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2008-05-28_REVISION - C1981019 (2)
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2008-05-28_REVISION - C1981019 (2)
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Last modified
8/24/2016 3:32:07 PM
Creation date
5/29/2008 1:36:58 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
27 May 2008 TR-72 Responses and Response Letter (Rule 2 Reclamation Plan 2.05.4)
From
Colowyo Coal Company
To
DRMS
Type & Sequence
TR72
Email Name
JRS
Media Type
D
Archive
No
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The introduced taxon that is included in the seed mixtures above, (Cicer milkvetch), has been <br />retained in the mix to provide forage for both wildlife (elk and sage grouse) and livestock. <br />Furthermore, Cicer milkvetch is an excellent species for providing necessary habitat <br />requisites for a variety of insects that in turn are especially important to sage grouse broods. <br />It is a well-documented observation that insects comprise a very significant portion of young <br />sage grouse diets. <br />Similarly, the introduced species, small burnett, has been retained in the contingency species <br />list (Table 2.05.8) owing to its well documented value to wildlife. <br />Data on reclaimed areas at Colowyo, has indicated that orchard grass is an important grass <br />species for controlling erosion and providing cover the first growing season, while decreasing <br />subsequent growing seasons. Orchard grass comprised 0.13 plants per square foot the first <br />growing season, while decreasing to less than 0.02 plants per square foot the second growing <br />season. This indicates the effectiveness of orchard grass to provide erosion control early on <br />revegetated areas, while not sustaining this vigor in later years due to increased competition <br />and crowding by other species as well as targeted selection by elk (i.e. it has been repeatedly <br />observed in Colowyo reclamation, that orchard grass plants have been selectively consumed <br />by resident elk, and therefore, can be considered highly desirable forage). <br />Also, data from Exhibit 10 indicates that Kentucky bluegrass is the most important grass <br />species contributing to the pre-mine vegetative diversity. <br />Given the aforementioned, it must be accepted that there is a place for certain introduced <br />species in Colowyo reclamation. In 2008 and thereafter, occasional use of introduced species <br />may occur, but will be limited (as indicated in the seed mixes) to specific circumstances. The <br />only circumstances where limited use of introduced species will not be followed are instances <br />where a unit of land is designed to target a post-mine land use of "pastureland" or a unique <br />area is highly susceptible to erosion. Use of the more aggressive taxa: smooth brome, <br />intermediate wheatgrass, and pubescent wheatgrass will be avoided, with the possible <br />exception of "pastureland" development should such a land use be targeted at some future <br />point of time. Prior to such land use designation or use of aggressive taxa to combat areas <br />that are highly susceptible to erosion, an MR or TR (as appropriate) will be obtained from <br />CDRMS to address such circumstances. <br />For the areas to be disturbed by mining, a timetable for reclamation has been established in <br />order to allow for proper scheduling of reclamation activities. The acres to be reclaimed are <br />shown in Section 2.03 on Table 1, Affected Areas for Mining and Reclamation. The <br />revegetation will be conducted during the first normal planting season following the <br />application of topsoil and preparation of the site for seeding. The most favorable times for <br />seeding in this area are in the early spring and late fall. Spring seeding is usually severely <br />limited by high soil moisture conditions, which prohibit the use of seeding and seedbed <br />preparation equipment at a time when conditions are best for germination and seedling <br />establishment. For this reason seeding will be done during late fall months immediately prior <br />to the average occurrence of the first significant snowfall event when the conditions for <br />seeding are optimal. A modest amount of broadcast seeding may occur at other times <br />including early spring, as detailed under Planting and Seeding Methods in this Section, but <br />typically only for small "mop-up" circumstances. <br />Given the significant and nearly ubiquitous past failures regarding the establishment of <br />2.05-56 Revision Date: 3/14/08 <br />Revision No.: TR-72
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