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revised acreage of this site being 0.29 acres (see e -mails from Doug Corley to Janet Binns dated <br />25 November 2013; from Doug Corley to Janet Binns on 1 June 2012 and on 1 June 2012 from <br />George Patterson to Doug Corley as found in the CDRMS Laserfiche TR39 file), which was <br />subsequently removed from the original proposed New Portal Reference Area making this RA <br />1.69 acres in size. <br />Evidence suggests that for some reason the revised RA figures apparently were not revised in the <br />TR39 submittal and will be correct in connection with this response. <br />Concern # 2. Comparison of cover and productivity, and woody plant density is based <br />upon the relative areas that each plant community was projected to occupy prior to mining <br />disturbance for reclaimed areas at the mine areas in accordance with Rule 4.15.7(4)(b). <br />EFCI is approved to compare reclamation success standards for the load out to the New <br />load out reference area (TR41), approved November 6, 2014, page 2.04.10 -5b. <br />In accordance with approved permit page 2.04.10 -5 and 5a, revegetation success standard <br />for plant cover and forage production will be calculated based upon the surveyed areas of <br />the three areas of the three reference areas, Refuse File reference area, the New Portal <br />reference area, and the Old Mine Portal reference area. <br />Response: Agreed and understood. <br />Concern # 2 continued. EFCI is proposing to change the species diversity standard based <br />upon the relative acreage of the four reference areas, including the New load out reference <br />area values with the three mine site reference areas. The proposed change is inconsistent <br />with the methods for determining reclamation success for cover and production as stated <br />on approved permit pages 2.04.10 -5 through 5b. <br />Please provide justification for using the relative acreage of the four reference areas for an <br />individual success standard. <br />Response: The current warm season species diversity standard is a permit wide standard and has <br />nothing to do with the characteristics of the individual reference areas. Since the proposed warm <br />season diversity standard will require a calculation, it was thought prudent to combine this <br />calculation into one number rather than calculating two different numbers. It was felt that this <br />proposal was entirely consistent with the currently approved standard of having a constant value <br />across all reclaimed areas within the Southfield Mine Permit area. <br />Concern # 3. The approved post mining land use is rangeland and wildlife habitat. The <br />operator is responsible for establishing a post- mining land vegetative community that <br />supports both land uses. The Colorado Division of Wildlife (aka Colorado Parks and <br />Wildlife) provided recommendations in 2002 regarding management of the wildlife habitat. <br />However, the reclaimed property is privately owned and some of the landowners have <br />expressed interest in reestablishment of trees and shrubs as well as domestic grazing. <br />2 <br />