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Colowyo, C1981-019, PR3 adequacy 8 February 25, 2011 <br />Rule 2.05.4(2)(e) Reclamation Plan <br />1. It is not clear in Section 2.05.4(2)(e) of PR-3 if the reclamation standards apply to the Collom <br />expansion area, the Colowyo Mine or both. Please insert a statement at the beginning of this <br />section indicating that all standards stated within PR-3 Collom Expansion Area are only for the <br />Collom Expansion Area and do not effect or change the existing reclamation procedures, <br />standards or timing of the Colowyo Mine. <br />2. Page 106, first paragraph - The text explains that the final grading of the mine will result in <br />approximately 20% to 40% of the terrain with a slope less than 10%. In contrast, the graph on <br />Map 19D indicates that the percent of final grading with a slope less than 10% is approximately <br />37%. It is understandable that a certain amount of error exists in the mapping due to the 100 <br />foot by 100 foot grids used in the percent slope calculations, but it would be logical that the <br />error be more evenly distributed around the mean 37%. The Division suggests that a target of <br />37% of the terrain have less than a 10% slope with a margin of error +/- 2%. If it is determined <br />during the reclamation process that a 10% slope on 37% of the terrain is not possible, the <br />Division and Colowyo will then determine an appropriate percentage of terrain with a slope <br />less than 10% through a technical revision. <br />3. Page 108, third paragraph - When situations arise that require Colowyo to deviate from the <br />approved reclamation plan, the Division needs to be contacted before any action is taken. The <br />Division feels that an adequate amount of flexibility is built into the Division's permitting and <br />inspection system that allows for "on-the-ground" reality. The Division makes monthly mine <br />inspections with mine personnel to discuss various issues of which include reclamation <br />progress. During these routine inspections, mine personnel have the opportunity to discuss <br />reclamation operations and any foreseeable shortcomings in the permitted/approved design. If <br />the mine reclamation specialist and the Division feel that a revision is warranted because of an <br />unforeseen/unplanned "on-the-ground" reality, then a revision to the permit will be submitted <br />to the Division at that time. The Division requests therefore, that this paragraph be removed <br />from the permit. <br />4. Page 110 - Colowyo is proposing to use two different seed mixes for the reclamation of the <br />entire Collom expansion area. Due to the fact that the Collom mine encompasses a landscape <br />with many different plant communities, land aspect, soil types, elevations, slope gradients and <br />soil moisture availability, the Division feels that a more diverse approach be used to address the <br />various topography and resource availability to plants at the site. There should be a seed mix <br />designed for topsoil stock piles, overburden stock piles, steep slopes, bottomlands, sage brush <br />steppe (already designed), mountain shrub habitat and grasslands. This reclamation approach <br />will yield better results for species diversity, cover, production and stem density rather than two <br />`diverse' seed mixes. <br />5. The seed mix tables 2.05-7,-8 & -9 in Volume 1 are difficult to read due to the small font size. <br />Please re-submit these and other proposed seed mix charts with a larger font size.