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Jim McArdle <br /> October 30, 1980 <br /> Page 4 <br /> It is our opinion that, in the case of Climax, bodies of water <br /> created for mining and/or used as part of the reclamation <br /> process must be maintained and managed for wildlife habitat. <br /> 22. Much of the reclamation proposed is based upon results or <br /> expected results of Climax research. To date, however, we <br /> have seen no hard data emanating from research efforts that <br /> lead us to believe we should accept the premise that Climax <br /> has or will have solutions to the many problems of high altitude <br /> reclamation. Therefore, we request that Climax send all <br /> results generated by their research projects to the MLR staff, <br /> DOW and other appropriate agencies for analysis. This could <br /> be done in the form of an annual review. <br /> 23. Just how good or bad is sewage sludge, wood chips and waste <br /> rock as a soil substitute? Again, no hard data has been pre- <br /> sented which would allow reviewers an opportunity to evaluate <br /> this. We feel that justification for the use of sewage and wood <br /> chips must be provided. If we read section 10 correctly, it <br /> appears that sewage sludge may be unacceptable as a soil <br /> substitute - yet it is still proposed for reclamation. <br /> 24. Climax often speaks of the "latest technology and state of the <br /> art". Are we to assume that reclamation and water treatment <br /> processes proposed by Climax are the latest technology and <br /> state of the art? Do literature reviews and research results <br /> verify this? <br /> 25. Is all topsoil being saved? (yes or no) To save topsoil "where <br /> practicable" based on equipment availability etc. does not fulfill <br /> the intent of MLR regulations. Topsoil at Climax should be con- <br /> sidered a very precious resource. <br /> 26. Of the total amount of disturbed area at Climax, what % will be <br /> revegetated, reclaimed as lakes and talus slopes? <br /> 27. On page 10-2, projected final reclamation for revegetated areas <br /> is a 5-40% foliage cover. We suggest that a 5% vegetative cover <br /> is unacceptable and a 40%o cover is marginal. Please comment. <br />