2011-05-23_REVISION - C1981019 (2)

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Colowyo Response - PR3 adequacy No. 2 13 May 6, 2011 CCC has noted that CCC will provide this information to the Division. A detailed Reclamation Cost Estimate is still required to be submitted for the Division's review. Colowyo's Response: A detailed reclamation bond cost estimate through year 2017 is provided in Volume 20, Exhibit 13 B with this submittal. Three new maps (Map 35B, 36B, and 40B) are also provided in support of this cost estimate. Rule 2.05.4(2)(e) Reclamation Plan 1. It is not clear in Section 2.05.4(2)(e) of PR-3 if the reclamation standards apply to the Collom expansion area, the Colowyo Mine or both. Please insert a statement at the beginning of this section indicating that all standards stated within PR-3 Collom Expansion Area are only for the, Collom Expansion Area and do not effect or change the existing reclamation procedures, standards or timing of the Colowyo Mine. CCC has clarified that the reclamation standards contained in Volume 15 pertain solely to the Collom expansion and do not change the previously approved standards for the Original permit area, East Pit, Section 16, West Pit and South Taylor mining areas (Rule 2, page108). This response is acceptable to the Division. This item has been resolved. 2. Page 106, first paragraph - The text explains that the final grading of the mine will result in approximately 20% to 40% of the terrain with a slope less than 10%. In contrast, the graph on Map 19D indicates that the percent of final grading with a slope less than 10% is approximately 37%. It is understandable that a certain amount of error exists in the mapping due to the 100 foot by 100 foot grids used in the percent slope calculations, but it would be logical that the error be more evenly distributed around the mean 37%. The Division suggests that a target of 37% of the terrain have less than a 10% slope with a margin of error +/- 2%. If it is determined during the reclamation process that a 10% slope on 37% of the terrain is not possible, the Division and Colowyo will then determine an appropriate percentage of terrain with a slope less than 10% through a technical revision. Page 108, third paragraph - The Division is not proposing an "additional" target to the PMT as suggested in Colowyo's response. The graph on Map 19D documents the PMT with a slope less than 10% will be 37%. The permit text needs to accurately reflect this standard set by Colowyo. The commitment to "attempt in earnest on approximately 20% (or more) of the reclaimed landscape, with the goal of achieving success on at least one-half of this acreage," is inadequate for wildlife habitat. In a letter dated Feb 22, 2011, the US Fish and Wildlife Service expressed concern that "approximately 20 percent of the expansion area to sagebrush would fall short of the site's original condition and potential," which could impact local sage-grouse populations. Please amend the text to accurately reflect the 37% standard proposed by Colowyo with a smaller margin of error (ex. ± 2-3%). Colowyo's Response: Colowyo doesn't dispute the slope determinations portrayed in Map 19D, and Colowyo does not anticipate large-scale issues creating the proposed PMT surface. However, Colowyo did