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2015-05-12_REVISION - C1981014
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2015-05-12_REVISION - C1981014
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Last modified
8/24/2016 6:00:14 PM
Creation date
5/13/2015 9:30:57 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981014
IBM Index Class Name
Revision
Doc Date
5/12/2015
Doc Name
Adequacy Review Responses
From
Energy Fuels Coal Inc
To
DRMS
Type & Sequence
TR45
Email Name
JHB
DIH
Media Type
D
Archive
No
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EFCI planted One -seed juniper seedlings, in addition to other approved three and shrub <br />species, on the refuse area and on the Vento property at the portal area, as part of the <br />reclamation plan to reestablish woody plants. <br />Due to the stated interests of the landowners, Division does not consider it appropriate to <br />selectively exclude Juniper and Oak brush in the woody stem success values. Neither <br />species is considered a noxious species in accordance with the Colorado State Noxious <br />Weed Management Act. Please revise any proposed changes to the woody plant density <br />success standard to include these species. <br />Response: Rule 4.15.1(1) states: "Each person who conducts surface coal mining operations <br />shall establish on all affected land a diverse, effective and permanent vegetation cover of the <br />same seasonal variety native to the area of disturbed land, or species that support the approved <br />postmining land use." Rule 4.15.1(4) states that "each operator shall submit a weed <br />management plan that will become a part of the permit requirements. Species to be considered <br />shall be noxious weeds asset forth in the permit. The plan shall also address invasion of other <br />weed species that seriously threaten the continued development of desired vegetation. Weed <br />control measures shall also be used whenever the inhibitation of the disturbed area by weeds <br />threatens further spread of weeds to nearby areas." <br />Rule 4.15.2 states that "Plant species may be approved for use only if the species meet the <br />following criteria: (1) the species are compatible with the plant and animal species of the area; <br />(2) the species meet the requirement of applicable State and Federal seed or introduced species <br />statutes and are not poisonous or noxious; and (3) introduced species may be used after <br />appropriate field trials and /or relevant technical literature have demonstrated that the <br />introduced species are desirable and necessary to achieve the approved postmining land use." <br />Rule 4.15.8(6) states; "that the vegetation on the reclaimed surface consists of a mixture of the <br />species of the same seasonal variety native to the area of disturbed land, or species that support <br />the approved postmining land use. The vegetation on the reclaimed surface must be of equal <br />or superior utility for the approved postmining land use when compared with the utility of <br />naturally occurring vegetation during each season of the year." <br />Response: EFCI never planted "One -seed Juniper" in their tree and shrub planting program as <br />no nursery seedlings of One -seed juniper could be located to transplant. Rocky mountain <br />juniper was planted instead. EFCI also readily acknowledges that neither One -seed Juniper or <br />Gambel Oak are on the state list of noxious species, however, the Division's response <br />demonstrates a lack of understanding of their regulations in that they look no further at what <br />they recommend to be planted other than they look only at what is there now and assume that <br />since it is there, it must be OK to plant without any consideration of whether it is compatible <br />with the approved post mining land use or whether it might have any other deleterious properties. <br />The mere fact that a species is native to the area of disturbance only scratches the surface in <br />determining whether or not it can or should be planted on the reclaimed areas. The <br />recommendation made by the Division that EFCI knowingly plant poisonous trees and shrubs in <br />connection with their reclamation program is in direct contradiction of all of their regulations <br />9 <br />
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