2011-05-23_REVISION - C1981019 ‎(2)‎

• Permit No: C1981019
• IBM Index Class Name: REVISION
• Doc Date: 5/23/2011
• Doc Name: 2nd Adequacy Response Review
• From: Colowyo Coal Company
• To: DRMS
• Type & Sequence: PR3
• Email Name: JHB
• Media Type: D
• Archive: No

Colowyo Response - PR3 adequacy No. 2 15
May 6, 2011
Colowyo has modified the appropriate text to reflect that approximately .37% of the proposed
post-mine topography will exhibit slopes <10% slope and provide clarification why the area
targeted for attempted sagebrush steppe establishment will be approximately 30% of the overall
disturbed reclamation surface.
Page 108, third paragraph - When situations arise that require Colowyo to deviate from the
approved reclamation plan, the Division needs to be contacted before any action is taken. The
Division feels that an adequate amount of flexibility is built into the Division's permitting and
inspection system that allows for "on-the-ground" reality. The Division makes monthly mine
inspections with mine personnel to discuss various issues of which include reclamation
progress. During these routine inspections, mine personnel have the opportunity to discuss
reclamation operations and any foreseeable shortcomings in the permitted/approved design. If
the mine reclamation specialist and the Division feel that a revision is warranted because of an
unforeseen/unplanned "on-the-ground" reality, then a revision to the permit will be submitted
to the Division at that time. The Division requests therefore, that this paragraph be removed
from the permit.
Page 118, last paragraph - The additional language added to this paragraph does not add
clarification as to when deviation from the permit is acceptable. The Division reaffirms its
position that when a situation arises that requires Colowyo to deviate from the original permit,
the Division needs to be contacted before any action is taken. An adequate amount of
flexibility is built into the permitting and inspection system that allow for "on-the-ground"
reality. The Division requests that this paragraph be removed from the permit.
Colowyo's Response:
Colowyo believes the Division was referring to the last paragraph ofpreviously revised page
110 and the first paragraph of page 111 above with regards to deviations from the "approved
reclamation plan". Colowyo has provided specific clarification for the latitude being proposed
with respect to reclamation plan implementation in the final two paragraphs of Section
2.05.4(2)(e) prior to the Revegetation Plan sub-heading.
4. Page 110 - Colowyo is proposing to use two different seed mixes for the reclamation of the
entire Collom expansion area. Due to the fact that the Collom mine encompasses a landscape
with many different plant communities, land aspect, soil types, elevations, slope gradients and
soil moisture availability, the Division feels that a more diverse approach be used to address the
various topography and resource availability to plants at the site. There should be a seed mix
designed for topsoil stock piles, overburden stock piles, steep slopes, bottomlands, sage brush
steppe (already designed), mountain shrub habitat and grasslands. This reclamation approach
will yield better results for species diversity, cover, production and stem density rather than two
`diverse' seed mixes.
Page 113 - Colowyo's response addresses the concerns of seed mixes for temporary structures
used during active mining, but does not address the discussion of how "one seed mixture is
capable of self-selection for each micro-habitat encountered in the reclaimed areas" (Volume
15, Rule 2, page 111). The proposed seed mixture listed in Table 2.05-7 contains 15 species
while the Collom Expansion Area has 6 major vegetation communities and 4 minor vegetation
i