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Mike Boulay <br />-29- July 8, 2011 <br />of clean fill. Please give a description of the fill material and how the wind <br />erosion potential of the site will be minimized. Also, Rule 4.15.1(3) is cited <br />incorrectly in the text. The correct rule is 4.15.10(3). Please fix this typo. <br />CAM - Please see text added to page 2.05 -30 that addresses how wind erosion will be <br />managed. The incorrect rule citation was fixed on page 2.05 -29. <br />71. Division Response: Response accepted. <br />72. Division Response: Response accepted. <br />73. Section 2.05.4(2)(e)(vi). It seems that CAM is not proposing to seed the disturbed <br />land /industrial portion of the permit area. If that is the case, please clarify and <br />address a gravel surface or other measures that will be used to control wind and <br />water erosion as required by Rule 4.15.10(3). <br />CAM Response: Please see discussion in section 2.05.4(1) for a discussion <br />regarding Rule 4.15.10(3). <br />Division response: This item has not been adequately addressed. Please see <br />comment 70 above and update the PAP accordingly. <br />CAM - Please see response to comment 70. <br />74. CAM is not proposing a woody plant density standard for revegetation success. <br />Per Rule 4.15.8(7), for areas with a post- mining land use of fish and wildlife <br />habitat, minimum stocking levels, planting arrangements, and methods for <br />mitigation of potential adverse impacts must be determined on the basis of local <br />and regional conditions after consultation with and approval by the Colorado <br />Division of Wildlife (DOW). CAM must provide a basis for not reestablishing woody <br />plants; and documentation that DOW has been consulted and that DOW approves <br />of no shrub standard must be provided. <br />CAM Response: Please see revised page 2.05 -36. Revegetation success criteria <br />for the woody plant density for rangeland and fish /wildlife areas will be based upon <br />the greasewood reference area. <br />Division Response: The language used to describe the woody plant density <br />standard is confusing and it is not clear if a reference area or technical standard <br />will be used for comparison to show success. The Division suggests that CAM <br />use only the approved greasewood reference area as a standard which <br />achieves 90% woody plant density of the approved greasewood reference <br />area sample mean at the 90% confidence level. <br />CAM - Examination of the Greasewood Predisturbance Area shrub density data found in <br />Table 2.04.10 -5, documents that the average shrub density of this area is 17.84 <br />