2010-12-17_REVISION - C1981019 (160)

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• Land Use Key to the development of'a successful (bond releasabie) reclamation plan is a carefully designated pre- mining land use that will likely become the target post-mining land use: The current operatio n,exsts on a "rangeland" land use and I believe that the CDMG rangeland definition accurately. reflects the Collom area as well. However, there are two main sub=components to this use: '1.) .livestock grazing and 2) wildlife habitat. Neither of these are new concepts to coalmining in the West. The difficulty arises in that historically, most professionals involved in the permitting process tend to treat these "sub-components" of the "rangeland" land use as individual and separate land uses of "pastureland" and "wildlife habitat". The subtleties of differentiation will become very important when CDOW is requested.by CDMG to offer their input with regard to the look of final reclamation. The new regulations no longer seek only "consultation" with CDOW, but "approval" for areas with a wildlife postmining land use [4.15.8M1. Hence, it is extremely important for us in the permit to carefully describe the pre-mining land uses (and sub- components), the target post-mining land uses (and sub-components), and to justify the differences to keep the agencies, especially CDOW, in line with regulatory guidance. The importance arises because the revegetation communities that we design in the reclamation plan must necessarily and successfully target these uses, but must not do so at excessive cost, or risk of failure during success testing. I have discussed with Tay, and he concurs, that we do not want to offer the types of vegetation communities (shrublands) that target the sub-component of wildlife habitat on more than 20% of the reclaimed surface. (On the other side, it would be prudent to not offer less than 10%.) This would leave 80% for the community that targets livestock grazing (grasslands). Rationale being that standard reclamation practices (and modest costs) can be readily applied to achieve the livestock grazing sub- component on 80% of the surface. However, to specifically target the shrubland communities and hence wildlife habitats on the remaining 1.0% to 20% will require special reclamation techniques (specific soil handling and profile construction) that likely will involve some extra cost. This does not mean that we will not attempt to establish shrub populations using various inexpensive seeding methods within the livestock grazing-lands, however, grasslands should be emphasized in these areas to preclude erosion. It would strengthen our arguments if we could develop justification for this 80/20 land use sub-component split that is based on current uses of the land, however, defensibility of any such rationale may be difficult. Any ideas out there would be welcome. A couple of ideas that I've had would be to split the "rangeland" land use between these two sub-components based on AUMs of use by the larger wild ungulates versus sheep and cattle. However, this could be a very difficult task and it may result in a much higher wildlife habitat component than we.desire. Furthermore, it largely ignores sage grouse, which is the wildlife taxon of greatest importance to CDOW. A more practical justification is based on the physical limitations of the reclaimed surface given modern reclamation techniques. In other words, we would only, have about 10% to 20% of the area that offers the right physical environment conducive to the development of vegetation communities targeting desired wildlife habitats without elevating adverse impacts such as CEDAR (CREMNASSOCTATES, INC. Page 49 2005 Collom Vegetation Survey