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habitat. Therefore, we feel that an effort should be made to establish some smaller shrub clumps <br />(from one to three acres in size) interspersed throughout the reclaimed area. Ifseed mixes fail to <br />establish the shrubs, we recommend that an effort be made by using live stem plantings. Also, if <br />wildlife browsing proves to be a limiting factor in establishment of the shrub clumps, we <br />recommend that the clumps be temporarily fenced to allow the plants to become hardy enough to <br />withstand those pressures." Based on this recommendation, the Division does not approve BRL's <br />proposal for no woody plant density standazd. <br />A woody plant density standazd must be proposed that is acceptable to the DOW and the Division. <br />BRL may want to consider DOW's suggestion of planting shrubs in 1-3 acre concentrated clumps. <br />The woody plant density standazd could be evaluated based on the number of shrubs within the <br />approved shrub establishment areas. <br />In light of this information from the DOW, the Division intends to revise Stipulation Number 14 to <br />read: <br />AN ACCEPTABLE SHRUB PLANTING PLAN AND WOODY PLANT DENSITY <br />STANDARD MUST BE SUBMITTED BY BOWIE RESOURCES LIMITED. THE <br />PLANTING PLAN AND DENSITY STANDARD MUST BE DEVELOPED IN <br />CONSULTATION WITH THE COLORADO DIVISION OF MINERALS AND GEOLOGY <br />AND THE COLORADO DIVISION OF WILDLIFE. <br />Additionally, in the DOW letter, they requested that intermediate wheatgrass be eliminated from <br />all seed mixes. Intermediate wheatgrass should be replaced with thickspike, streambank and/or <br />slender wheatgrass in Seed mix No. 1 -Soil Stabilization. <br />Yellow clover also needs to be replaced in Seed mix No. I with any of the optional forbs in seed <br />mix 2 or 3. <br />Ground Water Hvdroloev <br />14. The Division has reviewed the discussion ojpossible contamination to the North Fork of the <br />Gunnison River by leachate from the proposed new gob pile. On page 2.05-74, monitoring wells <br />AW 1 through AW-6 are discussed (AW-1, 2, 3 installed down-gradient of the coal stockpile and <br />wells AW-4, S, 6 installed down-gradient of the old gob pile.) Additional wells will be installed to <br />monitor groundwater down-gradient of the proposed new gob pile -wells AW-I5, 16, and 17 <br />according the Map 09. Please note those new wells in the discussion, in addition to the existing <br />six wells, and comment on their purpose. The analysis ofcontamination to the North Fork <br />presented based on calculations and the data from the existing wells is acceptable, but it would be <br />appropriate to discuss the new wells and how the data from these wells will be used to monitor the <br />probable hydrologic consequences of the gob pile. <br />The response is acceptable. Page 2.05-76 was revised in the submittal dated February 11, 2004 to <br />state that three new alluvial wells will be used to monitor the new gob pile. <br />Surface Water Hvdroloev <br />15. Please provide a detail of the Ditch D-F7 crossing (Figure 2) of the Gulch D haul road culvert <br />and associated road ditches. Please add to Figure 2 the paths ofPond F discharge with design <br />