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KC* DNR O % Memo COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources To: Zach Trujillo From: Binns, Janet Date: August 29, 2018 Re: Colowyo Mine, C1981-019, TR123 Review I have reviewed Colowyo Mine's application for a Technical Revision to replace the currently approved Danforth Hills Aspen Reference Area with the Collom Aspen Reference Area, for reclamation success comparison for areas in the South Taylor mining area. I have the following comments or requests for corrections: 1) Although this comment is not germane to this application, CCC submitted page 2.04.10- 6 with the TR123 application. The statement that Rare and Endangered Plant species were last evaluated using the August 21, 1996 USFWS list. The Division usually requires the operator to verify the list at each permit renewal. RN7 was approved on July 9, 2018. Was the Rare and Endangered Plant Species evaluated for any new listings? This statement needs to be updated to reflect recent evaluation of the most current list. 2) Although, the Division concurs that the Collom Aspen reference area is an acceptable replacement for the Danforth Hills Aspen Reference Area for comparison to reclaimed areas at the South Taylor district, there were errors in the comparison. CCC's comparison of Danforth Hills Aspen Study Area cover data and Collom Aspen Reference Area cover data was acceptable, but the "Reference Area Statistical Comparison table" needs to reflect that 15 transects were collected in 1984 not 13. Likewise on this table, the comparison of Danforth Hills Aspen Study Area production data and Collom Aspen Reference Area production data was acceptable, but the table needs to reflect that 13 transects were collected in 1984 not 15. 3) On the Exhibit 10 -Item 6, "Reference Area Statistical Comparison table", CCC used a vegetative cover value of 74.3% for the 1984 Danforth Hills Aspen Reference Area value in its comparison with the 2005 Collom Aspen Reference Area. The Division was unable to locate where CCC found the 74.3% cover value. All of the 1984 Danforth Hills data show that the Aspen Reference Area cover was 78.1%. CCC also submitted a new Table 5 that reiterates the "Danforth Project Vegetation Cover -1984 Aspen Reference Area" with yet a different value for the 1984 Aspen Reference Area vegetative cover of 94.27%. Exhibit 10 -Item 5, Tables 3.3, 3.6,