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2011-02-22_REVISION - C1981019 (4)
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2011-02-22_REVISION - C1981019 (4)
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Last modified
8/24/2016 4:31:08 PM
Creation date
2/23/2011 8:16:35 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981019
IBM Index Class Name
REVISION
Doc Date
2/22/2011
Doc Name
Adequacy Review & Discrepancies in PR3
From
Brock Bowles
To
Janet Binns
Type & Sequence
PR3
Email Name
JHB
Media Type
D
Archive
No
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6. It should be noted in the text that the seeding rate of the drilled species will be doubled in <br />the areas which are inaccessible by the seeder and will be exclusively broadcast seeded. <br />7. Page 111, paragraph 2 - As per Rule 4.15.8(2), Colowyo mine is required to have a woody <br />plant density at least equal to that of an approved reference area. Therefore, Colowyo <br />cannot exempt itself from the woody plant density standard. Please remove this paragraph <br />from the permit. <br />8. Page 111, paragraph 2 - Colowyo Mine has had shrub establishment success with the direct <br />seeding method; however, some desired plant species that have a high wildlife value did not <br />respond to the direct seeding method in the field trials as reported in the 2008 report by <br />Paschke. Two species in particular (chokecherry (Prunus virginiana) and serviceberry <br />(Amelanchier alnifolia)) are present in the Collom expansion area and should be included in <br />the tall shrub vegetation plan as containerized stock. Please include a plan to plant <br />containerized stock in wildlife exclosures that includes these two species. <br />9. Page 111, paragraph 3 - Please expand on the details as to when and which stabilization <br />method is utilized on road cuts. Include the seed mix used and explain the use of species. <br />Also, this paragraph was written in the past tense as if the roads have been cut and <br />stabilized. Please re-write this paragraph in the present or future tense to prevent confusion <br />as to what has been accomplished and what will be performed. <br />10. Page 111, paragraph 5 - The use of elk proof fencing is to prevent the browsing and <br />destruction of planted shrubs (by large game animals) to ensure their establishment. The <br />Division would like to see a more proactive fencing plan to prevent the destruction of the <br />shrubs rather than a reactive approach after "excessive damage (severe hedging) to those <br />populations is noted." Please submit a comprehensive fencing plan which addresses: <br />location of exclosure (include a map), size of the exclosure and plant community in the <br />exclosure. <br />11. Page 112, last paragraph - The use of the "banding" technique is not warranted on slopes <br />with a gradient less than 10%. The Division feels that the techniques of contour furrows, <br />surface roughening and seeding on the contour, already proposed by Colowyo, is adequate <br />for erosion control on these slopes. Please remove this paragraph from the text. <br />12. Page 113, last paragraph - The use of the word indication/indicated is unclear in this <br />sentence. Please revise. <br />13. Please address all of the items in the vegetation section of the attached CDOW letter dated <br />Feb 15, 2011 in this section of the permit. <br />2.05.6(2) Fish and Wildlife Plan <br />At the time of the Adequacy Review for PR-3, the Division received comments from the <br />Division of Wildlife (attached letter Feb 15, 2011) pertaining to the mitigation of impacts to <br />wildlife. The Division will not make further comments about Colowyo's wildlife <br />mitigation plan until Colowyo has had a chance to review this letter and make appropriate <br />changes to PR-3. <br />4.15.1 Revegetation Requirements <br />1. Page 27, Use of Introduced Species - In the second exception for use of introduced species <br />it is stated "prior to the use of aggressive taxa to combat areas that are highly susceptible to <br />4
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