Laserfiche WebLink
03/2512011 06:36 FAT( 7192275297 DOWCOS <br />STATE OF COLORADO <br />John W. Mckenlooper, Governor <br />DEPARTMENT OF NATURAL RESOURCE$ <br />DIVISION OF WILDLIFE <br />API EQUAL QPPOMMyt7Y MPWyM <br />Thamas E. Remington. Director <br />Southeast Region: <br />4255 Sinton Road <br />Colorado sprtrtgs, Co 80907 <br />Telephone, (719)227-5200 <br />FAK (719)227-5297 <br />wWW. wlldlile. dtate_oo_ ua <br />March 24, 2011 <br />Mr. Kent Gorham <br />Environmental Protection Specialist <br />Division of Reclamation, Mining and Safety <br />1313 Sherman St., Room215 <br />Denver, CO 80203 <br />1a0041005 <br />a <br />For W10ife- <br />For Pwpk <br />Re: CDOW Review and Comments Pertaining to Now Elk Mine (Permit No. C-1981-012)0 Technical <br />Revision Application No. 56 (TR-54 and I(nddental Permit Boundary ChaAge-and 2011 "at Plan <br />Dear Mr. Gorham: <br />The Colorado Division of Wildlife (CROW) has reviewed your letter, dated February 28, 2011, regarding the <br />proposal to increase the permit boundary of 22.5 acres within CDOW owned surface and coal at the Cline Mining <br />- New Ells Mine (NECC) under the Bosque del Oso State Wildlife Aaron (SWA). <br />CDOW's comments relate to the proposed permit boundary changes and our concerns for the mitigation measures <br />which were recommended for surface subsidence. <br />While CDOW does not, in general, have concerns with the proposal to increase the permit boundary by 22.5 acres <br />within the lease, we wish to reiterate our concern for the proposed mitigation measures outlined in the Subsidence <br />Control, Monitoring, and Mitigation Plan developed by Agapito Associates, Inc. (AAI Plan). CROW outlined <br />these specific concerns in our letter for PR-02. <br />Specifically, CDOW is concerned about the additional surface disturbance that uncovering methane gas limes to <br />alleviate subsidence would create, including: <br />• the length of time during which the gas pipelines would remain decoupled from the ground, <br />• the amount of time the pipelines would remain uncovered, <br />+ the recommended measures to mitigate the impacts that the open trenches pose to wildlife, <br />• the effects on public use of the surface, <br />• the effects on the state's ability to perform routine management operations, <br />• whether the additional surface disturbances places XTO Energy in direct violation of the states Surface <br />Use Agmnaent, <br />+ the recommended interim reclamation, and <br />• 't'imeline for final reclamation, <br />DEPARTMENT OF NATURAL RESOURCES. Mike long. Emecx" DimcSor <br />WILDLIFE COMMISSION, Trn Gle m, Chair. Robert Strader, Vke Chair. Mark Smith, Secretary <br />Members. DaW R. Brot ham • Dennis Bued*r . Donthaa Farris . Atan Jones • John SingMW • Dean Wingfield <br />Px OMdo Members. M w King and John Salem