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Louis Head, New Elk Coal Company <br />Page 4 <br />July 22, 2014 <br />Over the entire 66 disturbed acres classified as Wildlife Habitat, this works equates to —6 <br />stems /acre. <br />The landowners in question are NECC and Colorado Parks and Wildlife, (CPW). <br />Mike Trujillo of CPW was consulted on the proposed plan from its inception and was asked to <br />comment on the formal plan in writing. His letter, dated March 24, 2014 endorses the plan, with just <br />one comment: that the transplanted shrubs should be watered twice monthly during the first two <br />seasons after planting. <br />Please add a line to page 2.05 -60 clarifying the total number of shrub clumps that will be <br />established. Please also revise the watering plan to allow for two season's worth of watering, <br />per CPW's recommendation. <br />ii. TYPOS <br />The response is sufficient <br />iii. Permanent impoundments <br />The Division is in agreement, in principle, with the plan to retain ponds 4 and 8 as permanent <br />impoundments, as described on proposed pages 2.05 -52 and -53. <br />Please provide a letter from the landowner showing their support for the retention of pond 4 <br />as a permanent impoundment. (Since pond 8 is on land owned by New Elk Coal Company, <br />landowner approval is assumed.) <br />15. Permit boundary Maps 1 & 2 <br />The paper maps were scanned and georeferenced in ArcGIS and the area enclosed by the permit <br />boundary was measured. Although each of the steps in this process introduce errors, the area was <br />measured at 5770 acres which clearly does not agree with the Division's record or the value in Table 4 <br />on page 2.04 -1 (4198.9 acres). The permit boundary shown on the currently approved version of map 2 <br />(dated 1/31/2011) appears to correspond to this area. <br />Please ensure that all maps show the same permit boundary. The area enclosed by the boundary <br />(plus, the permitted acreage at the Jansen Loadout) should be equal to the value in Table 4. Until <br />and unless a revision is approved which extends the permitted area is 4198.9 acres. This comment <br />applies to all maps that show the permit boundary. <br />16. Map 2 unidentified parcel <br />The response is sufficient <br />17. Disturbance area boundary, Map 15 <br />The version of Map 15 dated 10/18/2013 is much clearer and easier to interpret than the currently <br />approved version. The disturbance boundary is clearly shown, as are the post- mining land uses and the <br />areas where refuse has been deposited. The following issues remain: <br />i. At the east end of the site an area has been indicated as "Industrial land use ". This does not <br />appear on the currently approved version of Map 15. Furthermore, the approved Post - <br />Mining Land Uses at the New Elk mine are Rangeland, Wildlife Habitat (Upland) and <br />