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02.7.2019 <br />To <br />Rob Zuber <br />From <br />Janet Binns <br />CC: Laserfiche <br />Re <br />Lorencito <br />TR20 PAR Response <br />Review <br />Memo <br />Comments: <br />I have reviewed New Elk Coal Company's adequacy responses to the Division's <br />Preliminary Adequacy Review, dated May 23, 2018, for Lorencito Canyon Mine's <br />TR20. The Division identified six items of concern. NECC provided responses on <br />February 6, 2019. This memo repeats the adequacy item, and comments in blue are the <br />Division's evaluation of NECC's response. <br />1. Revised page 2.05-71a still discusses domestic grazing the final two years of <br />the liability period. Domestic grazing is intended to demonstrate that the <br />reclamation is able to support the post mining land use or Rangeland and <br />Wildlife Habitat. However, the operator has stated to the Division that the <br />landowner does not want the property grazed. Please either revise this <br />commitment, or state how the PMLU will be evaluated. (Rule 4.16.1(1)) <br />NECC has made the requested revision to the text. NECC failed to paginate the <br />pages, making correct page referencing impossible. Please put page numbers <br />on the revised pages. <br />2. Related to item no. 1; LCC has proposed a wildlife usage sampling <br />methodology on revised page 2.05-73. Is this intended to demonstrate post - <br />mining land use? (Rule 4.16.1(1)) if so, the Division suggests that LCC state <br />they will either conduct domestic grazing or wildlife counts to demonstrate post <br />mining land use support. As submitted, the text indicates that both methods <br />will be used. The Division suggests a sentence on page 2.05-73, stating that if <br />the landowner request no domestic grazing the final 2 years of the liability <br />period, LCC will employ wildlife usage counts to demonstrate the post -mining <br />land use is being met. <br />NECC provided an appropriate response and revised page. The revised page <br />needs pagination. <br />3. Please correct "typo" on revised page 2.05-74; in Table 2.05.4-5 please correct <br />"Woody Seem Density" to Woody Stem Density. <br />Colorado Division of Reclamation, Mining and Safety <br />