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Colowyo, C1981 -019, PR3 adequacy No. 3 12 July 22, 2011 <br />application. Please provide the detail required by Rule 2.05.3(6). Please state which seed mix <br />CCC will employ for temporary overburden stockpile stabilization (Collom -Rule 2, page 99). <br />CCC has provided the requested information. This item has been adequately addressed. <br />Rule 2.05.4(2)(b) Reclamation Costs and Rule 3 Performance Bond <br />Colowyo Coal Company has not provided a reclamation cost estimate for the Collom expansion area at <br />this time. As mine plan details are finalized, a reclamation cost estimate is required to be submitted <br />and incorporated into the permit. <br />CCC has noted that CCC will provide this information to the Division. A detailed Reclamation Cost <br />Estimate is still required to be submitted for the Division's review. <br />CCC has provided a reel amation cost estimate in Exhibit 13B. The Division is rcvicicing CC( <br />r t he Dik is ion's ommients rceardiuL CC(,, Cstimate kill be sent to CCC io a sepur,ue lclwf. <br />Rule 2.05.4(2)(e) Reclamation Plan <br />1. It is not clear in Section 2.05.4(2)(e) of PR -3 if the reclamation standards apply to the Collom <br />expansion area, the Colowyo Mine or both. Please insert a statement at the beginning of this <br />section indicating that all standards stated within PR -3 Collom Expansion Area are only for the <br />Collom Expansion Area and do not effect or change the existing reclamation procedures, <br />standards or timing of the Colowyo Mine. <br />This item has been adequately resolved. <br />2. Page 106, first paragraph — The text explains that the final grading of the mine will result in <br />approximately 20% to 40% of the terrain with a slope less than 10 %. In contrast, the graph on <br />Map 19D indicates that the percent of final grading with a slope less than 10% is approximately <br />37 %. It is understandable that a certain amount of error exists in the mapping due to the 100 <br />foot by 100 foot grids used in the percent slope calculations, but it would be logical that the <br />error be more evenly distributed around the mean 37 %. The Division suggests that a target of <br />37% of the terrain have less than a 10% slope with a margin of error +/- 2 %. If it is determined <br />during the reclamation process that a 10% slope on 37% of the terrain is not possible, the <br />Division and Colowyo will then determine an appropriate percentage of terrain with a slope <br />less than 10% through a technical revision. <br />Page 108, third paragraph —The Division is not proposing an "additional" target to the PMT as <br />suggested in Colowyo's response. The graph on Map 19D documents the PMT with a slope <br />less than 10% will be 37 %. The permit text needs to accurately reflect this standard set by - <br />Colowyo. The commitment to "attempt in earnest on approximately 20% (or more) of the <br />reclaimed landscape, with the goal of achieving success on at least one -half of this acreage," is <br />inadequate for wildlife habitat. In a letter dated Feb 22, 2011, the US Fish and Wildlife Service <br />expressed concern that "approximately 20 percent of the expansion area to sagebrush would <br />fall short of the site's original condition and potential," which could impact local sage - grouse <br />