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.~ <br />Given the fact that over 500 acres of land have now been reclaimed at Colowyo, with <br />some revegetated stands over 15 years old, and some "shrub establishment areas" <br />over 10 years old, it would seem to be appropriate to evaluate the success or lack of <br />success of the various woody plant establishment techniques, and the degree to which <br />initial projections regarding woody plant reestablishment and impacts to key wildlife <br />species have been realized. Based upon such an evaluation, decisions could be made <br />with regard to modifying woody plant reestablishment techniques or objectives as <br />appropriate. This would seem to have been one of the primary reasons for the <br />monitoring requirement of the permit, and the absence of such data from the annual <br />reports is a serious deficiency. <br />Review of the herbaceous cover data indicates that intermediate wheatgrass is the <br />dominant plant on the reclaimed area, appearing as a principle species in almost all <br />sampled stands, and as the dominant species in most. Cicer milkvetch would appeaz <br />to be the most prominent species other than intermediate wheatgrass, with five or <br />six other native and introduced grasses appearing as principle species in the various <br />stands, but typically not as the dominant or subdominant species. A significant <br />component of cheatgrass was present in several stands less than 5 years old. Vazious <br />other annual species are common in one and two year old stands, but generally not <br />in older stands. <br />~(~~ 2. Colowyo submitted quarterly inspection reports for the Streeter Fill. The reports <br />dated 8/24/94 and 11/16/94 were not certified by a qualified professional engineer <br />as required under Rule 4.09.1(11). Please have these inspection reports certified by <br />a P.E. <br />3. Colowyo states in the permit application that all monitoring data is submitted in an <br />annual report. Rule 5.02.4(1) states that copies of all records, reports, inspection <br />materials or information obtained under the rules shall be immediately available to <br />the public at the Division office and at a convenient place in the area of mining. <br />Inspections and monitoring at the Colowyo Mine can be broken down into 5 <br />categories; fill inspections, pond inspections, )VPDES monitoring, groundwater and <br />surface water monitoring, and vegetation monitoring. <br />a. Fill inspections- Rule 4,09.1(11)(b) states that the operator shall provide the <br />to the Division a certified report 2 weeks after each inspection that the fill has <br />been constructed as specified in the design approved by the Division. Please <br />provide the Division a certified inspection report for the Streeter Fill, Section <br />16 Fill and West Pit Fill on a quarterly basis, 2 weeks after each inspection. <br />b. Pond Inspections- Rule 4.05.6(13) states that pond inspection reports shall be <br />submitted to the Division on a quarterly or annual basis, as required by the <br />Division. Pond inspection reports should be immediately available for the <br />public at the Division office as stated above in Rule 5.02.4(1). The Division <br />would like to have the reports on a quarterly basis to review the condition of <br />sediment ponds if necessary. Please submit the pond inspection reports on a <br />