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2009-04-27_REVISION - C1981019
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2009-04-27_REVISION - C1981019
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Last modified
8/24/2016 3:45:54 PM
Creation date
4/28/2009 11:08:05 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981019
IBM Index Class Name
REVISION
Doc Date
4/27/2009
Doc Name
Response to 3rd Adequacy Review
From
DRMS
To
Colowyo Coal Company
Type & Sequence
TR72
Email Name
JRS
Media Type
D
Archive
No
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22. Item Resolved in first adequacy review. <br />Rule 4.15 Revegetation Performance Standards <br />23. The Division requested that the first sentence of amended page 4.15-3 be <br />amended to clarify that the post-2008 seedmixes were limited to native species <br />"with limited and specified exceptions". The sentence was properly amended. <br />Item Resolved. <br />24. Colowyo has amended the text on pages 2.05-61 and 4.15-3 as requested. While <br />there is still some leeway in the plan, as written, the Division understands the <br />need for flexibility in such a plan. The Division considers this Item Resolved. <br />25. Item Resolved in first adequacy review. <br />26. In the 26 June 2008 letter, the Division requested narrative clarification regarding <br />the distinction between "evolved" and "targeted" sagebrush steppe, with respect <br />to applicable cover and production standards and success demonstration specifics. <br />The requested information was provided and the amended narrative on pages <br />4.15-15 through 4.15-17 is acceptable, with one exception. On amended page <br />4.15-17, under Herbaceous Production, the revised language indicates that post- <br />2008 sagebrush steppe revegetation areas would not be subject to herbaceous <br />production success criteria. This change was made based on anticipated state rule <br />changes that have not yet been finalized or submitted for approval. The change to <br />eliminate the production standard cannot be approved in the permit until the <br />pertinent rule change is approved. <br />Please revise the narrative section regarding herbaceous production criteria <br />for post-2008 sagebrush steppe revegetation to comply with current <br />regulations. <br />Colowyo's Response: <br />Colowyo has amended the text as requested. In addition, Colowyo has added a <br />statement that should the state rule allow for elimination of the Herbaceous <br />Production success criteria in the near fixture as expected, the pertinent criteria <br />will be dropped at the time the state rule becomes effective. <br />27. Item Resolved in first adequacy review. <br />28. Item Resolved in first adequacy review. <br />29. In the June 2008 letter, the Division requested revision of the diversity criteria for <br />wildlife habitat to specify the minimum relative cover component to be <br />represented by native* perennial forbs. The section was amended to address our <br />concern, but it appears that the proposed standard could be still be interpreted to
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