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final reclamation seeding and that this sampling effort will use ocular estimation of cover. No <br />discussion of herbaceous production sampling or shrub density evaluation in regards to third year <br />sampling was included in the revised page. The operator should commit to sampling during the <br />third year and remove the word "typically" from the revised page, or discuss what actions would be <br />taken if sampling was not conducted during the 3`d year following reclamation seeding. Also, <br />ocular sampling is subjective and hard to quantify. The Division believes the sampling plan for <br />final revegetation success sampling should be used, however in accordance with Rule 4.15.1(4) <br />sample adequacy need not be achieved for the 3 d year sampling effort. Please revise the proposed <br />page accordingly. <br />Response: Although not specifically reqMMW the applicabltatory provisions,CM is <br />proposing the option of limited monitoring (ocular estimation) of reclaimed areas in year 3 to <br />assess the progress of vegetative reestablishment. If this limited monitoring indicates poor <br />vegetative reestablishment, there is the opportunity for reseeding the area(s) or completing other <br />management practices to enhance vegetative reestablishment, potentially without "restarting the <br />clock" on the 10 -year revegetation liability period. This approach is consistent with the applicable <br />regulatory provisions, and has been used successfully at other sites, therefore, MCM suggests that <br />no modification of the referenced text is necessarv. Note also that as a result of the 2014 <br />submitting a revision sampling effort and associated research, MCM anticipates A69 and <br />revegetation success <br />g to change the revegetation success criteria for certain areas nical <br />dard, connt appr <br />23. Permit page 2.05 -33 discusses the reclamation and revegetation plan that will be used on the "No. 9 Portal <br />Area/Refuse Pile". The No. 9 Mine refuse pile was reclaimed in 2009. Please update the text on permit <br />page 2.05 -33 to include a discussion of how the No. 9 Mine refuse pile was reclaimed. <br />a. MCM Response: The referenced Permit text discussion has been reviewed and updated, as <br />appropriate, to reflect recent site reclamation activities. Copies of the revised Permit discussion <br />accompany these responses for replacement in the PAP. <br />b. DRMS Response: Please revise the first paragraph under the "No. 9 Portal Area/Refuse Pile" <br />section to clearly indicate the pasture reference area to be used for this parcel is depicted on Map <br />20. <br />c. MCM Response #2: Page 2.05 -33 has been revised to reference Map 20, and the revised page is <br />included with these responses. <br />d. DRMS Response #2: This item is considered resolved. <br />24. The information contained in this section is out of date with regards to the permit term information and <br />anticipated mining dates. Several of the specific pages where the dates are incorrect are 2.05 -48.1, 50, 51, <br />52, 53, 63 and 65. Although subsidence monitoring has been discontinued at the Williams Fork Mines <br />(with TR -12 and TR -30), this information still needs to be updated. Please update the permit term <br />information and anticipated mining dates that are listed in the text in the subsidence control plan, which <br />begins on permit page 2.05 -48 <br />a. MCM Response: The specific Permit text discussion for the Subsidence Control Plan has been <br />reviewed and updated, as appropriate, to reflect current status and conditions. Copies of the <br />revised Permit discussion accompany these responses for replacement in the PAP. <br />b. DRMS Response: Revised Page 2.05 -53; under the "Renewable Resources Lands" section <br />updates the discussion of subsidence for the Yampa River and the Williams Fork River. Please <br />address the following issues: <br />