2015-07-22_REVISION - C1981014

• Permit No: C1981014
• IBM Index Class Name: Revision
• Doc Date: 7/22/2015
• Doc Name: Response to PAR Response Review ‎(Second Adequacy Review)‎
• From: Energy Fuels Coal, Inc
• To: DRMS
• Type & Sequence: TR45
• Email Name: RDZ
• Media Type: D
• Archive: No

Janet Binns
July 15, 2015
Page 11
Literature Cited
Hubbard, R. E. and R. M. Hansen. 1976. Diets of Wildhorses, Cattle and Mule Deer in the Piceance Basin,
Colorado. Journal of Range Management Vol. 29(5):389-392.
Pfister, J. A., G. B. Donart, R. D. Pieper, J. D. Wallace and E. E. Parker. 1984. Cattle Diets Under Continuous
and Four -pasture, One -herd Grazing Systems in Southcentral New Mexico. Journal of Range Management Vol.
37(1):50-54.
Vavra, M., R. W. Rice, R. M. Hansen and P. L. Sims. 1977. Food Habits of Cattle on Shortgrass Range in
Northeast Colorado. Journal of Range Management Vol. 30(4):261-263.
Wallace, J. E., J. C. Free and A. H. Denham. 1972. Seasonal Changes in Herbage and Cattle Diets on Sandhills
Grassland. Journal of Range Management Vol. 25:100-104.
Permit page 2.05.4-27a has been revised to include proposed woody plant density standards
for the Southfield Mine site in accordance with Mr. Crofts' technical review, and is attached in
the revised PAP pages for your review.
4. DRMS concern
On proposed page 2.05.4-27, it is unclear how EFCI plans to apply the weighting factor
for the portal area Vento land ownership and Corley land ownership. It has previously
been approved that the Portal disturbance area accounted for 20.2% of the mine
disturbance. The Portal disturbance area correlates to the woodland pre -mining
vegetation community. EFCI proposes that the Vento portal reclamation will be
weighted 9.42% and the Corley portal reclamation will be weighted 0.78%.
Page 5 of EFCI's explanation of proposed changes defines the Vento portal area was
surveyed as approximately 10.22 acres, and the Corley portal area was surveyed as
approximately 11. 71 acres. The Division calculates that the Vento properly would
account for 46.6% of the Portal area, and the Corley properly would account for 54.4%
of the Portal area.
Please provide an explanation of how the 9.42% and 0.78% acreage ratios were
determined.
EFCI Response
According to the PAR Response Review dated June 10, 2015, the Division accepts EFCI's
May 12, 2015 response that provided an acceptable explanation of how the reclaimed area
weighting factors will be applied.
The Division requests submittal of a revised page 2.05.4-27 that corrects the ratio allotted to
the Corley portal area reclamation. Page 2.05.4-27 has been revised to show the correct ratio,
and is attached in the revised PAP pages for your review.