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Janet Binns <br />July 15, 2015 <br />Page 2 <br />EFCI Response <br />According to the PAR Response Review dated June 10, 2015, the Division accepts these <br />revised acre values, and requests submittal of a revised page 2.04.10-5b to correct these <br />surveyed values in the permit. <br />These acre values are shown on page 2.04.10-5a, rather than page 2.04.10-5b, of the PAP. <br />Page 2.04.10-5a has been revised to show the correct surveyed values, and is attached in the <br />revised PAP pages for your review. <br />2. DRMS concern <br />EFCI is proposing a change to the diversity standard based upon the relative acreage of <br />the four reference areas, including the New load out reference area values with the three <br />mine site reference areas. This proposed change is inconsistent with the methods for <br />determining reclamation success for cover and forage productivity as stated on <br />approved permit pages 2.04.10-5 through 5b. <br />Please provide justification for using the relative acreage of the four reference area for <br />an individual success standard. <br />EFCI Response <br />According to the PAR Response Review dated June 10, 2015, the Division accepts EFCI's <br />response and is in agreement with the proposed warm -season grass success standard change. <br />DRMS concern <br />The approved post mining land use is rangeland and wildlife habitat. The operator is <br />responsible for establishing a post -mining vegetation community that supports both land <br />uses. The Colorado Division of Wildlife (aka Colorado Parks and Wildlife) provided <br />recommendations in 2002 regarding management of the wildlife habitat. However, the <br />reclaimed property is privately owned and some of the landowners have expressed <br />interest in reestablishment of trees and shrubs as well as domestic grazing EFCI planted <br />Rocky Mountain [corrected] juniper seedlings, in addition to other approved free and <br />shrub species on the refuse area and on the Vento properly at the portal area, as part of <br />the reclamation plan to establish woody plants. <br />Due to the stated interests of the landowners, Division does not consider it appropriate <br />to 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 to include these species. <br />