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Completeness Review <br />Colowyo PR-3 Collum Expansion <br />February 4, 2009 <br />Page 3 of 4 <br />the existing permit area are currently under review by the Division. Many of the <br />concepts under review in TR-72 may be applicable for the Collum area, but the <br />Collura revegetation success criteria must be site specific, and be based upon the <br />pre-mining land-uses, soil surveys, vegetation characteristics and wildlife usage <br />within the Collum expansion area. <br />Wildlife - Rules 2.04.11, 2.05.6(2) and 4.18 <br />2.04.11 Fish and Wildlife Resources Information <br />Complete. In this section Colowyo did include discussions and data from the <br />Collum expansion area and made appropriate reference to Exhibit 11. <br />2.05.6(2) Mitigation of the Impacts of Mining Operations, Fish and Wildlife Plan <br />This section is incomplete. Colowyo references Volume 1 which does not include <br />consideration of the Collum expansion area. Colowyo must address Rule <br />2.05.6(2), Mitigation of the Impacts of Mining Operations, Fish and Wildlife <br />Plan, using the wildlife resources information provided for the Collum expansion <br />area in Section 2.04.11 and Exhibit 11 of the PR-3 application. <br />4.17 Protection of Fish, Wildlife and Related Environmental Values <br />This section is incomplete. Colowyo references pending TR-72 which is based on <br />the existing permit boundary; the Collum expansion area is not considered in TR- <br />72. The specifics of 4.18(5) (d) and (i) subsections (i) and (ii) are site specific and <br />must be included in this section and considered in the reclamation plan for the <br />Collum expansion area. <br />General Comment <br />In several places throughout the PR-3 application Colowyo refers to the pending approval of TR- <br />72. TR-72 was submitted in response to Stipulation No. 8 attached to Permit Revision No. 2 for <br />the existing and contiguous disturbance in South Taylor Creek at the Colowyo Mine. <br />Stipulation No. 8 <br />The Colowyo Coal Company Shall submit a Technical Revision to the Division <br />containing a comprehensive reclamation plan for the East Pit, West Pit, Section <br />16 Pit, South Taylor Pit, facilities area, Gossard Loadout and all remaining <br />disturbances at the Colowyo Mine. The revision will eliminate outdated methods <br />of reclamation that are currently used at the Colowyo Mine. Further, the revision <br />will address Division concerns regarding revegetation, soils handling and species <br />diversity success standards, etc. to meet the current post-mining land-use. <br />Consultation with the Division, the Colorado Division of Wildlife, the Bureau of <br />Land Management and other appropriate agencies will be necessary. <br />I think it is important to note that many of the proposed concepts for topsoil replacement, <br />location of sagebrush steppe, and revegetation success standards in TR-72 are good proposals.