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2008-05-28_REVISION - C1981019
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2008-05-28_REVISION - C1981019
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Last modified
8/24/2016 3:32:07 PM
Creation date
5/28/2008 1:30:07 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981019
IBM Index Class Name
REVISION
Doc Date
5/28/2008
Doc Name
Adequacy Response
From
Colowyo Coal Company
To
DRMS
Type & Sequence
TR72
Email Name
JRS
Media Type
D
Archive
No
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Fourth, given that the vast majority of sagebrush steppe targeted reclamation areas occur along <br />upper topographic circumstances, there will be large acreages of "grassland" down gradient to <br />intercept any eroded materials until the system stabilizes and reaches equilibrium. <br />In addition to the aforementioned, the implication by the state's comment is that Colowyo's <br />reclamation objective is for a "relatively low density mountain big sagebrush community ". To the <br />contrary, Colowyo 's goal is to achieve a woody plant density of approximately 1000 plants per acre <br />(largely comprised of sagebrush), to match the sagebrush density of the target sage grouse reference <br />area. However, as explained elsewhere, setting a standard at this level would be inappropriate for such <br />a short time frame as ten years. <br />Given these points it is Colowyo's position that changing the standard to 70% of the sagebrush <br />reference area will not lead to an erosionally problematic circumstance. However, Colowyo would <br />stipulate that a return to the 90% value would be uncontested if it is found that a return to 70% of the <br />reference area cover is inadequate to control erosion from slopes of 10% or less. <br />27. The weighting percentages listed on amended page 4.15-13 for the Mountain Shrub, Sagebrush, and <br />Aspen Woodland Reference Areas, with respect to acreage weighted comparisons applicable to the <br />South Taylor expansion area, appear to be incorrect. Specifically, the 25% factor for Mountain Shrub <br />and 52% factor for Sagebrush appear to be reversed; the mountain shrub community is the dominant <br />vegetation type in the South Taylor expansion area. Please revise the weighting factors as <br />appropriate. <br />Colowyo's Response: <br />Comment noted - corrections to text made as appropriate. <br />28. No rationale was provided for the proposed revision of the diversity success standard for the pre-2008 <br />grazingland reclaimed areas in amended Section 4.15.8. The current standard is: <br />• At least 4 principal species, with a minimum of 3 cool season grasses and 1 perennial forb, each <br />providing at least 3% relative cover, and; <br />• No single species provides in excess of 50% relative cover. <br />The proposed standard would be less stringent, and would require: <br />• At least 2 cool season perennial grasses with between 3% and 50% relative cover, and; <br />• Either all forbs or all shrubs combined with between 1% and 50% relative cover. <br />Under the proposed standard, adequate diversity could be demonstrated by as few as two grasses <br />providing a combined 99% relative cover and one or more forbs providing a combined 1% relative <br />cover. Please provide the rationale for the proposed change to the previously approved diversity <br />standard (or retain the original standard). Please also provide a rationale for the differing <br />standards proposed for the three reclamation categories (pre-2008 grazingland, post-2008 <br />grazingland, and post-2008 wildlife habitat). <br />Colowyo's Response:
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