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Twentymile Coal, LLC (TC) <br />Narrative <br />Lease by Modification Application Wolf Creek Reserve — April 2014 <br />the wildlife species identified and discussed in the preceding sections, the following TES <br />species are identified as potentially occurring in Routt County: Yellow -billed Cuckoo, Black - <br />footed ferret, Canada lynx, and Boreal toad. Detailed review of habitat preferences, mapped <br />habitat, and known sightings for these additional species indicates little or no potential for <br />these species to inhabit the Permit Area. This conclusion is supported by impact reviews of <br />recent mine projects in the same areas by Colorado Parks and Wildlife. <br />G. Plant Species — Wolf Creek Reserve <br />Within the Wolf Creek mining area, existing vegetation is characterized by the sagebrush, <br />sagebrush/meadow, pasture, cropland, meadow, and sagebrush/grassland plant communities. <br />Review of current databases for TES species indicate that the only TES plant species known <br />to occur in the general vicinity is Spiranthes diluvialis (Ute Lady' Tresses). Documented <br />occurrences of Ute Lady's Tresses have been at elevations below 6,500 feet, which is well <br />below the lowest elevations in the Mine Permit Area, and field surveys have not identified <br />any occurrences of this species within the Permit Area. <br />The only potential impact on plant species anticipated as a result of mining operations and <br />related surface subsidence would be localized shifts in vegetation communities for areas in <br />and adjacent to Fish Creek where seasonal flooding and/or sub -irrigation create favorable <br />conditions for riparian vegetation. In such cases, areas of Sagebrush -Meadow may transition <br />to riparian (Meadow) areas, with accompanying habitat benefits. <br />H. Prevention of Fires — Wolf Creek Reserve <br />Planned mining within the proposed lease area will be limited to underground operations, and <br />no surface coal mining or other surface activities will occur. Therefore, surface fire <br />prevention should not be a significant issue. Nevertheless, as a standard operating practice, <br />TC implements and maintains the following surface controls for all mine operations and <br />facilities: <br />All fuel tanks are either double -walled or bermed for containment, and any electrical <br />installations are fenced for security. Vegetation is controlled in and around all surface <br />installations. TC trains all mobile equipment operators in fire -fighting procedures, and <br />maintains a core group (Fire -Brigade) with regular training in both fire -fighting and <br />emergency response. All contractors are also required to have basic fire -fighting training, <br />and all mine and contractor mobile equipment is required to have on -board fire extinguishers. <br />TC also has a large water -truck and heavy equipment (wheel loaders and tracked dozers) that <br />can be mobilized in an emergency for fire -fighting or emergency use. In the event of a fire, <br />immediate measures (control or removal of flammable materials and the use of portable <br />extinguishers) would be taken to control and contain the fire, if possible. For a larger fire, <br />Mine Security would be notified, and the Fire Brigade along with any required equipment <br />would be dispatched to assess and control the fire. If the initial assessment indicates that <br />WCR BLM Lease App Narrative 0414.docx Page 11 <br />