2008-04-14_REVISION - C1981019 - Laserfiche WebLink

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~;~ ` STATE OF COLORADO Bill Ritter, Jr., Governor DEPARTMENT OF NATURAL RESOURCES DIVISION OF WILDLIFE AN EQUAL OPPORTUNITY EMPLOYER Thomas E. Remington, Director 6060 Broadway Denver, Colorado 80216 Telephone: (303) 297-1192 wildlife. state. co. us ~~eEw~D ~°v°~t'o ~r°~'of~v4 For Wildlafe- ForPeople ~~'+~ 14 2008 March 7, 2008 . ,~ ....~~amation, Colorado Division of Reclamation, Mining, and Safety hA~nmg and Safety Mr. James R. Stark, Environmental Protection Specialist 1313 Sherman Street, Room 215 Denver, CO 80203 Re: CDOW Comments on the Proposed Revised Reclamation Plan for Colowyo Coal Mine (Permit No. C- 1981-019), Revision Application No. 72 (TR-72) Dear Mr. Stark: The Colorado Division of Wildlife (CDOW) is sending this letter in response to your notice of Colowyo Coal Mine's (Mine) request to revise their reclamation plan. The CDOW provides the following comments for consideration related to the revision application. Overall, CDOW believes the revised reclamation plan is a positive step intended to improve newly reclaimed areas in the southern portion of the Mine permit and may serve as a "test plot" for future Mine reclamation should activity expand to the Collum Drainage. The Mine has already demonstrated an ability to establish ground cover for soil erosion and livestock grazing during previous reclamation efforts. These already established sites have also proven to have obvious benefits to some species of wildlife in the form of cover and forage. As we have previously discussed, the chief component still lacking on existing reclamation is a substantial shrub component. Generally speaking, the lack of this shrub component and, to some degree, a strong herbaceous component has resulted in a grassland monoculture. This lack of overall plant diversity is not as beneficial to most wildlife populations. After reviewing the revised reclamation plan, CDOW believes Colowyo is making good use of previously collected site specific data, along with sound plant science based decisions, to improve future reclamation efforts. Specifically, CDOW supports the Mine's plans to re-create surface relief which provides improved cover and diversity for wildlife. Additionally, CDOW supports the Mine's plans to create highly variable topsoil depths in an effort to create better growing conditions for shrub communities. Furthermore, CDOW believes the concept of creating "natural snow fences" out of topsoil berms has merit and should improve soil moisture and browsing protection for shrubs. Finally, after review of the Mine's proposed seed mix for both the proposed "Grazing Land" and "Wildlife Habitat" sites, CDOW believes the mix provides a good deal of diversity of herbaceous and. shrub species. This increase in diversity, especially the forb component, should increase benefits to sage grouse and Columbian sharp-tailed grouse broods. CDOW would like to take this opportunity to make the following recommendations to the proposed reclamation plan. First, CDOW has some concerns about the actual percentage of acreage currently allocated to sagebrush steppe (wildlife favorable habitats) versus that percentage allocated to grassland. The proposed plan discusses general allocations as 60-80% grassland and 20-40% sagebrush steppe. Furthermore, the plan describes a goal of achieving sagebrush steppe on at least one-half of the proposed acreage. That equates to a possibility of only reclaiming a total of 10% of the entire site to sagebrush steppe. CDOW recommends the Mine set a shrub DEPARTMENT OF NATURAL RESOURCES, Hams D. Sherman, Executive Director WILDLIFE COMMISSION, Tom Burke, Chair • Claire O'Neal, Vice Chair • Robert Bray, Secretary Members, Dennis Buechler • Brad Coors • Jeffrey Crawford • Tim Glenn • Roy McAnally • Richard Ray Ex Officio Members, Hams Sherman and John Stulp