging the diversity of both game and non -game species, and should provide protection, rehabilitation, or improvement of wildlife habitat. CC &V has demonstrated and proven successful in reclamation practices to date at the Cresson Project in both interim and final reclamation projects, as evident by the numerous awards CC &V has received on reclamations practices completed at the site. CC &V's overall objectives of the reclamation and closure plan are to stabilize disturbed areas and re- establish the pre- mining land uses of wildlife habitat and livestock grazing and CC& V is committed to that overall objective to ensure an overall net gain of important wildlife habitat. 34. The Arcadis Baseline Technical Report identified several areas that may potentially support red - tailed hawks. The wildlife survey was conducted in 2011. Please indicate if any subsequent surveys have been conducted for raptor nests in the areas identified by Arcadis. If not, please commit to conducting a survey for raptor nests prior to disturbing these areas and commit to working with CDOW to identify mitigation measures in the event raptor nests are found. RESPONSE: No subsequent surveys for possible rapture nests in areas identified by Arcadis have been completed by CC &V since 2011. CC &V is committed to conducting additional survey for raptor nests prior to disturbing new areas associated with the MLE2 Project and committed to working with CDOW to identij� possible mitigation measures in the event raptor nests are found in those areas. The Division will be advised as this program moves forward. 35. The Applicant has designated `Wildlife Habitat' as one of the post- mining land uses. The Reclamation Plan for the Cresson Project is directed towards creating habitat for larger game species. Please specify what measures will be taken to create habitat for smaller non -game species. RESPONSE: Prior amendment applications reviewed and approved for the Cresson Project have referenced plating steep slopes with rock to emulate historic underground development rock piles in the area Emulating historic underground development rock piles helps to achieve the post- mining land use of rangeland/wildlife habitat by providing habitat for small mammals (foxes, pocket gophers, and ground squirrels), rodents (field