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2008-06-26_REVISION - C1981019
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2008-06-26_REVISION - C1981019
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Last modified
8/24/2016 3:33:35 PM
Creation date
6/26/2008 3:21:41 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981019
IBM Index Class Name
REVISION
Doc Date
6/26/2008
Doc Name
2nd Adequacy Review
From
DRMS
To
Colowyo Coal Company
Type & Sequence
TR72
Email Name
JRS
Media Type
D
Archive
No
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saltbush will not be counted toward the woody plant density success <br />standard. <br />11. The Division requested deletion or modification of misleading paragraphs on page <br />2.05-56. The paragraphs were properly deleted. Item Resolved. <br />12. The Division requested corrections to the text on page 2.05-56, to clarify that use <br />of introduced species would be subject to submittal and approval of an <br />appropriate revision to the reclamation plan. Item Resolved. <br />13. Aspen and tall shrub communities provide important wildlife habitat functions, <br />even when present as small patches within a landscape dominated by grassland or <br />sagebrush steppe. Given the potential for reestablishment of these components <br />indicated by previous small scale plantings, and in consideration of the significant <br />acreage of these community types that has been disturbed by Colowyo, and may <br />be disturbed by future operations in the Danforth Hills, the Division believes it is <br />important for Colowyo to include plans for a limited number of aspen and tall <br />shrub establishment areas in appropriate site locations. <br />Colowyo's response to this concern is, in essence, that due to limited past success, <br />and due to the difficulty and expense involved, they will not attempt to establish <br />even a limited number/acreage of tall shrub or aspen stands. They also argue that <br />establishment of small pockets of mountain shrub habitat would be of minimal <br />benefit to big game populations, and that expanses of grassland would be of <br />higher benefit. Colowyo does not address the benefits of pockets of aspen or <br />mountain shrub habitat to wildlife species other than big game, the benefits of <br />establishing small pockets of these community types to allow for future spread, or <br />the value of continuing efforts on the part of mining companies to develop <br />approaches for reestablishment of these community types when they are impacted <br />by mining. Unless DOW indicates agreement with Colowyo, that replacement of <br />a limited number of aspen and tall shrub establishment areas in appropriate site <br />locations would not benefit the wildlife habitat postmining land use, the Division <br />stands by its original request. <br />Please revise the reclamation plan as appropriate to address this concern. <br />14. The Division had requested a commitment and detailed plans for provision of at <br />least one elk fenced sagebrush/bitter brush seeding area, one or more fenced <br />"rocky soil" mountain shrub planting areas, and two or more fenced "thick <br />topsoil" aspen/tall shrub planting areas, within appropriate locations in the post- <br />2008 wildlife habitat emphasis areas. <br />Colowyo's response was that elk fencing would be used if necessary to meet <br />woody plant success standards, but no specific plans or commitments were <br />provided. The response is adequate if sagebrush steppe is the only community <br />type to be established in the wildlife habitat postmining land use areas. If further
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