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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
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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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acreage exhibiting slopes 10% or flatter; 2) elimination of all small, isolated, or impractical <br />areas for targeting this community; 3) implementing "banding" (alternating strips of <br />grassland versus shrubland) procedures on large units with long slopes that might otherwise <br />lead to excessive "snowmelt" erosion; and 4) assuming 50% shrub establishment success (i.e. <br />sufficient density) on the acreage that actually receives shrub conducive metrics. Please refer <br />to Map 44 for a visual representation of areas that are < 10% slope at Colowyo Mine <br />according to the current PMT surface. <br />Critical to the adoption of this approach is the need for Colowyo to be allowed to deviate <br />from the plan in instances where plan maps or specifications do not reflect "on-the-ground" <br />reality, and to the contrary, when opportunities for adding unplanned supplementary areas <br />targeting shrub establishment present themselves. By acceptance of this new approach, <br />Colowyo will be granted the flexibility to take advantage of day-to-day opportunities to <br />promote shrub establishment and be able to option out of planned areas if site conditions <br />prove significantly different than anticipated. Such flexibility will in no way be allowed to <br />circumvent the requirement to maintain a proper life-of-mine topsoil balance and overall plan <br />objective to improve shrub establishment. All significant deviations from plan maps and <br />expectations will be documented and submitted in the Annual Reclamation Report. In this <br />manner, as well as documentation through bond release evaluations, CDRMS will maintain <br />authority over any such deviations. <br />Related to this flexibility and as presented in revisions to Section 4.15, Colowyo commits to <br />revised woody plant density success criteria for Phase III bond release for 2008 and later <br />reclamation, that are somewhat less stringent than the original requirements, and are <br />significantly less stringent for pre-2008 reclamation, but are ecologically defensible and <br />appropriate. This commitment is in the interest of promoting the momentum of the bond <br />release process and the pursuit of a "land-use" based reclamation program. Furthermore, this <br />commitment on the part of Colowyo is based on the fact that the best reclamation science <br />(30+ years ago), and significant financial expenditure went into implementation of the <br />previous reclamation plan (and development of success criteria), and that recent experience <br />and advancements in reclamation science now dictate less stringent requirements for a 10- <br />year bond responsibility period. In other words, the original woody plant density success <br />criterion was developed without sufficient experience, knowledge, or empirical evidence and <br />as such was established at too high a level over too short a time period. In effect, this will <br />amount to the waiving of the previous standards and the adoption of the new proposed <br />standards. <br />2.05-45 Revision Date: 3/14/08 <br />Revision No.: TR-72
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