2013-07-26_PERMIT FILE - M2012052 (5)

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the road gutter and sediment control areas. An erosion and runoff control map will be drafted per discussions with CDPHE. In response to unoxidized ores, no minable quantities of unoxidized ore has been blocked out, and if and when some is discovered, it is not anticipated that it will be stored so as to cause any storm water related environmental issues. Comment 9 Pursuant to Rules 6.3.4(1)(c) and 6.3.4(2)(b) provide specific seed rated for species prelisted on the second page of Exhibit D. Response: The minimum seeding rate of 10 pounds of seed per acre is shown on page 2 of Exhibit D (Rule 6.3.4(1)(c)), and the estimated cost for reclamation is shown on page 3 to be $2,000 per acre including seed and finish (Rule 6.3.4(2)(b)). Specific seed costs currently range from $5.00 to $7.50 per pound for the most commonly used species. It is our experience that this application at near this rate for covered seed leads to a good stand of grass, while also being the most economical. As a supplement to the information provided in the permit application, specific seeding rates for the grass species identified on Page 2 of Exhibit D, is normally at a rate of 6 to 8 pounds of seed (live seed) per acre, planted as individual species for covered seed. Canadian bluegrass has the smallest seed diameter of those listed, thus the lowest application rate of about 4 to 5 pounds per acre for single species. When multiple grasses are sown, the application rate is reduced into the range of 1.5 to 2 pounds of seed per acres per species. This application rate typically allows 5 to 6 different species of grasses to be mixed. The grass reclamation mix that we have most recently used on the site for reclamation contained a mixture of Wildrye (20%), Wheatgrass (20 %), Smooth Brome (20 %), Slender Wheat (10 %), Crested Wheat (10 %), along with ryegrass, and Orchardgrass (10% each). The results of this mix are currently being evaluated and recommendations for any modifications will be made following review of this season's results. The local soil conservation district is selling what they term a "Teller -Park Dryland Pasture and Stabilization Mix" that contains three species of Wheatgrasses, Meadow Brome, Ryegrass, and an Orchard grass. This mix, the mix used previously on the site by Braun, or any of the other grasses listed in Exhibit D will be suitable as a shotgun approach for reclamation and the seed mix that contains members of these species will likely be suitable. As a result, whatever mixture might be in stock by either the soil conservation district, or from a private vender can likely produce a reasonably good vegetative cover. However, if it is found that a one or more of the grasses that have performed well in our previous reclamation, we might recommend that grass over others. It might be that DRMS has experience with other mines that have the same hillside slopes and western exposures in the area, and can provide additional input based on their experience. The common goal of both the regulators and industry is to establish vegetative cover in the least amount of time.