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2012-05-14_REVISION - C1981019
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2012-05-14_REVISION - C1981019
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Last modified
8/24/2016 4:57:41 PM
Creation date
5/15/2012 7:25:32 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981019
IBM Index Class Name
Revision
Doc Date
5/14/2012
Doc Name
Preliminary Adequacy Memo (Emailed)
From
Janet Binns
To
Rob Zuber
Type & Sequence
RN6
Email Name
RDZ
JHB
DIH
Media Type
D
Archive
No
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Post-mining land use –Rangeland and wildlife habitat. <br /> <br />4.Permit page 2.05-20 and 2.05-21 appear to duplicate the same information. Please <br />consolidate this discussion. <br /> <br />5.Page 2.05-23 states that that the wildlife PMLU is targeted for at least 20% of the Post- <br />2008 reclamation, “with the goal of achieving success on at least ½ of this acreage”. <br />CCC’s goal should be achieve reclamation success on 100% of the lands reclaimed. <br />Please explain how achieving reclamation success on 50% of a reclaimed community <br />meets the requirements of Rules 4.15.1(1), 4.15.1(2), 4.15.8(1), and Section 34-33- <br />120(2)(s) of the Act. <br />CCC states that success criteria of only meeting reclamation success criteria on 50% of <br />the Post-2008 acreage established to Sagebrush steppe is also stated on page 4.15-29. <br />Since the cover and production criteria are already depressed for the reclaimed Sagebrush <br />steppe community. If the reclaimed Sagebrush steppe community fails to meet the <br />reclamation success criteria on ½ of the reclaimed are, would CCC use the grazingland <br />success criteria to determine reclamation success on those portions of the logical <br />management unit that fail to meet Sagebrush steppe criteria? <br /> <br />6.Page 2.05-26 states, “At the appropriate time post TR-72 approval (by August 2012, a re- <br />evaluation will be conducted to resolve any issues involving pre and post mining land <br />uses, AVF status, reclamation plan, and AVF restoration of the essential hydrologic <br />functions for the Gossard Loadout area.” (TR-82 rev. 9/28/09) <br />Has this re-evaluation occurred? If so, this statement needs to be revised to reflect that <br />these issues have been re-evaluated. If not, RN6 is an appropriate time to re-evaluate <br />these concerns. <br />P. 2.05-28 Topsoil balances in the ARR. Section 11-commitment: <br />CCC has met the commitment of documenting topsoil stockpile volumes and topsoil balances in <br />Section 11 of the Annual Report for 2010 and 2011 in accordance with the permit commitment. <br />No response is required form CCC. <br /> <br />7.On permit page 2.05-40 (TR-82 rev. 9/28/09), CCC makes the declaration, “Given the <br />significant and nearly ubiquitous failures regarding the establishment of shrubs, the only <br />technique for use at the Colowyo mine that holds any reasonable promise for success is <br />direct seeding. Therefore, all previous shrub-metrics indicated for use at the Colowyo <br />mine are hereby remanded.” <br />This declaration is counter to the approvals achieved between CCC, DRMS and P&W <br />(formerly DOW) with TR84 (approved 7/15/2011) and the subsequent installation of the <br />tall shrub/aspen study plots. Please remove this statement on pages 2.05-40 and 41 to <br />minimize conflict with permit commitments approved in permit section 4.15. <br /> <br />RECLAMATION COST ESTIMATE: <br />CCC updated the Reclamation Cost Estimate (RCE) during TR81 (approved 6/29/2011). <br />2 <br />
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