2011-12-07_REPORT - C1981022

• Permit No: C1981022
• IBM Index Class Name: REPORT
• Doc Date: 12/7/2011
• Doc Name: 2009 & 2010 ARR Ressponse to Nov 21, 2011 Adequacy Review Letter
• From: Oxbow Mining, LLC
• To: DRMS
• Permit Index Doc Type: Annual Reclamation Report
• Email Name: BFB
• Email Name: SB1
• Media Type: D
• Archive: No

OXBOW MINING, LLC
December 1, 2011
Mr. Brock Bowles
Environmental Protection Specialist
Colorado Division of Reclamation, Mining and Safety
1313 Sherman St., Room 215
Denver, Co. 80203
Re: 2009 and 2010 Annual Reclamation Reports
Response to November 21, 2011 Adequacy Review Letter
Permit C- 1981 -022, Oxbow Mining, LLC
Dear Mr. Bowles:
• Page 1
3737 Hwy 133 P.O. Box 535 Somerset, Colorado 81434 USA Tel [phone] Fax
(970)929 -5177
R SCSINIes o
OEC 0 72011
Division of - eclamation,
Mining and Safety
The following information provides a response to the Division's November 21, 2011 Adequacy
Review of the 2009 and 2010 Annual Reclamation Reports (ARR) for Oxbow Mining, LLC.
1. Pacific Aster (Aster chilensis) — Granite seed has found that collections of this seed have
not been available for at least 3 years and did not recommend a suitable alternative.
2. The approved seed mix contains American Vetch, (Vicia americana) a native legume.
Unfortunately, the availability of the species is in very short supply and Granite seed could not
fulfill our needs. Canadian milkvetch (Astragalus canadensis) is also a legume native to
Colorado and was substituted in order to cover the shortfall in the American vetch. Granite seed
recommended the legume species as a suitable alternative and Oxbow believes it was important
to avoid shorting the nitrogen fixing component of the seed mix.
In general, Granite Seed indicates the availability of native seed sources are often variable and
depend on uncontrollable factors such as annual precipitation and the uncertain success of native
seed collections. Native forb seed in particular is often very difficult to obtain. Where needed,
Granite seed will recommend suitable alternative native species as substitutions.
3. Apparently, the Division used the weights presented in the "Total Bulk Lbs" column to
arrive at the formulation of this comment (27.25 bulk lbs/180.74 bulk lbs x 100 = 15.08 %).
Rather, the correct method is to use the weights found in the "Total PLS Lbs" column. For
example, the 8/23/2010 shipment indicated that the Rubber Rabbitbrush in the mix was 3.8% (5
pls lbs/131.42 pls lbs x 100 = 3.8 %). Because the purity and germination of seed is so variable,
the appropriate method is to analyse PLS lbs. rather than Bulk lbs.