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2011-06-02_APPLICATION CORRESPONDENCE - C2010089 (10)
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2011-06-02_APPLICATION CORRESPONDENCE - C2010089 (10)
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Last modified
8/24/2016 4:34:06 PM
Creation date
6/3/2011 8:50:28 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C2010089
IBM Index Class Name
APPLICATION CORRESPONDENCE
Doc Date
6/2/2011
Doc Name
Response to Preliminary Adequacy Review
From
Western Fuels Association
To
DRMS
Email Name
MLT
SB1
Media Type
D
Archive
No
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predisturbance area since it is already the approved revegetation success standard of the Big <br />Sagebrush vegetation type at the NI-12 Mine." The Division believes the sentence should be <br />"Based upon this comparison, WFC feels justifies [sic] in proposing to use the existing <br />Dryland Pasture Reference area [sic] since it is already the approved revegetation success <br />standard of the Big Sagebrush vegetation type at the NI-12 Mine." If this statement is <br />correct, please make appropriate changes to the text. <br />Response: The DRMS is correct, and the sentence will be changed to read as <br />recommended. <br />8. Vegetation Success, Dryland Pasture, page 32 - The last sentence of the third paragraph <br />states "based upon this comparison, WFC feels justified in proposing to use the existing <br />Dryland Pasture Reference Area as a success standard for the Dryland Pasture <br />predisturbance area. The division [sic] feels that the sentence should say "Based upon this <br />comparison, WFC feels justified in proposing to use the existing Dryland Pasture Reference <br />Area as a success standard for the Dryland Pasture predisturbance area in the NHN area <br />since it is already, the approved revegetation success standard of the Dryland Pasture <br />predisturbance area at the NI-12 Mine. <br />Response: WFC agrees with the changes recommended by the DRMS and the subject <br />sentence will be changed as recommended. <br />9. Section 2.05.4(2)(e), page 10 - Attachments 2.05.4(e)-I Irrigation Design and Application <br />Rates and 2.05.4(2)(e)-2 are not in the PAP. Please submit a copy of each of these charts to <br />the Division. <br />Response: The document for Attachment 2.05.4(e)-1 will be submitted once the design is <br />completed The documents for Attachment 2.05.4(2)(e)-2 are included with this response. <br />2.04.11- Fish and Wildlife Resources Information <br />1. The text of section 2.04. 11 states that fish and wildlife data collected during previous studies <br />in the vicinity of the NHN Mine is sufficient such that further field studies are not <br />warranted. Two studies are summarized in the text: 1) 1979/80 by Mariah Associates <br />[baseline for PCC's Nucla (later NHI) Mine]; and 2) 1987/88 by PCC [baseline for PCC's <br />Nucla East (NI-12) Mine]. Summarizing the surveys in the text is acceptable, but the reports <br />themselves must also be included in the PAP. Please include copies of all referenced <br />wildlife surveys, including maps, in the PAP. <br />Response - The determination that the wildlife information previously collected from the <br />NHI and NH2 Mine areas would be adequate for the proposed NHNMine is based upon <br />the direction given to WFC by Mr. Jim Garner and Mr. Tony Bonacquista of the <br />Colorado Division of Wildlife (CDO99 in a wildlife consultation meeting held in Nucla <br />on June 15, 2009. <br />The Mariah report is being submitted as Appendix 2.04.11-1. The 1987/88 report by PCC <br />could not be located. Asper February 11, 2011 discussion with DRMS, the reference to <br />this report in the text of Section 2.04.11 has been deleted <br />Response to First Adequacy Review Page 26
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