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2011-08-02_REVISION - C1982057
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2011-08-02_REVISION - C1982057
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Entry Properties
Last modified
8/24/2016 4:36:27 PM
Creation date
9/2/2011 9:51:59 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1982057
IBM Index Class Name
REVISION
Doc Date
8/2/2011
Doc Name
Response to Re-submittal Comments
From
Seneca Coal Company
To
DRMS
Type & Sequence
TR70
Email Name
SLB
SB1
Media Type
D
Archive
No
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• <br />• <br />• <br />11K-70, Aspen/ Woody Plant Density Standard <br />Page 2 <br />2. The following comments pertain to Exhibit 22 -1 Post Mining Vegetation Map: <br />a. Please include the abbreviations used to identify vegetation types on the map in `Undisturbed <br />Island and Border Area Vegetation Chart'. <br />b. Many different naming conventions are used to identify the shrub concentration areas but none <br />are consistently used throughout the map. Please re -label the shrub concentration areas using a <br />consistent labeling convention that includes: date of planting (proposed planting date for those <br />areas under areas still under construction), shrub community type and whether the area is fenced <br />or unfenced. <br />Response: Attached is a revised Exhibit 22 -1 that attempts to address your comment. <br />3. On page 58 the text says there are ten fenced shrub plots, but eleven are described. Please fix this <br />typo. <br />Response: The typo has been fixed. <br />4. Rule 4.15.8(7) requires that for areas with a wildlife postmining land use the minimum stocking <br />levels ....must be determined on the basis of local and regional conditions after consultation with <br />and approval by the Colorado Division of Wildlife (CDOW). Since Seneca is proposing a <br />reduction in the minimum stocking levels, the CDOW was consulted and reviewed the proposal. <br />CDOW's comments are in the attached letter. Please incorporate these comments into TR -70. <br />CDOW Comments <br />a. CDOW suggests that domestic livestock grazing be banned in reclamation areas to encourage <br />woody plant growth. While wildlife grazing may be difficult to control, we can and should <br />control livestock grazing in these areas. <br />Response: Experience and studies have shown that controlled grazing can actually promote increases in <br />woody stem density (see Tab 22, page 2 and Annual Revegetation Monitoring Reports, 2006, 2007, 2008, <br />2009, 2010). Data indicates that woody stem density can readily increase when the herbaceous <br />component is reduced or eliminated. <br />SCC has a grazing plan in place. SCC does not allow grazing to begin prior to mid -July (following <br />annual revegetation monitoring) and ends around October 1 depending on the pasture conditions and <br />weather. SCC sets the number of animals and grazing days allowed for each pasture or area based on past <br />production results obtained from vegetation monitoring results. This grazing plan has been accepted since <br />inception and the details are presented in each Annual Reclamation Report. <br />
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