2010-11-30_APPLICATION CORRESPONDENCE - C2010088 (2)

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Corey Heaps CAM - Colorado, LLC November 30, 2010 Page 12 36. The initial paragraph under "Conclusions" on page 17 of Exhibit 5 is not clearly stated. The second sentence of the paragraph is jumbled and does not make sense. The third sentence could be clarified by stating that sample adequacy was achieved for total plant cover sampling in the greasewood affected and reference areas, and that minimum sample sizes as agreed upon with DRMS prior to sampling were achieved for herbaceous production and woody plant density in the greasewood affected and reference areas, and for all parameters in the wetland and riparian communities. The fourth sentence of the paragraph could be deleted. The one sentence second paragraph should be clarified to state that, due to the very minimal extent of proposed disturbance to the Wetland type (less than 0.5 acres cumulative), and absence of proposed disturbance to the Riparian type, herbaceous production and vegetation cover for all areas reclaimed to Fish and Wildlife habitat postmine land use will be sampled as a single unit for comparison to the Greasewood Reference area. Please revise the narrative for clarity. 37. There is a species with acronym "PENPAN" listed as a shrub in the shrub density tables for riparian and wetland communities, and as a noxious weed in the cover data for the same types. There is no species listed in the species list that matches the subject acronym. We also note that salt cedar (Tamarix ramosissima), is noted in the text of Exhibit 5 as the only shrub other than greasewood that was encountered in the woody plant density sampling of the Reed Wash riparian community, but the species was not listed in the shrub density or cover tables for the riparian or wetland communities, nor was the species included in the species list. Presumably, "PENPAN" should be "TAMRAM ", and definitely, salt cedar should be listed in the species list. Please make corrections as appropriate. 38. The Tab 5 narrative does not appear to contain the discussion required by Rule 2.04.10(4) regarding current condition of the plant communities and relevant environmental and management factors affecting species composition and distribution. Please amend the narrative to include the required discussion. 39. The potential for impacts to rare and endangered plant species is addressed in Exhibit 10, "McClane Canyon Coal Mine Coal Loadout Facility Wildlife and Sensitive Plant Studies" The report notes that Colorado hookless cactus (,Sclerocactus glaucus), is the only T &E plant species potentially occurring in the project area, and states that surveys conducted in the project area did not detect the species. Please provide expanded discussion regarding the extent of potential habitat for the species within the permit and proposed disturbance areas, and the timing and method of surveys that were conducted within the areas of potential habitat. Rule 2.04.11 Fish and Wildlife Resources Information 40. The Colorado Division of Wildlife (DOW) submitted comments to the DRMS that was received on November 19, 2010. Please see the attached letter (Attachment 3) from them