2008-09-19_REVISION - C1980004 (4)

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Mr. Jim Stover, P.E. September 19, 2008 Page 4 the submittal, but could not be found in the submittal copy reviewed. Please submit a copy of the referenced emission permit application. Rule 2.05.6(2) Fish and Wildlife Plan 51. The Division requested the operator to address the concern identified by OSM regarding possible impact of proposed disturbance on the threatened Uinta Basin hookless cactus (Scler ocactus glaucus). In response, the operator submitted a brief opinion letter addendum to Table 4.3-10, prepared by Rare Earth Science, the consultant who prepared the 2006 Draft Biological Assessment for the McClave Canyon Mine permit renewal. The opinion letter supports the conclusion of the 2006 report, namely that no impact would occur to the subject cactus species, due to lack of documented occurrences within several miles of the mine and lack of suitable habitat within the area of proposed disturbance (East Salt Creek terrace with dense big sagebrush/greasewood shrubland vegetation). Item tentatively resolved; response will be forwarded to OSM for their review and consideration with respect to preparation of the biological assessment. 52. The Colorado Division of Wildlife (DOW) had previously commented on aspects of the TR-16 plan, with comments focusing primarily on water quality impacts associated with proposed waste pile and associated sediment pond discharge/leachate. CAM's most recent submittal included responses to the original DOW concerns, which DOW has reviewed and commented on in a letter dated August 19, 2008, received by the Division on August 28, 2009. DOW continues to have concerns related to potential water quality impacts of the proposed activities to East Salt Creek. A copy of DOW's August 19, 2008 review letter is enclosed. Please review and respond to the concerns identified by DOW. A meeting including appropriate CAM, DOW, and Division personnel may be helpful to resolve these concerns. Please let us know if you would like us to schedule such a meeting to assist in preparation of a response submittal that will be acceptable to DOW and the Division. Rule 2.05.6(3) Protection of the Hydrological Balance 53. through 56. Items Resolved. 57. This item is pending. Further PHC analysis and modifications to Appendix N may be required, pending resolution of Item #52 (see above) regarding DOW's initial comment letter dated January 25, 2008 and the recent letter from DOW dated August 19, 2008. 58. Item Resolved.