2020-06-25_REVISION - C1981019 (6)

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RULE 2 PERMITS efforts,the effect on local deer and elk herds has proven minimal. There has been no evidence that any of the wildlife populations have been adversely affected by the mining activity. None of the species has shown signs of altering seasonal use patterns or in any way avoiding the mining operations. Observations during the last five years at Colowyo confirmed by similar observations at several other mines in northwest Colorado tend to contradict earlier expected impacts on wildlife. This is especially true during the fall months when hunting puts pressures on the local elk and deer herds. The Colowyo permit area has proven to be more of a wildlife preserve. Where elk and deer number in the hundreds adjacent to the mining operations as they feed and rest undisturbed. Elk and deer are routinely observed foraging on the now extensive reclaimed areas as well. It is well accepted in northwest Colorado that extensive acres of reclaimed grasslands on reclaimed mined lands and CRP cropland serve as "magnets" for elk and deer populations. During the spring greenup of grasses and forbs these reclaimed areas are also providing valuable spring rangeland for the local wintering deer and elk herds. It is not uncommon to see hundreds of elk and deer grazing on the Colowyo reclamation areas early in the spring while snow is still covering adjacent native rangelands. In summary, the preponderance of evidence provides little doubt that activities associated with the Colowyo mine have in fact proven beneficial to local wildlife populations rather than a detriment. 2.04.12 Prime Farmland Investigation In order to determine the presence of potential prime farmlands within the permit area, a reconnaissance inspection was conducted to determine if any prime farmland was present in those areas to be disturbed by surface operations or facilities. Results of the investigation indicate that all of the area to be disturbed by surface operations or facilities can be excluded as prime farmland, since the land has not historically been used as cropland. This conclusion is based upon consultation with the local Soil Conservation Service(SCS).Based also on soil-survey information supplied by the Soil Conservation Service, no soil series encountered on the area have been designated as soil mapping units applicable as prime farmland. This conclusion is confirmed by correspondence from Mr. William Lee Hill, the USDA Soil Conservationist for Moffat County, to Colowyo, enclosed as Exhibit 9, Soils information as a December 18, 1980 letter from Mr. William Lee Hill of SCS to Colowyo. The letter states that "No lands in Moffat County have been designated as prime farmland." Based upon the soil survey conducted by the U.S. Soil Conservation Service and subsequent interpretation of that survey by the SCS, Colowyo is hereby requesting a negative determination for prime farmland. 2.04.13 Annual Reclamation and Hydrology Report By March 15 of each year, Colowyo will file an annual reclamation and hydrology report covering the previous calendar year (January 1 through December 31) for all areas under bond. The report will include text, discussion and maps to address the following: Rule 2 Permits 2.04-70 Revision Date: 6/22/20 Revision No.: MR-220