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the utilization of the reclaimed areas by target species such as the Columbian sharp-tailed grouse and <br />nesting raptors." The Division does not have a similar evaluation requirement of wildlife utilization of <br />reclaimed areas. A commitment by PSCCC to conduct wildlife monitoring during reclamation success <br />evaluation may meet the CDOW's requirement. A determination of which species of concern PSCC is <br />expected to monitor, and what extent of utilization is considered success or failure by the CDOW needs to <br />be determined between the operator and CDOW, preferably during this initial permit application process. <br />Seed mixes: The CDOW has provided comments on the proposed reclamation seed mixes for the PSCM. <br />The proposed seed mixes are the same as the approved Seneca II Mine seed mixes. The CDOW had no <br />additional comments regarding seed mix 2.05.4-T1 and found this seed mix acceptable. Seed mix 2.05.4-T2 <br />is proposed for reclamation of the mine surface facility disturbance area. The CDOW recommends <br />replacing Alpine fescue with Idaho fescue (Festuca Idahoensis) as Idaho fescue is better adapted to the <br />proposed location. The CDOW noted that Creeping foxtail (Alopecurus arundinacea) included in Seed Mix <br />2.05.4-T3 is an introduced species, however, the CDOW did not request PSCCC to replace this species in <br />the mix. The CDOW did request that PSCCC include Mountain big sagebrush in the 2.05.4-T3 seed mix. <br />2.05.4-T5 seed mix is proposed for use on very small disturbances associated with drill hole, monitoring <br />wells, and other drilling related sites. Generally these disturbances are less than half an acre. The CDOW <br />expressed concerns with the 2.05.4-T5 seed mix. Species the CDOW expressly requested to be removed <br />from the drill site seed mix include Intermediate wheatgrass, Pubescent wheatgrass, Desert wheatgrass, and <br />Smooth brome. Although the Division has previously approved these species in exploration drill pad <br />reclamation seed mixes, these species do tend to be aggressive introduced species, and generally are <br />discouraged from inclusion in large disturbance reclamation seed mixes. Drill sites are typically 100 ft. x <br />100ft. (0.22 acres) in size. In these small disturbance areas, these introduced species have not outcompeted <br />the desired reclamation species, and the seeding rates have been kept low. Rule 4.18(5)(i)(i) requires that <br />seed mixes used to reclaim areas with post-mining land use of fish and wildlife habitat shall support and <br />enhance fish and wildlife habitat. The Division recommends that the noted introduced species be removed <br />from seed mix 2.05.4-T5 and either increase the other remaining species, or replace with less aggressive <br />species. Perennial grass species recommended by CDOW (Columbian Sharp-tailed Grouse Conservation <br />Plan, Routt, Moffat, and Rio Blanco Counties, by Rick Hoffinan, 2001) include Big bluegrass, Idaho fescue, <br />Bluebunch wheatgrass, Basin wildrye, Mountain brome, Western wheatgrass, and Tall wheatgrass, in <br />addition to acceptable species already in 2.05.4-T5 seed mix. Please have PSCCC revise the 2.05.4-T5 seed <br />mix to address the CDOW's concerns. <br />The CDOW recommendations for protection of Columbian sharp-tailed grouse require that disturbance <br />within 1.25 miles of two identified Columbian sharp-tailed grouse leks should be minimized between March <br />15 through June 15. The PSCM application contains provisions to restrict activity near the leks from March <br />through May, Section 2.05.6(2) of the permit application. Please have PSCCC revise the time period of <br />avoidance of the leks to match the CDOW recommendation. <br />The CDOW provided direction for protection of golden eagle nesting locations. Although PSCCC included <br />raptor mitigation measures in the PSCM application, Section 2.05.6(2), this section will need to be revised <br />to address the CDOW's concerns regarding protection of five identified golden eagle nests. The CDOW has <br />concerns regarding activity within %2 mile of any active golden eagle nest from March 1 through May 31. <br />The CDOW requires consultation with the CDOW with regard to mitigation of potential subsidence issues