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Colowyo, C1981-019, PR3 adequacy No. 2 12 April 22, 2011 <br />7. Page 111, paragraph 2 - 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. Therefore, Colowyo cannot <br />exempt itself from the woody plant density standard. Please remove this paragraph from the <br />permit. <br />Page 113, last paragraph - The response provided by Colowyo does not address the concern <br />that the text clearly states "...all previous shrub-establishment metrics indicated for use at the <br />Colowyo mine are hereby remanded." Colowyo cannot exempt itself from the woody plant <br />density standard. Please remove this paragraph from the permit <br />8. Page 111, paragraph 2 - Colowyo Mine has had shrub establishment success with the direct <br />seeding method; however, some desired plant species that have a high wildlife value did not <br />respond to the direct seeding method in the field trials as reported in the 2008 report by <br />Paschke. Two species in particular Chokecherry (Prunus virginiana) and serviceberry <br />(Amelanchier alnifolia) are present in the Collom expansion area and should be included in the <br />tall shrub vegetation plan as containerized stock. Please include a plan to plant containerized <br />stock in wildlife exclosures that includes these two species. <br />Page 113, last paragraph - Chokecherry and serviceberry (highly desired plant species for <br />wildlife) did not respond to the direct seeding method in the field trials at the Colowyo Mine as <br />reported by Paschke ("Establishing Shrubs to Achieve Bond Release on Colorado Coal Mines - <br />A Demonstration of Methods", 2008. CSU, Fort Collins, CO). Please include a plan for <br />containerized stock in wildlife exclosures that includes these two species. <br />9. Page 111, paragraph 3 - Please expand on the details as to when and which stabilization <br />method will be utilized on road cuts. Include the seed mix used and explain the use of species. <br />Also, this paragraph was written in the past tense as if the roads have been cut and stabilized. <br />Please re-write this paragraph in the present or future tense to prevent confusion as to what has <br />been accomplished and what will be performed. <br />This item has been resolved <br />10. Page 111, paragraph 5 - The use of elk proof fencing is to prevent the browsing and destruction <br />of planted shrubs (by large game animals) to ensure their establishment. The Division would <br />like to see a more proactive fencing plan to prevent the destruction of the shrubs rather than a <br />reactive approach after "excessive damage (severe hedging) to those populations is noted." <br />Please submit a comprehensive fencing plan which addresses: location of exclosure (include a <br />map), size of the exclosure and plant community in the exclosure. <br />Page 114, paragraph 4 - Elk proof fencing is an effective way to prevent the browsing and <br />destruction of planted shrubs to ensure shrub establishment. Given the intensity of elk use at <br />Colowyo, and results we have observed at Colowyo and other mines in northwest Colorado, <br />including research as well as operational plantings, fencing to exclude elk appears to be <br />necessary for successful establishment of shrub species including serviceberry and <br />chokecherry. This technique has been used with great success at other mines and has proven to