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EFCI conservatively estimates that with these selected examples, this is by no means a <br />comprehensive list, the Division has previously approved either via final bond release or in their <br />currently approved Mining and Reclamations Permits, covering nearly 15,000 acres of land <br />revegetation success woody plant density standards significantly different than what they are <br />now saying must be applied to 56.6 acres of land in Fremont County. EFCI feels that the <br />Division is being extremely inconsistent in this situation and requests a detailed explanation <br />explaining why the environmental concerns associated with the Southfield Mine site are so <br />unique that this property requires a special set or rules that is several orders of magnitude higher <br />than any other coal mines which have ever operated or which is now operating and which cannot <br />be duplicated at any other location in the state of Colorado. <br />Partial Response to Landowner Comments. <br />EFCI believes that the landowners have made so many unfounded, undocumented, incorrect and <br />untrue statements regarding the reclamation situation at the Southfield Mine that it would be <br />impossible to address them all. It is the Division's job to defend their regulations and by their <br />refusal to become involved they have by default make the decision that requires the Permittee to <br />address this misinformation. While it is impossible for EFCI to address all of the misinformation <br />being conveyed, we feel that three issues need to be addressed. <br />The landowners state in their e -mail of 18 March 2015 that "the Colorado Division of Wildlife <br />states `pinon and juniper are becoming invasive' but if you look at our property and the <br />revegetation reports, you know that this is not the case." With respect to this statement, EFCI <br />offers the following comment. <br />It is extremely disappointing to work on a project where the landowners who by their own <br />admission "have no previous experience with how the entire process is done" have decided that <br />all of the scientific literature relative to the issues they are concerned with some how do not <br />apply to their property and that neither the Operator, who has been recognized for excellence in <br />reclamation for decades, now knows nothing about what they are doing nor that the Division <br />likewise knows nothing about their concerns and knowingly refuses to enforce their regulations. <br />No less an authority than the US Department of Agriculture - Natural Resource Conservation <br />Service reports on their website websoilsurvey.nres.usda_gov, that for soil mapping unit 122, one <br />of the predominate soils mapping units found at the Southfield Mine site, the Wages loam, 2 to 9 <br />percent slopes and the only soils mapping unit, at the Southfield Mine site which in April of <br />2015 has a completed Ecological Site Description, corresponding to the Loamy Foothill 11 -14 <br />inches precipitation zone, has a total of five different plant communities corresponding to this <br />one ecological site, the Blue Grama Community, Decadent Community, Juniper and /or Pinyon <br />Dominated Community, Reference Community and a Snakeweed, Annuals, an At Risk Plant <br />Community and Bare Ground Plant Community. <br />With respect to the Blue Grama Community, the NRCS, gives the following site specific <br />description to this community for Fremont County, Colorado. <br />"This plant community developed with continuous grazing without adequate recovery <br />11 <br />