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Mr. Steve Glass December 9, 1998 Page 2 functioning drain tile system. The continuing drainage has encouraged the encroachment of nettles and other weeds and is probably causing the organic soils of the marsh to oxidize and flush nutrients downstream through the drainage system. The southern outlet of the drain has been exposed by severe gullying and erosion in a ditch immediately north of the railroad crossing. The ditch appears to be the dominant drainage of the area, as the drainage on the west side of the drumlin is split, with only minor base flow going south beneath the railroad on that side. The east side ditch appears to have eroded out along the tile path due to a combination of soft, organic soils, erosive flows and the shallow rooting zone of the reed canary grass dominating the area. No springs were located during the field review. Based on our field review, the following appear to be the leading environmental issues: • Although the project does not footprint or fill wetlands, the state wetland water quality rules under NR 103 may apply under any state surface mine permits because of the discharge of storm water to adjacent wetlands. • The project may have an adverse impact on local groundwater recharge. The coarse mineral content of drumlins can function as a recharge catchment for adjacent wetlands, lakes or streams due to the ease of percolation and the steep groundwater gradients involved. Removal of this material and diversion of precipitation into surface runoff by the abandoned facility could skew the local water balance further in favor of surface runoff, exacerbate eutrophication of the adjacent wetland and have a minor, depressing effect on the local water table. These local effects could be offset by destroying the tile drainage system in the wetland and planting deep-rooted, native grassland over a permeable soil layer as final cover on the mine parcel. We expand on this topic later in this report. • Breaking the ground or removing the plant cover on the drumlin would generate erosive runoff. We recommend strict enforcement of erosion control standards, combined with controlled, staged disturbance of surface vegetation and the tree canopy only as necessary for operations. We also recommend that a 10-year, 12- hour storm design storm be used as the basis for the design of erosion control measures and storm water management facilities. • The existing vegetation of the drumlin and adjacent marsh does not appear to have any special resource significance. However, high points adjacent to wetlands or other water resources have a very high probability of having Native American campsites or other cultural features. Under Section 44.40 of the Wisconsin State Statutes, the State Historical Society of Wisconsin has review authority under any other state approvals to determine whether the site has previously reported cultural features. If so, the Society would then have the authority under this statute to require mitigative measures prior to mining. B33A042\B33-98A