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Mr. Ross Gubka, P.E. <br />Western Fuels-Colorado <br />January 25, 2008 <br />Page 4 <br />surveys are given on page 2.04.11-36 and on page 2.05.6(2)-5 of the Fish and <br />Wildlife Plan in Volume VI of the PAP. The peregrine falcon noted on both of <br />these pages is no longer included on the Threatened and Endangered Species list <br />for Montrose County. Please review and verify that the survey includes the <br />current list of species identified for Montrose County, or have a new survey done <br />using the current list. The current and appropriate list can be found on the <br />USFWS web site at: <br />httn://www.fws.gov/mountain-prarie /endspp/CouMLists/COLORADO htm <br />Rule 3 Performance Bond Requirements <br />7. WFC has not applied for a Phase II bond release on any disturbed areas in the <br />NH2 Mine area (as discussed in the TR-54 reclamation cost estimate <br />correspondence), so the reclamation cost estimate will again include costs for <br />redistributing topsoil on all disturbed areas not yet bond released. <br />8. WFC provided a fence diagram for Cut 88 (Map 3.02.2-3) showing reclamation of <br />the final pit at a worst case scenario. This diagram shows final contours of a 50' <br />deep, 500' wide channel, which would not be approximate original contour. <br />While this may be necessary for reclamation prior to completion of the life of <br />mine plan, the Division is concerned that this would also be the case at any point <br />from Cut 88 to the end of the life of mine plan. Reclamation contours east of the <br />existing pit are up to 25' higher in elevation than premining contours, suggesting <br />that this may have contributed to the apparent deficit of material that now exists. <br />WFC needs to review the currently approved post-mining contours for the site and <br />determine if those contours can realistically be achieved. <br />9. WFC states that all structures on site will be retained permanently, asserting that <br />WFC is the landowner of the land upon which the structures reside, and that WFC <br />desires their permanent retention. WFC must also provide a complete list of all <br />structures on site (as required by Rule 2.05.3(3)), a narrative detailing continued <br />compliance with Rule 4.04, and a description of the compatibility of each <br />structure with the approved postmining land use, as required by Rule 2.05.5(1). <br />10. Revegetation and postmining land use sections of the permit are still under <br />Division review (please refer to our letter dated January 14, 2008 regarding RN-5; <br />Soils, Land Use and Revegetation Review). One proposed change that could <br />possibly affect the reclamation cost estimate relates to irrigation of dryland <br />pasture for initial establishment. The Division had expressed concern that WFC <br />was irrigating the dry pasture excessively and for too long, and recommended that <br />consideration be given to irrigation at lighter rates during the first or possibly first <br />and second growing season only, if at all. It appears that WFC has decided to <br />forego irrigation of the dryland entirely (narrative regarding the 3 years with <br />water cannon was deleted from the text in the latest version of the revision).