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PeaboPeabody Sage Creek Mine <br />RGY 29515 RCR 27 <br />Oak Creek, CO 80467 <br />Peabody Sage Creek Mining, LLC <br />perpendicular to the flow path. Willow/riparian root balls will also be selectively placed to reinforce <br />these straw bale dams. This will force flow out of the shallow channels/flow paths and into adjacent <br />riparian and riparian/meadow areas. The straw bale wing diversion structures will not create wetland <br />impoundments, but rather will distribute flow-through riparian zones enhancing palustrine emergent <br />wetland establishment and growth in these and adjacent areas. Straw bales will be placed and staked by <br />hand. Vehicles and equipment may be used selectively for straw bale hauling and willow/riparian root <br />ball placement. If equipment is used within the wetland and riparian areas, its use will be minimized <br />and operational control measures, including the use of low ground pressure equipment and/or mats, may <br />be used as appropriate to reduce impacts to soil and vegetation. The proposed enhancement measures <br />are entirely consistent with CDRMS regulations which recommend "using straw dikes, riprap, check - <br />dams, mulches, vegetative sediment filters, dugout ponds, and other measures that reduce overland flow <br />velocity, reduce runoff volume, or trap sediment". These measures will extend and support the <br />enhancements previously established below Pond 002 and will result in similar benefits through initial <br />enhancement for the areas below Pond 004. <br />The CDRMS regulations specifically require operations to minimize disturbance to the hydrologic <br />balance onsite and in adjacent areas, and to prevent material damage to the hydrologic balance outside <br />the permit area (2 CCR 407-2 Section 4.05.1(1)). Sediment ponds and "other treatment facilities" are <br />the primary method of treating runoff from the disturbed area (Section 4.05.2). Wetlands are known to <br />provide multiple benefits to water quality including the ability to filter suspended sediments and through <br />natural chemical and biological processes to reduce potential pollutants from runoff from both mine <br />disturbance and undisturbed areas. The existing marginal wetlands below Ponds 002 and 004 have been <br />shown to effectively reduce chemical concentrations of certain potential pollutants in PSCM discharges. <br />PSCM data collection has shown that, in fact, these wetlands are currently preventing material damage <br />offsite, as evidenced by compliance with State water quality standards at sampling locations below these <br />wetlands. One of the primary benefits of the existing and proposed enhancements will to increasing the <br />treatment capacity and efficiency of the existing wetlands, consistent with PSCM's reclamation <br />obligations under the applicable CDRMS regulations, and the regulatory objectives of PSCC 2-s Colorado <br />Discharge Permitting System (CDPS) discharge permits, as administered by the WQCD. <br />An additional benefit of the proposed wetland enhancements will be to improve the overall quality and <br />function of these palustrine and riverine wetland areas. Currently, the stream channels below Ponds 002 <br />and 004 are partially incised in some areas and braided in others, likely due to years of grazing and <br />resulting streambank erosion from livestock use. This has limited surface water flow and soil moisture <br />levels in the adjacent riparian and riparian/meadow areas. As indicated by vegetation surveys for these <br />areas, the associated drainage valley areas consist of a mix of upland and wetland vegetation- with a <br />significant number of upland and facultative upland species. Implementing the proposed water diversion <br />measures will significantly increase the flow and sustained soil moisture levels in the surrounding <br />riparian and riparian/meadow areas. This will allow for denser and more diverse growth of obligate and <br />facultative wetland plants. This will also increase habitat diversity in the reclaimed areas consistent with <br />the approved postmining land use of wildlife habitat and livestock grazing. These relatively simple non - <br />intrusive enhancements have the potential (as demonstrated for the Pond 002 enhancements) to <br />significantly improve both wetland and overall ecological function and diversity. <br />Pending approval of this minor revision by CDRMS, PSCM has submitted an application for approval <br />of the proposed wetland enhancement activities under ACOE Nationwide Permit 27 (NWP 27), for <br />