2017-03-23_PERMIT FILE - C1981019A

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RULE 2 PERMITS 'k,. I, e . Sagegrouse Mitigation Recently, the federal status of the greater sagegrouse has been changed to "Candidate for Listing." Prior to this development, during permitting activites for the South Taylor Mining area, regulatory developments convinced Colowyo, CPW and the Colorado Division of Reclamation, Mining and Safety to target sagegrouse brood rearing habitat for future reclamation planning efforts and overall improvement in shrub establishment on reclaimed lands at Colowyo. The result of these efforts was the approval of TR -72 that rewrote the existing reclamation plan and performance criteria for bond release (TR -72 has since been modified by TR -82 and soon by TR -84 that further refine specific components of the existing reclamation plan). This new plan was developed specifically to create sagegrouse brood rearing habitat, while promoting improved shrub establishment on all reclamation areas. This effort and focus will continue into the future with Collom expansion area reclamation, as the reclamation plan developed for Collom mirrors the principles and innovations applied to the existing mining area. As stated previously, Colowyo will focus on sagebrush steppe establishment as a function of sagegrouse habitat creation. Sagebrush oblitgate species will also benefit from these efforts as a result. Again, please refer to Map 46 for the location of (potentially impacted) pre -mine sagegrouse lek areas and proposed stockponds that will add value for sagegrouse habitat. The reclamation plan focus, reclamation seed mixes, bond release criteria, interim revegetation monitoring program and pre -planning of disturbance to avoidance high value habitat (leks) where practical, was initiated in large part to specificically mitigate potential impacts to area sagegrouse populations from mining activity. Consideration was given to all endemic wildlife populations during the creation of the proposed reclamation plan and seed mixes in order to balance multiple uses among different wildlife species, not only on the sagebrush steppe areas, but areas targeted for grassland as well. Justification for the use of specific plant materials proposed for the sagebrush steppe and grassland areas may be found under Section 2.05.4. Electric power lines located in the permit area will be constructed in accordance with the requirements of Section 4.18 to minimize potential electrical hazards to large raptors. Vehicle use within the Collom area will be limited to the active mining area and the various support facilities. Off-road vehicle use is kept to a minimum and is usually only authorized for surveying, environmental data collection and monitoring, security, etc. Travel by foot, which causes much more disturbance to wildlife than vehicle traffic, is highly unlikely outside active mining areas. Any firearm activity inside the proposed Collom area boundaries will be closely managed by Colowyo. Speed limits in the mine area will be limited to reduce the likelihood of collisions between vehicles and wildlife. Colowyo employees are fully aware of the possibility of encountering wildlife on and around the current operation and will take special care to avoid these species in the Collom area. With regard to sage grouse populations, Colowyo believes that the revegetation metrics presented within this submittal address the concern for negative impacts to area populations and brooding habitat. It is anticipated that sage grouse use of reclaimed lands will return to pre -mining levels, or perhaps return to elevated levels as has been experienced at certain Wyoming mining operations. Additional Mitigation Measures Recommended By CDOW During the PR -03 permitting process, Colowyo provided CDRMS with copies of the communications between CPW and Colowyo that identified additional mitigation strategies Colowyo has proposed in Collom — Rule 2, Page 106 Revision Date: 11/16/16 Revision No.: MR -166