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• approval due to geotechnical investigation required. Therefore, this response is inadequate <br />at this time. <br />Rule 4.14 Backfilling and Grading <br />184. No change in scale allowing for overlay was evident. Furthermore, the PMT map depicts <br />no terracing but cross sections do. This response is inadequate. <br />185. This response is also inadequate. Please refer to the original question. <br />Rule 4.15 Revegetation <br />Under this section, all responses were found adequate except as listed below. <br />186. Lorencito Coal Company considers that no additional measures aze necessary to assure <br />protection of the grassland extended reference azea. Lorencito Coal Company will need <br />to be awaze that any new disturbances that would be proposed in the Lorencito Canyon <br />grassland azea may be assessed with respect to Rules 4.15.7(3)(c) and (d). Unless <br />statistical compazison aze made of grassland communities in Cow Canyon, Puertecito <br />Canyon, Bonita Canyon , Alamosa Canyon, or any other grassland areas outside of the <br />defined Lorencito Canyon, these aeeas aze not available for use as extended reference <br />• aeeas. No additional response is necessary from Lorencito Coal Company at this time. <br />190. Lorencito Coal Company revised the technical success standard for woody stem density <br />in the oak pinyon vegetation type from 1000 stems/acre to 500 stems acre. Lorencito <br />Coal Company has provided no explanation of the rationale for this proposed reduction, <br />nor have they provide an explanation of how the proposed standazd will comply with Rule <br />4.15.7(2). The surface mine azea has been proposed to be revegetated to a grassland <br />community and would not have a woody stem revegetation requirement. Other proposed <br />disturbance aeeas that would fall into the oak/pinyon vegetation communities would be <br />primazily limited to roads and the underground portal aeeas. Due to the limited areal <br />extent of these proposed disturbances in the oak pinyon community, the Division is not <br />categorically opposed to this reduction, however the only means of re-establishing shrubs <br />that Lorencito Coal Company has proposed is by inclusion of shrub seed in the seed mix. <br />The Division, through past experience, has observed limited success of shrub <br />establishment via inclusion of shrub seed in a grass/forb seed mix. The Division <br />continues to question the potential shrub re-establishment success possible at the Lorencito <br />Mine without implementation of additional establishment measures. <br />As the oak pinyon reclaimed communities will have rangeland/wildlife asthe post-mining <br />land use, the Division questions whether the Colorado Division of Wildlife is in <br />agreement with the proposed reduction. <br />• <br />