1977-11-10_PERMIT FILE - M1977493

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r k . COMMENTS ON CLIMAX MOLYBDENUM COMPANY'S MINE RECLAMATION PLAN Area: Approximately 11 ,000 acres of continguous land in Eagle, Lake and Summit counties. Headwaters of Eagle and Arkansas Rivers and Tenmile Creek. Approximately 4,500 acres will be directly affected, of which 2,900 acres are willow meadow, 800 acres are spruce and fir, 100 acres are aspen and 680 acres are tundra. General Comments: Reclamation is not scheduled to start until 1978-1982, with most scheduled between years 2016 and 2025. Most reclamation tech- niques considered have not been tried on a large scale and satisfactory evidence of their potential success is not available. Plans for revegeta- tion of the disturbed areas dn not consider plant succession, native pl =_nt species, esthetics and are not imaginative or innovative. The reclamation plan poorly documents present animal occupancy by habitat type and has no provision for retaining or attracting native animals to reclaimed areas. Both the wildlife and recreation sections of the report are completely inadequate. No mention is made of tourism and the positive and negative impacts the mine development has had or will have in the future. Recommendations: 1 . Present plan for management of the mined area after 2026. Will the land be given to the U. S. Forest Service, Division of Parks and Outdoor Recreation, etc. for management in perpetuity? How will management costs be funded after 2026? 2. Initiate reclamation of a major area now on a scale large enough to demonstrate that proposed revegetation can be done. For example, part of the Robinson and/or Tenmile tailing ponds can be reclaimed in the near future instead of waiting until after 2000. 3. Consider revegetation with native plants such as aspen, maple, alder, willow, sedges , etc. The "Climax Seed Mixture" has little value for animals. The same is true for spruce and lodgepole pine. Revegetation should consider normal plant succession in the area using native plants or plants desirable to wild animals. 4. Consider innovative reclamation techniques such as creating a wet meadow for establishment of sedges and willows. Techniques such as the use of plastic sheets , bentonite clay, etc. may result in interrupted drainage and be conducive to re-establishment of formerly existing plant communities. 5. Sample area by vegetation types to ascertain present animal abundance and diversity. Attempt to recreate vegetation types disturbed so that nature communities of plants and animals will eventually repopulate the area.