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Colowyo, C1981-019, PR3 adequacy 17 <br />February 25, 2011 <br />to designating areas at the time of reclamation to as sagebrush steppe to ensure successful shrub <br />establishment. <br />3. Page 34, footnote at bottom of page - Many reasons have been given as rationale to lower the <br />herbaceous cover of reclaimed areas from 90% to 70% of the sagebrush reference area's cover. <br />Along with the given rationale, please provide additional documentation and/or data which <br />support the proposal that a 90% cover of sagebrush reference area is not acheivable within the <br />10 year bond period. <br />4.15.8 Revegetation Success Criteria <br />Page 38, last paragraph - Colowyo has proposed that the maximum proportion of countable <br />shrubs of fourwing saltbush be 20%. Please include an explanation in greater detail (including <br />documentation/data collected at Colowyo and other locations) that supports this proposed <br />standard. <br />2. Page 39, Diversity - The diversity standards proposed for the Collom Expansion Area are <br />different from the diversity standards in the Colowyo Mine. Please provide an explanation and <br />supporting evidence justifying the differences in diversity standards. <br />3. Page 29, first paragraph - 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. If best management practices <br />are followed, such as installing fencing before elk browsing occurs, Colowyo will have a <br />successful establishment of tall shrubs. Other mined land reclamation experiments at Seneca <br />Yoast and Seneca IIW have shown this to be possible. Please remove the sentence in this <br />paragraph describing the use of the information from these trials as "an avenue for relief of the <br />tall shrub establishment area expectations" from the permit. <br />Rule 4.16 Post-Mining Land Use <br />1. CCC states that "Grazing has not been allowed within the initial Colowyo Permit area since <br />fences were constructed in 1977 and will not be allowed in the additional permit area until final <br />bond release is achieved." Please provide an explanation of how CCC proposes to demonstrate <br />that the reclaimed lands will be capable of supporting the post-mining land use of rangeland <br />and grazingland if grazing pressure has not been implemented. <br />2. The operator has proposed a post mining land use of grazingland for a large portion of the <br />reclaimed Collom area. The Division is currently in the process of conducting formal rule <br />changes to the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining <br />(Rules) to identify grazingland as a defined post-mining land use. Should the Division propose <br />to approve PR3 Collom mine expansion prior to final rule change promulgation; the post- <br />mining land use will require revision to an approved land use as defined by Rule 1.04(71).