2011-05-23_REVISION - C1981019 (2)

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Colowyo Response - PR3 adequacy No. 2 17 May 6, 2011 targeted areas, Colowyo doesn't have any objection to doubling the seed mix application of the "drill seeded" components of either seed mix when the mixes are applied exclusively via the aerial broadcast method, and has modified Tables 2.05-7 and 2.05-9 to reflect this in addition to adding a sentence to the end of the first paragraph of the Section 2.05.4(2) (e) text following the "Planting and Seeding Methods" subheading. 7. Page 111, paragraph 2 - As per Rule 4.15.8(2), Colowyo mine is required to have a woody plant density at least equal to that of an approved reference area. Therefore, Colowyo cannot exempt itself from the woody plant density standard. Please remove this paragraph from the permit. Page 113, last paragraph - The response provided by Colowyo does not address the concern that the text clearly states "...all previous shrub-establishment metrics indicated for use at the Colowyo mine are hereby remanded." Colowyo cannot exempt itself from the woody plant density standard. Please remove this paragraph from the permit Colowyo 's Response: The statement in quotations does not appear in the revised text... and Colowyo is not asking to exempt itself from the woody plant density standard. The statement previously included in the text was misinterpreted. It was removed and clarification added in its' place to explain that containerized saplings and live local transplants will not be a part of large scale shrub establishment efforts. 8. Page 111, paragraph 2 - Colowyo Mine has had shrub establishment success with the direct seeding method; however, some desired plant species that have a high wildlife value did not respond to the direct seeding method in the field trials as reported in the 2008 report by Paschke. Two species in particular Chokecherry (Prunus virginiana) and serviceberry (Amelanchier alnifolia) are present in the Collom expansion area and should be included in the tall shrub vegetation plan as containerized stock. Please include a plan to plant containerized stock in wildlife exclosures that includes these two species. Page 113, last paragraph - Chokecherry and serviceberry (highly desired plant species for wildlife) did not respond to the direct seeding method in the field trials at the Colowyo Mine as reported by Paschke ("Establishing Shrubs to Achieve Bond Release on Colorado Coal Mines - A Demonstration of Methods", 2008. CSU, Fort Collins, CO). Please include a plan for containerized stock in wildlife exclosures that includes these two species. Colowyo's Response: Based on discussions at the April 29, 2011 meeting, CDOW fully appreciates the challenges of establishing tall shrub species. CDOW is supportive of the implementation of another round of field trials as proposed for the current operation and incorporated into the proposed Collom Expansion Area reclamation plan. As long as Colowyo continues to pursue these efforts to advance the state of reclamation science, CDOW may not pursue large-scale reclamation requirements to establish this plant community. Colowyo has provided a letter to CDOW to evaluate and provide further comment on this issue and many others.