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Colowyo, C3981 -019, PR3 adequacy No.3 13 July 22, 2011 <br />populations. Please amend the text to accurately reflect the 37% standard proposed by <br />Colowyo with a smaller margin of error (ex, t 2 -3 0/6). <br />CCC has provided a statement in Section 2.05.4 that indicates that approximately 30 %. of the <br />disturbed Collura acreage will be reclaimed to the sagebrush steppe requirements. The <br />Division accepts this response. <br />3. Page 108, third paragraph β€” When situations arise that require Colowyo to deviate from the <br />approved reclamation plan, the Division needs to be contacted before any action is taken. The <br />Division feels that an adequate amount of flexibility is built into the Division's permitting and <br />inspection system that allows for "on-the-ground" reality. The Division makes monthly mine <br />inspections with mine personnel to discuss various issues of which include reclamation <br />progress. During these routine inspections, mine personnel have the opportunity to discuss <br />reclamation operations and any foreseeable shortcomings in the permitted/approved design. If <br />the mine reclamation specialist and the Division feel that a revision is warranted because of an <br />unforeseen/unplanned "on-the-ground" reality, then a revision to the permit will be submitted <br />to the Division at that time. The Division requests therefore, that this paragraph be removed <br />from the permit. <br />Page 118, last paragraph β€”The additional language added to this paragraph does not add <br />clarification as to when deviation from the permit is acceptable. The Division reaffirms its <br />position that when a situation arises that requires Colowyo to deviate from the original permit, <br />the Division needs to be contacted before any action is taken. An adequate amount of <br />flexibility is built into the permitting and inspection system that allow for "on-the-ground" <br />reality. The Division requests that this paragraph be removed from the permit. <br />The Division uaxpts CCC's response <br />4. Page 110 β€” Colowyo is proposing to use two different seed mixes for the reclamation of the <br />entire Collom expansion area. Due to the fact that the Collom mine encompasses a landscape <br />with many different plant communities, land aspect, soil types, elevations, slope gradients and <br />soil moisture availability, the Division feels that a more diverse approach be used to address the <br />various topography and resource availability to plants at the site. There should be a seed mix <br />designed for topsoil stock piles, overburden stock piles, steep slopes, bottomlands, sage brush <br />steppe (already designed), mountain shrub habitat and grasslands. This reclamation approach <br />will yield better results for species diversity, cover, production and stem density rather than two <br />`diverse' seed mixes. <br />Page 113 β€” Colowyo's response addresses the concerns of seed mixes for temporary structures <br />used during active mining, but does not address the discussion of how "one seed mixture is <br />capable of self - selection for each micro- habitat encountered in the reclaimed areas" (Volume <br />15, Rule 2, page 111). The proposed seed mixture listed in Table 2.05 -7 contains 15 species <br />while the Collom Expansion Area has 6 major vegetation communities and 4 minor vegetation <br />communities with 2 sub -types (mesic and xeric). Please breakdown the seed mix to explain <br />which species are appropriate for each of the various reclaimed vegetation types, and provide <br />evidence of other reclamation projects where a single seed mix met all the revegetation <br />