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A success standard of 200 stems/acre is appropriate given past success <br />levels on Colowyo reclamation and is a reasonable shrub density to <br />measure for the 10-year bond liability period on ecotonal areas given <br />the same arguments presented above. Successful achievement of 200 <br />stems/acre should be achievable consistently given the improvements <br />in the proposed reclamation plan including reduced grass competition, <br />significant levels of sagebrush seed in the grassland mix and variable <br />topsoil depths. Furthermore, the standard on Ecotonal areas is reduced <br />as these are areas with appropriate habitat character, but have not fully <br />developed within the 10-yr liability period. They are labeled as <br />ecotonal as the expectation is that they will become more dense with <br />time, but not as quickly as core areas. <br />MORGAN CREEK RANCHING FOR WILDLIFE <br />- Colowyo believes about 7,642 acres of the Morgan Creek Ranching for Wildlife <br />Area will be incorporated into the Collom expansion area boundary. <br />o Colowyo will evaluate the inclusion of reclaimed areas into the Morgan Creek <br />Ranching for Wildlife Area after Phase III bond release is achieved on those <br />areas. <br />o Currently, Colowyo's policy is not to allow hunting activities within the mine <br />permit boundary due to safety and liability concerns. <br />As Colowyo is currently in the process of answering a second round of technical adequacy <br />questions from CDRMS regarding the Collom Expansion Area and a proposed decision date for <br />this package is currently scheduled for May 16, some of the information discussed in this letter <br />will be incorporated into the revised application material text that will be submitted in the next <br />week to ten days. It is likely that a brief extension to the current decision date deadline will be <br />necessary to allow CDRMS to complete their review of updated materials, but the sooner <br />CDOW could provide a response to Colowyo regarding the content of this communication the <br />greater likelihood Colowyo and CDOW can resolve any continuing concerns. There may be <br />some potential CDRMS would be willing to allow CDOW and Colowyo to resolve the <br />formalization of any off-permit mitigation plans/strategies outside of the CDRMS permitting <br />process, but I cannot speak for them. <br />Hopefully this letter and the attached information is helpful to your group. Colowyo looks <br />forward to continuing our cooperative efforts to improve wildlife habitat in the region. Please <br />feel free to contact me at (970) 824-1531 if you have any additional questions or would like <br />further clarification on a particular point or response. <br />Sincerel <br />'e?t?e' ?ej <br />Kurtis R. Blunt <br />Environmental Supervisor <br />cc: File <br />Colowyo Mine C-1981-019 page 9 of 9 4 May 2011 <br />Permit Revision 03 - Collom Permit Expansion