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Revegetation [(2.05.4(2)(e) and 4.151 <br />In Items 5 through 18 below, the Division identifies a number of concerns with specific sections of Rule 2 <br />application narrative. Portions of Rule 4 application narrative will likely need to be updated to correspond to <br />amended Rule 2 narrative sections, in the response submittal to this adequacy review. The Division has <br />identified additional adequacy concerns specific to Section 4.15 amended sections in Items 23 through 30. <br />Supplemental Introduction in amended Section 2.05.4 <br />5. The Division concurs that the wildlife habitat/sagebrush steppe enhancement efforts should be focused <br />primarily on the more gentle terrain, estimated to comprise approximately 20% to 40% of the post-2008 <br />reclaimed landscape. However, the Division believes that the woody plant density standards proposed, <br />and the acreage to which such standards would apply, are too low. This determination is based on <br />consideration of the large acreage of relatively low diversity grassland habitat that has been established <br />at Colowyo in the past, and the understanding that wildlife habitat would be strongly emphasized in the <br />remaining areas of the original permit and the South Taylor expansion. With use of the amended <br />seedmixes, it is expected that a modest sagebrush/snowberry component would become established <br />within the grassland/erosion control targeted slopes, as typically is the case with use of similar native <br />dominated seedmixes at other mines in northwest Colorado. Use of the "banded seeding approach" with <br />occasional strips of the "Sagebrush Steppe" mix included within larger patches of the "Grassland" mix <br />could be utilized to enhance diversity and woody plant establishment on the slopes, without significantly <br />increasing erosion potential, if warranted. <br />Based on the plan presented, consideration of results that could reasonably be expected, and following <br />discussion with Jon Wangnild of CDOW, the Division requests the woody plant density standard for <br />post-2007 reclaimed areas at Colowyo be stated as follows: <br />• A standard of at least 500 live woody plant stems per acre and at least 250 live big sagebrush <br />plants per acre will apply on "Sagebrush Steppe/Wildlife Habitat Targeted Areas". "Sagebrush <br />Steppe/Wildlife Habitat Targeted Areas" will comprise a minimum 20% of the acreage of post- <br />2008 reclamation. <br />• A standard of at least 150 live woody plant stems per acre will be apply on "Grassland" targeted <br />areas of the post-2008 reclamation. <br />• A standard of at least 250 live woody plant stems per acre will apply on at least 3% of the pre- <br />2008 reclaimed surface. <br />Please revise all appropriate sections of the narrative within revised sections 2.05.4 and 4.15 to <br />incorporate the above stated woody plant density standard commitments. <br />Colowyo's Response: <br />First, Colowyo does not believe that "compensation "for previous Division approved procedures <br />that have largely failed should be part of the new program that is designed to target specific land uses in <br />the post-mining reclamation. This new reclamation should be goal driven and should target specific <br />land uses without regard to "compensation "for past efforts. Furthermore, these new procedures must <br />still be proven and care must be taken to set mandatory success criteria at minimally acceptable and