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COLORADO <br />Division of Reclamation, <br />Mining and Safety <br />Department of Natural Resources <br />December 14, 2020 <br />Tony Tennyson <br />Colowyo Coal Company L.P. <br />5731 State Highway 13 <br />Meeker, CO 81641 <br />Re: Colowyo Coal Mine (Permit No. C-1981-019) <br />Technical Revision No.143 (TR-143) <br />Second Adequacy Review <br />Dear Mr. Tennyson: <br />After reviewing TR-143 from Colowyo Coal Company L.P. (Colowyo), the Division has the following additional comments <br />in conjunction with the Division's original adequacy letter dated December 4, 2020: <br />1. Section 4.15.6 Field trial. The proposed TR143 text summarizes the tall shrub/aspen test plots. Although the trial <br />had unfavorable results, The Division contends that there may be value in maintaining the details of the X-Pod <br />field trial in the permit. The previously approved Section 4.15.6 may be appropriate to retain in a historic <br />appendix. <br />2. With Colowyo proposing a New Field Trial and the plots being being fenced during the first few years, please <br />provide more detail regarding the fencing. What kind of fencing is planned? Will the fencing be designed to <br />exclude elk? Will the fencing exclude rabbit and other small herbivores? How long will the fencing be <br />maintained? What is the plan for fencing removal? <br />Colowyo states that the operator will collect native soil and inoculate test site with soil for mychorrhizae. The <br />Division wants to encourage this practice as we have observed positive results from mychorrhzae inoculation of <br />shrub seedlings at other mine sites in Colorado. Please provide detail on how mychorrhizal inoculation will occur. <br />For example, Seneca sent soil to greenhouse and the tubelings were inoculated with the soil. Will mixing soil inte <br />the replaced soil plots have the same impact? Does Colowyo have any detail on this part of the plan? <br />4. Colowyo states that weed guard will be put in place around the shrub seedlings. Will weed annuals that come up <br />in the weed guard during the first growing season when water resource is limited by the tubelings root system? <br />Additionally, will dead plantings be replaced? <br />5. In section 4.17, Colowyo had previously committed to establishing 450 acres Sagebrush steppe habitat <br />development. Has Colowyo met the 450 acres during previously approved bond releases? Was the 450 acres of <br />Sagebrush Steppe habitat a commitment required by CPW? If this commitment was previously required by CPW, <br />does CPW accept the elimination of this commitment? <br />6. Under Reclamation Success Standards, Colowyo commits to establishing wildlife habitat, of both low and high <br />density areas, on approximately 20% of the acres in each bond release evaluation. At least half of the 20% acres <br />OF COlO <br />n O <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us * <br />* <br />Jared S. Polis, Governor I Dan Gibbs, Executive Director I Virginia Brannon, Director 1876 <br />