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<br /> <br /> <br />Peabody Sage Creek Mining, LLC <br />Peabody Sage Creek Mine <br />29515 RCR 27 <br />Oak Creek, CO 80467 <br /> <br />runoff from reclaimed mine areas; and 2) As a land reclamation and habitat enhance measure to increase <br />ecological diversity and provide additional wetland/riparian habitat, which is utilized by a wide variety <br />of wildlife species, consistent with the approved postmining land uses of wildlife habitat and livestock <br />grazing. The proposed wetland enhancement maintenance activities are consistent with those previously <br />authorized at Pond 002. Wheat straw bales will be staked within the current shallow channels and <br />distributed flow paths in wing formations perpendicular to the flow path to replace and supplement those <br />bales that have deteriorated over time. Additional willow/riparian root balls will also be selectively <br />placed to reinforce these straw bale dams. These measures will continue to force flow out of the shallow <br />channels/flow paths and into adjacent riparian and riparian/meadow areas. The straw bale wing <br />diversion structures will not create wetland impoundments, but rather will distribute flow-through <br />riparian zones enhancing palustrine emergent wetland establishment and growth in these and adjacent <br />areas. <br /> <br />Straw bales will be placed and staked by hand. Vehicles and equipment may be used selectively for <br />straw bale hauling and willow/riparian root ball placement. If equipment is used within the wetland and <br />riparian areas, its use will be minimized and operational control measures, including the use of low <br />ground pressure equipment and/or mats, may be used as appropriate to reduce impacts to soil and <br />vegetation. The proposed enhancement maintenance measures are entirely consistent with CDRMS <br />regulations which recommend “using straw dikes, riprap, check-dams, mulches, vegetative sediment <br />filters, dugout ponds, and other measures that reduce overland flow velocity, reduce runoff volume, or <br />trap sediment”. These measures will extend and support the enhancements previously established below <br />Pond 002 and will result in similar benefits through initial enhancement for the areas below Pond 004. <br /> <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. <br /> <br />One of the primary benefits of maintenance of the existing wetland enhancements for Pond 002 and <br />establishment of wetland enhancements as a postmining management measurement for Pond 004 will <br />be to maintain or increase the treatment capacity and efficiency of the existing wetlands. An additional <br />benefit of the proposed wetland enhancements will be to improve the overall quality and function of <br />these palustrine and riverine wetland areas. Currently, the stream channels below Ponds 002 and 004 <br />are partially incised in some areas and braided in others, likely due to years of grazing and resulting <br />streambank erosion from livestock use. This has limited surface water flow and soil moisture levels in <br />the adjacent riparian and riparian/meadow areas. As indicated by vegetation surveys for these areas, the <br />associated drainage valley areas consist of a mix of upland and wetl and vegetation with a significant <br />number of upland and facultative upland species. Implementing the proposed water diversion measures