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2011-05-26_APPLICATION CORRESPONDENCE - C2010088
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2011-05-26_APPLICATION CORRESPONDENCE - C2010088
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Last modified
8/24/2016 4:33:49 PM
Creation date
6/22/2011 10:17:38 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C2010088
IBM Index Class Name
Application Correspondence
Doc Date
5/26/2011
Doc Name
Preliminary Adequacy Review
From
Brock Bowles
To
Mike Boulay
Email Name
MPB
BFB
SB1
Media Type
D
Archive
No
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Page 2 of 4 <br />25a. Map 3, Permit Area Vegetation Map — The entire permit area is not included on the map. The <br />borrow pit area on the south side of the permit boundary and the haul road have been cut off <br />Please submit a new map that includes the entire permit area including the entire haul road. <br />26. Item Resolved. <br />27. On page 4 -6 of Exhibit 5, the procedure for ensuring randomly located sample locations is <br />described. The sampling sequence in the pre- disturbance area is sequential. Therefore, our <br />assumption is that transects in the reference area would also be sequential to maintain random <br />selection. This was not the case for cover and woody plant density sampling within the <br />Greasewood Reference Area where transects 1 -24, 29, 33, 37, 39, 40, 42, 44, and 46 -50 were <br />measured. By looking at these sampled transects, it appears that sampling started out <br />sequentially but became selective after #24, yet, in the predisturbance areas, transects were <br />sampled for cover and shrub density sequentially, 1 through 25. The Division does accept "both <br />random and systematic (selective) sampling designs" as per Rule 4.15.11(1), but also requires <br />"consistency in sampling." The explanation given in the last adequacy response does not clarify <br />the issue as to whether the transect selection was unbiased. Please provide an explanation within <br />the appropriate section of Exhibit 5, explaining why cover data was collected sequentially in the <br />predisturbance area and sequentially /selectively in the reference area to meet sample adequacy. <br />27a. The legal applicant for the Fruita Unit Train Loadout is CAM- Colorado LLC as listed on page <br />2.03 -1. Rhino Energy is referred to in Exhibit 5 on Page 5 and tables 10 -3, 10 -9 and 10 -10. <br />Please amend the text to refer to CAM — Colorado LLC for clarity and to prevent confusion. <br />27b. The transect lines on Map 5 of Exhibit 5 are difficult to see. Please submit a new version of Map <br />5 that has clearly visible transect lines against the background photo. <br />27c. Transect LGRRA -34 on Map 5 is not completely in the reference area. The east end of the <br />transect crosses the stream and continues into a riparian area. Is this accurate or is it a mapping <br />error? <br />27d. The column and /or row headings in tables 10 -4, 10 -5, 10 -6 and 10 -13 were cut -off Please <br />correct the tables so the headings are legible. <br />28. Item Resolved. <br />29. Item Resolved. <br />30. A thorough and detailed description of Alkali seepweed and Gray Molly was included in the <br />adequacy response. Many reliable sources were quoted giving credibility to the fact that the <br />plant in question could be Gray Molly. What lacked in the adequacy response was a detailed <br />description, photograph or a dried specimen of the plant species in question from the Fruita <br />Loadout site. Without knowing what the species in question actually looks like, the Division <br />
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