2009-08-31_APPLICATION CORRESPONDENCE - C2009087

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During a meeting with CDOW staff and Peabody's Environmental Manager Jerry Nettleton and Environmental Specialist Scott Cowman (July 31, 2009), the need for ventilation shafts was discussed. Currently these shafts are not part of the permit application, but will be a necessary component of the subsurface mine. Statements by Mr. Nettleton indicated that the ventilation shafts will be located west of Routt County Road 27. These shafts could have an impact on grouse leks in the immediate area and could impact hunting opportunity on the two State Trust Lands listed above depending on site location. It was stated that the location of the ventilation shaft(s) would hopefully be sited near existing roadways to minimize any additional disturbance. State Trust Lands / Noftsteger, Noftsteger Zeigler, Pecoco and Wadge Ponds/Mitigation Two areas of concern from the mining operation on the Twenty Mile State Trust Lands will be the possible need to drain the Noftsteger and Noftsteger Zeigler reservoirs. These are currently stocked by the CDOW with trout and provide some locally important fishing opportunities for Hayden and. the surrounding community. Hunting of pronghorn, elk and Columbian sharp-tailed grouse are also of importance on the Twenty Mile and Grassy Creek State Trust Lands. The hunting opportunities would only be impacted by the location of ventilation shafts and any new access roads not currently in place and with an associated increase in traffic. Mitigation of mining impacts should include the following: • Minimize activities and operations within 300 feet of the ordinary high water mark of any reservoir, lake, wetland, or natural perennial or seasonally flowing stream or river. • Restore both form and function of impacted wetlands and riparian areas and mitigate erosion. • Remove or otherwise dispose of road surface materials that are incompatible with post- production land use and re-vegetation requirements. • Do not remove native riparian canopy or stream bank vegetation where possible. • Schedule construction, and completion activities to avoid nesting sandhill cranes and brood rearing of Columbian sharp-tailed grouse. • Vent shaft construction activities should be scheduled to avoid seasons and locations when public use of lands is at its highest (e.g., big game hunting seasons). • Install exclusionary devices to prevent bird and other wildlife access to equipment stacks, vents and openings. • Reduce noise by using effective sound dampening devices or techniques (e.g., hospital-grade mufflers, equipment housing, insulation, installation of sound barriers, earthen berms, vegetative buffers, etc.). • Continue with an aggressive, integrated, noxious and invasive weed management plan that includes a monitoring and response program. Utilize an adaptive management strategy that permits effective responses to monitored findings and reflects local site and geologic conditions. • Map the occurrence of existing weed infestations prior to development to effectively monitor and target areas that will likely become issues after development. Continue control programs through reclamation. Reclamation The performance standard for reclamation success is the establishment of a self-sustaining, vigorous, and diverse plant community on the site with a density sufficient to control erosion and non-native plant invasion. Reclamation efforts should include the following: 2