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GORHAM ENERGY CONSULTANTS LLC <br />February 18, 2014 <br />Leigh Simmons <br />Colorado Division of Reclamation, Mining, and Safety <br />1313 Sherman St, Rm 215 - f'' �vED <br />Denver, CO 80203 �" `� "" <br />RE: Change to post - mining land use <br />FEB "� `,j 2014 <br />Technical Revision No. 68 (TR -68) D�\nS*N OG REWMATION <br />tv�NNG,;ND SAFETY <br />Dear Mr. Simmons: <br />After discussions with Sandy Brown, NECC will not be requesting a change to the post - <br />mining land use in TR -68, which responds to issues raised in the 2012 Midterm Review <br />No. 6 (MT6) for the New Elk Mine. <br />The currently approved post- mining land uses (PMLU) for the New Elk mine are <br />discussed in the approved permit text beginning on pages 2.05 -54 and 55. Under TR -68, <br />page 68, NECC had initially proposed that the PMLU be changed to rangeland, a change <br />that is in alignment with the proposed rule change definition of rangeland, which in <br />essence, requires that wildlife considerations are assumed under the proposed definition <br />of rangeland. As you know, the proposed Rule changes continue to be under review and <br />consideration by other parties, and the timing of any final approval of said Rule changes <br />is unknown at this time. As discussed, the Division believes changes to the shrub plan <br />can be reviewed and potentially approved under the currently approved land uses of <br />rangeland and two types of wildlife habitat, upland and riparian. <br />It is important to note that the original proposed request to change the PMLU in no way <br />represented an attempt to alter or reduce the commitment to reclaim disturbed areas to <br />benefit wildlife usage and wildlife habitat in general. To the contrary, the proposed <br />PMLU change focused exclusively on improvements to the plan to re- establish shrubs, <br />which in the currently approved plan is poorly conceived, technically flawed, and not <br />representative of current state -of -the -art practices and proven techniques to establish <br />shrubs on reclaimed areas. It is the goal of TR -68 to receive the Division's approval of a <br />shrub re- establishment plan that will greatly improve the chances for success and also <br />improve the overall reclaimed area with regard to re- establishing quality wildlife habitat. <br />The currently approved plan with regard to fish and wildlife is documented on permit <br />pages 2.05 -57 and 58. The primary mitigation for fish and wildlife during and after <br />operations is limiting the disturbance (as an underground mine), properly locating <br />facilities, and using reclamation and revegetation procedures and techniques as approved <br />under Section 2.05.4 to enhance the reclaimed area as wildlife habitat post - mining. As <br />discussed on -site with representatives of the CPW, the mine site area, in particular, the <br />13356 Wild Basin Way ■ Broomfield CO 80020 - Phone: 303.465.1274 - kent @gorhamenergyconsultants.com <br />