Laserfiche WebLink
Response: It is Colowyo's understanding that the approved standard of 1,000 stems/acre and <br />achievements on already existing reclamation will be re-evaluated in the technical revision <br />submitted in response to Stipulation 8 from the Permid Revision 02. As stated in the <br />September 24 meeting, Colowyo will be seeking approval to proceed with Phase III Bond <br />Release on reclamation areas greater than ten years old and that meet the other criteria for <br />release with the exception of the 1, 000 stems/acre standard. All parties in attendance were <br />not interested in redisturbing established tracts of reclamation for the sake of further <br />attempts to meet the shrub density standard after the substantial efforts undertaken to date <br />have not yielded success in this respect. Furthermore it was agreed that exposing reclaimed <br />areas to new disturbance would likely invite cheatgrass infestation and reduce the current <br />wildlife habitat value and potential future livestock grazing opportunities. The new Phase <br />III Bond Release criteria developed for the remaining unreclaimed areas of Colowyo Mine, <br />including the future planned disturbance areas associated with the development of the South <br />Taylor Pit are planned to take effect for areas seeded during the 2008 reclamation season <br />and beyond unless unforseen circumstances delay the approval of the upcoming reclamation <br />plan submittal and revised Phase 117 Bond Release Criteria. Colowyo will be seeking <br />reduced shrub density standard criteria comprised of a regulatory threshold which will be <br />how the Division will determine eligibility for Phase III Bond Release. In addition, Calowyo <br />will plan, manage and strive to attain a higher level of shrub density as anon-binding <br />component of the revised Phase Ili Bond Release Criteria as a good faith commitment to <br />outperform the threshold standard and help to ensure full release in a timely manner. <br />Additionally, please see response to comment g. <br />6. The Division received a comment letter from the Division of Water Resources dated <br />14 May 2007. The letter is attached for your review. Since the application for Permit <br />Renewal OS does not include any additional mining or disturbance, the DWR does not have <br />any objections to the renewal. <br />Response: No response required. <br />7. The Division received a comment letter from the Colorado Historical Society dated <br />18 May 2007. The letter is attached for your review. Since the application for Permit <br />Renewal OS does not include any additional mining or disturbance, the CHS does not have <br />any objections to the renewal. In the letter, however, CHS reiterates the requirement to stop <br />work if any azchaeological resources are discovered until they can be evaluated in terms of <br />the National Register of Historic Places eligibility criteria, in consultation with the CHS. <br />Response: No response required <br />8. The Division would like Colowyo to include a map of the azeas that have been <br />backfilled and rough graded and the years this was accomplished and a map of the areas that <br />have been topsoiled and the years this has been accomplished in the Annual Reclamation <br />Report. <br />Response: Colowyo currently includes topsoiled and seeded acres on the Annual Map contained in the <br />Annual Reclamation Report. Colowyo believes that the Division has sufficient information <br />on backfilled and rough graded areas through monthly CDRMS inspections to be able to <br />