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West Mine area, is already heavily used by wildlife, including deer, elk, bear, and turkey. <br />The majority of the main mine facility is long and narrow, stretching along nearly two <br />miles of the Purgatoire River. Access across the mine is very important to the wildlife <br />that use the 30,000 acre timbered area of the Bosque del Oso State Wildlife area. The <br />CPW is also the landowner surrounding a large portion of the disturbed area. Having <br />grassland areas adjacent to the river along with shrub groupings is a vast improvement <br />over a plan to establish a shrub every five feet over large portions of the reclamation. <br />Wildlife can utilize these shrub grouping areas and will also having access to important <br />grasslands located in close proximity of the river. Shrub groupings on the RDA will <br />provide loafing and resting areas on the more open area of the reclaimed RDA, especially <br />when properly located toward the center of the reclaimed area. <br />The currently approved plan to re- establish vegetation, including shrubs, can be found <br />beginning on approved pages 2.05 -47b under the heading (f) Revegetation. Under <br />proposed TR -68, the revegetation plan begins on page 58 of Section 2.05 part 1. No <br />change to the rangeland seed mix, cover standard, production standard, or diversity <br />standard is contemplated or proposed under TR -68. No change to the approved sampling <br />methodology (shrubs excepted) is proposed under TR -68. Permit text remains unchanged <br />with regard to previously approved plans and commitments. Only the land use change <br />(to also be left unchanged, as discussed above with minor wording adjustments) and a <br />change to the shrub plan, success methodology, and shrub standards is proposed under <br />TR -68. NECC remains interested in changing the shrub re- establishment plan in <br />accordance with pre - permitting discussions with CPW. <br />To that end, we request that the Division review the plan to re- establish shrubs as <br />originally proposed and provide NECC any questions or concerns. In the forth - coming <br />adequacy response, permit text will be reinstated as previously approved with regard to <br />the PLMU. <br />We look forward to working with you to address all of the Division's concerns. Please <br />feel free to call me at any time. <br />Sincerely, <br />Kent Gorham <br />Principal/Technical Services <br />13356 Wild Basin Way • Broomfield CO 80020 - Phone: 303.465.1274 - kent @gorhamenergyconsultants.com <br />