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REV96722
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REV96722
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Entry Properties
Last modified
8/25/2016 3:21:18 AM
Creation date
11/22/2007 12:02:44 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1996083
IBM Index Class Name
Revision
Doc Date
3/15/2004
Doc Name
Comment Letter
From
DMG
To
Bowie Resources Limited
Type & Sequence
TR30
Media Type
D
Archive
No
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that the existing gob pile haul road drains northward into ditch D-F2, rather than southward onto <br />topsoil stockpile "D". Please revise the appropriate figures to show revised sediment control for <br />topsoil stockpiles "D" and "E". <br />Ve eg tation <br />12. BRL identified two vegetation communities associated with the WRDA proposed disturbance - a <br />mixed shrubland and a juniper woodland. Both community types were quantitatively sampled for <br />cover and production. BRL has pre-established reference areas for both of these vegetation types <br />that were also sampled in July 2003. Rule 4.15.7(3) requires the permittee to demonstrate <br />statistically that each proposed reference area is comparable to its equivalent area to be disturbed <br />in terms of vegetative cover and herbaceous productivity. BRL has not provided a statistical <br />comparison. <br />Based on the narrative on page 14, the mixed shrubland reference area is not representative of <br />the area to be disturbed. The mixed shrubland in the WRDA has 38% plant cover. The WRDA <br />disturbed area is described as a south facing slope in an area that has been heavily grazed in the <br />past. The mixed shrubland reference area has 54% percent plant cover, 26% higher than the area <br />to be disturbed. BRL has proposed reducing the reclamation standard for the WRDA by 50%. As <br />stated above, Rule 4.15.7(3) requires the permittee to demonstrate statistically that each proposed <br />reference area is comparable to its equivalent area to be disturbed. The Division does not agree <br />with a fifty percent reduction for the standard. <br />There are some alternatives BRL may want to consider. First, BRL can commit to the higher <br />mixed shrubland reference area standard. Second, BRL has hvo methods by which reference <br />areas may be utilized as described in Rule 4.15.7(4). BRL may want to evaluate using a weighted <br />acreage comparison. Rule 4.15.7(4)(6) states that, "a single comparison would be made between <br />all reference areas and the entire revegetated area and would be based on the relative area <br />occupied by each plant community in the premising surface ". If this method is selected the <br />disturbed area acreage by community type would need to be detailed. Lastly, BRL could select <br />another well-managed mixed shrubland reference area with a southern exposure at a lower <br />elevation. <br />Response accepted. In the submittal dated February 11, 2004, pages 14 and 15 of the baseline <br />vegetation report were revised to use the weighted average compazison. <br />13. Woody plant density standards have been proposed but concurrence by the Colorado Division of <br />Wildlife is necessary before it can be considered final. Stipulation number 14 remains <br />outstanding. BOWIE RESOURCES MUST SUBMIT VERIFICATION TO THE DIVISIONTHAT <br />THE COLORADO DIVISION OF WILDLIFE CONCURS WITH THE PROPOSED PLAN <br />CONCERNING THE WOODY PLANT STEM DENSll'Y STANDARD FOR THOSE AREAS TO <br />BE RECLAIMED.4T THE BOWIE NO. 2 MINE. <br />What progress has BRL made in addressing this stipulation? <br />BRL submitted a letter frcm the Colorado Division of Wildlife (DOW) dated May 15, 2002. The <br />DOW does not recommend that the woody plant density standazd be reduced to zero. The first <br />paragraph of the letter states: "..the shrub component ir: this area is a very important part of the <br />4 <br />
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