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05.21.2018 Memo <br />To <br />Rob Zuber <br />Comments: <br />From <br />Janet Binns I have reviewed the application for Lorencito Canyon Mine, TR20. TR20 proposes some <br />CC: Laserfiche changes and clarification of the grassland success standards. This revision proposes to change <br />the previously approved woody stem density standard from 500 stems per acre in both <br />Re transplanted shrub plot and overall reclaimed grassland area, to 500 woody stems per acre <br />Lorencito <br />Lorespecific to shrub plot areas. This revision also clarifies which areas remain a part of the extended <br />grassland reference area since the permit boundary has undergone significant changes since <br />the extended reference areas were initially established. TR20 also proposes to allow up to 3 <br />perennial forb species to count towards the 5% forb cover component for the species diversity <br />success standard. TR20 also introduces a method to measure wildlife usage of the reclaimed <br />site. <br />The Division has the following concern or requests additional clarification from the operator: <br />1. Revised page 2.05-71 a still discusses domestic grazing the final two years of the liability <br />period. Domestic grazing is intended to demonstrate that the reclamation is able to <br />support the post mining land use or Rangeland and Wildlife Habitat. However, the <br />operator has stated to the Division that the landowner does not want the property grazed. <br />Please either revise this commitment, or state how the PMLU will be evaluated. (Rule <br />4.16.1(1)) <br />2. Related to item no. 1; LCC has proposed a wildlife usage sampling methodology on <br />revised page 2.05-73. Is this intended to demonstrate post -mining land use? (Rule <br />4.16.1(1)) if so, the Division suggests that LCC state they will either conduct domestic <br />grazing or wildlife counts to demonstrate post mining land use support. As submitted, <br />the text indicates that both methods will be used. The Division suggests a sentence on <br />page 2.05-73, stating that if the landowner request no domestic grazing the final 2 years <br />of the liability period, LCC will employ wildlife usage counts to demonstrate the post - <br />mining land use is being met. <br />3. Please correct "typo" on revised page 2.05-74; in Table 2.05.4-5 please correct "Woody <br />Seem Density" to Woody Stem Density. <br />Colorado Division of Reclamation, Mining and Safety <br />