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2011-05-23_REVISION - C1981019 (2)
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2011-05-23_REVISION - C1981019 (2)
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Last modified
8/24/2016 4:33:45 PM
Creation date
5/23/2011 2:53:26 PM
Metadata
Fields
Template:
DRMS Permit Index
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
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Colowyo Response - PR3 adequacy No. 2 18 May 6, 2011 <br />More important and directly on point, evaluations of previous bare root and containerized <br />planting efforts at Colowyo from 1979 through 2000 resulted in an overall success rate of <br />approximately 12.6%. While Colowyo is willing to continue evaluating alternative methods for <br />advancing the knowledge of reclamation science with regards to establishing components of <br />the tall shrub plant community, it is not reasonable to require large scale implementation <br />efforts to re-establish the tall shrub plant community as part of reclamation requirements in the <br />Collom Expansion Area at this time. <br />9. Page 111, paragraph 3 - Please expand on the details as to when and which stabilization <br />method will be utilized on road cuts. Include the seed mix used and explain the use of species. <br />Also, this paragraph was written in the past tense as if the roads have been cut and stabilized. <br />Please re-write this paragraph in the present or future tense to prevent confusion as to what has <br />been accomplished and what will be performed. <br />This item has been resolved <br />10. Page 111, paragraph 5 - The use of elk proof fencing is to prevent the browsing and destruction <br />of planted shrubs (by large game animals) to ensure their establishment. The Division would <br />like to see a more proactive fencing plan to prevent the destruction of the shrubs rather than a <br />reactive approach after "excessive damage (severe hedging) to those populations is noted." <br />Please submit a comprehensive fencing plan which addresses: location of exclosure (include a <br />map), size of the exclosure and plant community in the exclosure. <br />S Page 114, paragraph 4 - Elk proof fencing is an effective way to prevent the browsing and <br />destruction of planted shrubs to ensure shrub establishment. Given the intensity of elk use at <br />Colowyo, and results we have observed at Colowyo and other mines in northwest Colorado, <br />including research as well as operational plantings, fencing to exclude elk appears to be <br />necessary for successful establishment of shrub species including serviceberry and <br />chokecherry. This technique has been used with great success at other mines and has proven to <br />increased shrub survival and density. The Division would like to see a more proactive fencing <br />plan to prevent the destruction of the shrubs rather than a reactive approach after "excessive <br />damage (severe hedging) to those populations is noted." Please submit a comprehensive <br />fencing plan which addresses: location of exclosure (include a map), size of the exclosure and <br />plant community in the exclosure. <br />Colowyo's Response: <br />Colowyo's reclamation plan is designed to overwhelm the local wildlife populations' ability to <br />significantly damage the shrub components of the plant communities targeted for <br />establishment. Colowyo is not in favor of annually fencing individual reclamation units for <br />practical and economic reasons. Colowyo has a requirement to create 350 acres of sagebrush <br />steppe in the Collom Expansion area. Should fencing be needed to ensure compliance with this <br />requirement, rest assured, fencing will be implemented. <br />11. Page 112, last paragraph - The use of the "banding" technique is not warranted on slopes with <br />a gradient less than 10%. The Division fcels that the techniques of contour furrows, surface
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