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3. Please include a plan for continued monitoring and managing of other pests and weeds <br />found on the site but not mentioned in 2.05.4(e)(v) but listed in Appendix U, Noxious <br />Weeds, page 6 and Appendix V, 7.1 Noxious Weeds, Table 16, page 44. These include <br />species that are on the Garfield County and Colorado Department of Agriculture weed lists. <br />2.05.4(2)(e)(vi) <br />1. The Division agrees with and approves the recommendation to use the Greasewood <br />Reference Area as the ultimate revegetation success standard for all of the Greasewood <br />areas to be disturbed. <br />2. Wood plant density - The previous reference data (Vegetation Inventory 4.5.10.1-3 1980) <br />documents that shrub density for each community is: greasewood - 3386/ac, shadscale - <br />1790/ac and juniper - 1797/ac. These densities are not reflected proportionally in the <br />targeted reclamation standard densities: greasewood - 500/ac, shadscale - 500/ac and <br />juniper 1,500/ac. However, the new predisturbance data suggests that the proposed <br />proportions are correct (Append U, Table 2.04.10-5, -8). However, it is not clear how the <br />proposed density standards were established. Additionally, all density standards need to be <br />based on consultation with the Colorado DOW as per rule 4.15.8(7). Please explain how <br />the density standard was determined including documentation from the DOW. <br />3. Diversity - A minimum of forb species is not proposed. Please include forb species in the <br />diversity standard. <br />4. A small area on top of the coal waste pile is proposed to be seeded with the Juniper <br />Woodland seed mix. The proposed reclaimed area will not be the same topography or soil <br />type as the area presently inhabited by the Juniper Woodland Reference Area. In addition, <br />this area is very small (10.79 acres). The Division questions if the Juniper Woodland type <br />will be successful in that location. CAM may want to consider returning that area to <br />greasewood, consistent with the remainder of the coal waste pile. If CAM elects to do that, <br />a weighted-average reference area for all the reclaimed areas could be applied. <br />5. Similar to the question above, the Division questions the feasibility of the proposed <br />shadscale reclaimed area. The proposed shadscale community is only one acre (Table 4.5- <br />2), and the proposed seedmix is very similar to the greasewood seedmix. An alternative <br />would be to reclaim all areas to the greasewood community and use a weighted average <br />reference area. <br />6. There is no mention of reference area management in Rule 2.05.4. Please address Rule <br />4.15.7(d) for reference area management on all three reference areas. <br />Rule 2.05.5 - Post Mining Land Use <br />The premining land use of the entire permit area is rangeland and fish and wildlife habitat. The <br />proposed postmining land use of the entire permit area is also rangeland and fish and wildlife habitat as <br />shown on Figure 4.1-1 and will be achieved by reclaiming the disturbed area in accordance with the <br />reclamation plan described in section 2.05.4. Three major vegetation communities will be disturbed <br />and MCM is proposing to reclaim the disturbed area to the standards of the corresponding reference <br />areas. The land is owned and managed by the BLM. <br />4