2011-02-15_REVISION - C1980004 (2)

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Corey Heaps McClane Canyon Mining, LLC February 15, 2011 Page 16 74. The Division agrees with and approves the recommendation to use the Greasewood Reference Area as the ultimate revegetation success standard for all of the Greasewood areas to be disturbed. 75. Wood plant density — The previous reference data (Vegetation Inventory 4.5.10.1 -3 1980) documents that shrub density for each community is: greasewood — 3386/ac, shadscale -- 1790/ac and juniper- 1797/ac. These densities are not reflected proportionally in the targeted reclamation standard densities: greasewood — 500 /ac, shadscale — 500 /ac and juniper 1,500 /ac. However, the new predisturbance data suggests that the proposed proportions are correct (Append U, Table 2.04.10 -5, -8). However, it is not clear how the proposed density standards were established. Additionally, all density standards need to be based on consultation with the Colorado DOW as per rule 4.15.8(7). Please explain how the density standard was determined including documentation from the DOW. 76. Diversity — A minimum of forb species is not proposed . Please include forb species in the diversity standard. 77. A small area on top of the coal waste pile is proposed to be seeded with the Juniper Woodland seed mix. The proposed reclaimed area will not be the same topography or soil type as the area presently inhabited by the Juniper Woodland Reference Area. In addition, this area is very small (10.79 acres). The Division questions if the Juniper Woodland type will be successful in that location. MCM may want to consider returning that area to greasewood, consistent with the remainder of the coal waste pile. If MCM elects to do that, a weighted- average reference area for all the reclaimed areas could be applied. 78. Similar to the question above, the Division questions the feasibility of the proposed shadscale reclaimed area. The proposed shadscale community is only one acre (Table 4.5 -2), and the proposed seedmix is very similar to the greasewood seedmix. An alternative would be to reclaim all areas to the greasewood community and use a weighted average reference area. 79. There is no mention of reference area management in Rule 2.05.4. Please address Rule 4.15.7(d) for reference area management on all three reference areas. Rule 2.05.5 Post Mining Land Use The premining land use of the entire permit area is rangeland and fish and wildlife habitat. The proposed postmining land use of the entire permit area is also rangeland and fish and wildlife habitat as shown on Figure 4.1 -1 and will be achieved by reclaiming the disturbed area in accordance with the reclamation plan described in section 2.05.4. Three major vegetation communities will be disturbed and MCM is proposing to reclaim the disturbed area to the standards of the corresponding reference areas. 80. The land is owned and managed by the BLM. On page 2.05 -53 MCM states that the BLM will have an opportunity to comment concerning the proposed postmining land use during its review of the permit. The BLM is preparing an EA for the proposed mine expansion project. This statement on page 2.05 -53 will need to be updated at the conclusion of the application