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2011-05-23_REVISION - C1981019
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2011-05-23_REVISION - C1981019
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Entry Properties
Last modified
8/24/2016 4:33:45 PM
Creation date
5/23/2011 2:53:24 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981019
IBM Index Class Name
REVISION
Doc Date
5/23/2011
Doc Name
Attached Response Letters from Colowyo, CDOW, USFWS regarding their Feb 2011 Comment Letter
From
Colowyo Coal Company
To
DRMS
Type & Sequence
PR3
Email Name
JHB
Media Type
D
Archive
No
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o Aspen: Colowyo and CDOW agree to agree that Aspen won't be part of the <br />reclamation plan for Collom. <br />PERFORMANCE STANDARDS <br />- Herbaceous Cover <br />o CDOW and Colowyo are in agreement <br />- Herbaceous Production <br />o CDOW and Colowyo are in agreement <br />Woody Plant Density <br />o In the grassland communities (>10% slope) as a whole, CDOW and Colowyo <br />are in agreement that the Woody Plant Density standard is zero. <br />o CDOW would like to see a 500 stems/acre success standard, not 375 <br />stems/acre on targeted sagebrush steppe core areas. <br />¦ Colowyo feels the 500 stems/acre proposed success standard could be <br />a similar issue as the previous 1000 stems/acre standard that delayed <br />Phase III bond release efforts since the first standards were instituted <br />in the late 1970's. Currently there is no proof that 500 stems/acre is <br />achievable as a baseline measure at Colowyo during the 10-year bond <br />liability period. A success standard of 375 stems/acre is appropriate <br />given past success levels on Colowyo reclamation and is a reasonable <br />shrub density to measure for the 10-year bond liability period. <br />Successful achievement of 375 stems/acre should be achievable <br />consistently given the improvements in the proposed reclamation plan <br />including reduced grass competition and shallow topsoil depths. <br />Please refer to the attached page that includes vegetation survey data <br />from 2006 and 2008 shrub patch counts. This data is from total counts <br />of shrubs within evolved shrub patches. As readily observable, there <br />is a great deal of variation among the species as well as between areas. <br />What is more notable is that an average of slightly more than 375 <br />stems/acre was observed across all of the shrub patches and further <br />demonstrates that this is a reasonable "minimum" expectation for <br />shrub establishment moving forward. As Colowyo has stated, we <br />believe this will be achievable in most instances in the 10-year time <br />frame, especially given the improvements to the reclamation plan. <br />However, until on-the-ground results from the new program are <br />measured and verified in the field, Colowyo is very hesitant to <br />incorporate a standard that has not been achievable to date, despite <br />great effort and best management practices. It is Colowyo's intent to <br />far surpass the minimum criteria for both acres and stems/acre; this <br />should be evident when reviewing the components of Colowyo's <br />proposed reclamation plan. <br />¦ Regarding the standard that one half of the countable shrubs being <br />sagebrush species - CDOW and Colowyo are in agreement. <br />o CDOW would like to see a 375 stems/acre success standard on ecotonal areas <br />as opposed to the proffered 200 stems/acre. <br />Colowyo Mine C-1981-019 page 8 of 9 <br />Permit Revision 03 - Collom Permit Expansion <br />4 May 2011 <br />i - _ .
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