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Colowyo, C1981-019, PR3 adequacy No. 2 11 April 22, 2011 <br />the Division needs to be contacted before any action is taken. An adequate amount of <br />flexibility is built into the permitting and inspection system that allow for "on-the-ground" <br />reality. The Division requests that this paragraph be removed 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 />Page 113 - Colowyo's response addresses the concerns of seed mixes for temporary structures <br />used during active mining, but does not address the discussion of how "one seed mixture is <br />capable of self-selection for each micro-habitat encountered in the reclaimed areas" (Volume <br />15, Rule 2, page 111). The proposed seed mixture listed in Table 2.05-7 contains 15 species <br />while the Collom Expansion Area has 6 major vegetation communities and 4 minor vegetation <br />communities with 2 sub-types (mesic and xeric). Please breakdown the seed mix to explain <br />which species are appropriate for each of the various reclaimed vegetation types, and provide <br />evidence of other reclamation projects where a single seed mix met all the revegetation <br />standards required by the Colorado Mined Land Reclamation Board across many vegetation <br />communities. <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. <br />CCC provided legible seed mix tables. This item is acceptable. <br />6. Please add text stating that the seeding rate of the drilled species will be doubled in the areas <br />which are inaccessible by the drill seeder and that these species will be exclusively broadcast <br />seeded in the areas inaccessible by the drill seeder. <br />The Division is not familiar with the relationship between increased broadcast seeding rates <br />and lower plant diversity. Doubling the seeding rate for broadcast seeding to that of drill <br />seeding is to account for loss of seeds to predation, desiccation and wind and water erosion. <br />Please provide evidence, such as peer reviewed articles/studies, that demonstrates a relationship <br />between increased broadcast seeding rates and an increase in competitive grass species thereby <br />decreasing community diversity. Note: the proposed seed mix listed in Table 2.05-7 for <br />Collom has a very high grass component and low shrub/forb diversity. Rather than lowering <br />the seeding rate to increase diversity, another approach may be to lower the number of grasses <br />in the mix and increase the number of shrubs/forbs.