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TRI-STATE GENERATION AND TRANSMISSION ASSOCIATION, INC. <br />HEADQUARTERS: P.O. BOX 33695 DENVER, COLORADO 80233-0695 303-452-6111 <br />November 29, 2017 <br />Mr. Brock Bowles <br />Environmental Protection Specialist <br />Colorado Division of Reclamation, Mining and Safety <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 RECEIVED <br />RE: New Horizon North Mine (Permit No. C-2010-089)012017 <br />Gnu <br />Permit Revision No. 2 (PR -02) <br />Adequacy Review Response Division of Reclamation, <br />Mining & Safety <br />Dear Mr. Bowles: <br />Tri-State Generation & Transmission Association (Tri-State) has received your adequacy <br />review letter for PR -02, dated October 6, 2017 and provides the following responses to your <br />comments on behalf of the Elk Ridge Mining and Reclamation's New Horizon North Mine. <br />Section 2.05.4(2)(d) Overburden and Topsoil Handling Plan <br />1. A letter from Mr. Garvey was included in the PR -2 application outlining his reclamation <br />plan requests. Bullet item 3 of the letter addresses the configuration, depth and order for <br />the replacement of Mr. Garvey's topsoil. These items should be described in the text with <br />a reference to the letter for consistency. <br />Response: Section 2.05. S Postmining Land Use has been revised to describe the request <br />made in item 3 of the landowner letter. Reference has also been made to Appendix <br />2.05.5-1 Letters from Landowners Consenting to Proposed Postmining Land Use. <br />Section 2.05.4(2)(e) Reve eta ation <br />2. It is being proposed that the irrigated pasture reference area (located by the NH2 facilities <br />area) be used as the reclamation standard for the reclaimed irrigated pasture on the <br />Garvey property. While the post mining land use and proposed management practices for <br />both areas is the same, the plant species composition of the two areas is quite different. <br />The irrigated pasture reference area is dominated by grasses (75.4% cover as shown in <br />the SL -19 application) and the Garvey property is proposed to be planted with all alfalfa <br />and no grasses. According to USDA, National Agricultural Statistics Service, Colorado <br />lands produce 35% more alfalfa by tons/acre than grass hay. Please provide additional <br />discussion demonstrating why the irrigated pasture reference area is a representative plant <br />community of the disturbed area and meets the requirements of Rule 4.15.7(3). <br />Response: Page 8-9 of the Section 2.05.4(2)(e) Revegetation narrative have been revised <br />to remove reference to the Irrigated Pasture Reference Area. Instead, the narrative now <br />provides revised Production Success Criterion and Cover Success Criterion for the NHN <br />Irrigated Pasture area on the Garvey property. Also, Maps 2.04.10-3, -4, -5 and -6 have <br />been removed from the PAP since they are no longer applicable. <br />AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER CRAIG STATION ESCALANTE STATION NULLA STATION <br />_/ P.O. BOX 1307 P.O. BOX 577 P.O. BOX 698 <br />A Touchstone Energy' Cooperative 1 CRAIG, CO 81626.1307 PREWITT. NM 87045 NUCLA, CO 81424-0698 <br />970.824-4411 505-876-2271 970.864-7316 <br />