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Corey Heaps <br />CAM- Colorado, LLC <br />November 30, 2010 <br />Page 3 <br />provide opportunity for CDPHE/HMWMD to review and provide comment on the <br />proposed operations and reclamation plan upon submittal, to confirm that such plans do not <br />require any action from HMWMD. <br />3. The boundaries of the designated premine and postmine land use types identified on Map 7 <br />and described in the narrative of Sections 2.04.3 and 2.05.5 require fixrther clarification. <br />The map does not contain clear boundaries separating the land use types. Narrative in the <br />two sections contains some contradictions as well. Please amend the narrative sections and <br />map to be internally consistent, and revise the map to clearly delineate boundaries between <br />the designated land use types. Separate maps for premine and postmine land use may be <br />warranted for clarity, if the land use boundaries or categories differ between premine and <br />postmine. For example, if premine management of all or a portion of the non - industrial <br />part of the permit area included livestock grazing, the appropriate designation would likely <br />be combination Rangeland/Wildlife Habitat, but if planned postmining use would not <br />include livestock grazing, the appropriate designation would be Wildlife Habitat. <br />We presume that premine and postmine land uses for all areas to the east of Reed Wash <br />within the permit area are identified as "Industrial ", as stated in the narrative, based in part <br />on the Mesa County land use classification. However, for the purposes of the DRMS <br />permit and associated reclamation requirements and standards, it may be appropriate that <br />the boundary between "Industrial" and "Fish and Wildlife" land use be defined by the <br />perimeter of the lands that have been physically disturbed by past industrial activity. Given <br />that the soils and vegetation conditions, and reclamation practices within the currently <br />undisturbed greasewood habitat on either side of Reed Wash are the same, it would seem <br />logical that land use (and associated reclamation success standards) should also be <br />consistent. Please give this matter consideration and either define the Previously Disturbed <br />Lands perimeter as the land use boundary, or provide justification for inclusion of the <br />undisturbed greasewood habitat east of Reed Wash as "Industrial ". <br />4. Premine land use for lands within the permit area to the west of Reed Wash is not entirely <br />clear, as there are some statements indicating "Wildlife Habitat" is the sole use (Section <br />2.04.3(2)(a)), and other statements indicating combined uses of "Rangeland" and "Wildlife <br />Habitat" (Section 2.05.5(2)(a)). Map 7 depicts an area of "Fish and Wildlife Habitat" and <br />also an area of "Commercial" land use (within a 3+ acre square parcel not mentioned in the <br />text) to the west of Reed Wash. Also, there is a very small (0.18) acre parcel of "Irrigated <br />Pasture" along the northwest boundary of the permit area, noted on the Vegetation Map <br />(Map 3), but "Pastureland" is not identified as a land use category. Please state under <br />2.04.3(2)(a) what the land uses within the permit area are at the time of filing of the <br />application, in accordance with the land use definitions in Rule 1.04, and amend Map 7 as <br />warranted to be consistent with the narrative. If the area west of Reed Wash is currently <br />grazed by livestock during portions of the year, the land use designation should include <br />Rangeland, (and possibly a small area of pastureland) in combination with Fish and <br />Wildlife Habitat. If the postmining land use designation for portions of the permit area will <br />