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Kurtis Blunt. Colowyo Coal Company <br />May 15, 2012 <br />Page 2 <br />2. Discrepancies with Areas <br />There are some discrepancies between the amount of acres in the RN -06 application (page 3) and <br />values in the Division's Permit System (see decision form for TR -94). Please work with the <br />Division to resolve the following: <br />a. Surface ownership (Federal) — is the correct value 2,373 acres or 2,290.19 acres? <br />b. Surface ownership (Private) —is the correct value 9,238 acres or 9,320.76 acres? <br />c. Disturbed area - is the correct value 4,800.6 acres or 4,766.3 acres? <br />3. Reclamation Plan <br />a. Regarding the new Table 2.03 -1 submitted with RN -06, please explain why there is much <br />more reclaimed area than disturbed area in the total row at the bottom of the table. <br />b. Permit page 2.05 -20 and 2.05 -21 appear to duplicate the same information. Please remove <br />this redundancy. <br />c. Page 2.05 -23 states that that the wildlife PMLU is targeted for at least 20% of the Post -2008 <br />reclamation, "with the goal of achieving success on at least half of this acreage." CCC's goal <br />should be to achieve reclamation success on 100% of the lands reclaimed. Please explain <br />how achieving reclamation success on 50 % of a reclaimed community meets the <br />requirements of Rules 4.15.1(1), 4.15.1(2), 4.15.8(1), and Section 34- 33- 120(2)(s) of the Act. <br />CCC states that success criteria of only meeting reclamation success criteria on 50% of the <br />Post -2008 acreage established to Sagebrush steppe is also stated on page 4.15 -29. The cover <br />and production criteria are already depressed for the reclaimed Sagebrush steppe community. <br />If the reclaimed Sagebrush steppe community fails to meet the reclamation success criteria <br />on half of the reclaimed area, would CCC use the grazing land success criteria to determine <br />reclamation success on those portions of the logical management unit that fail to meet <br />Sagebrush steppe criteria? <br />d. 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 uses, <br />AVF status, reclamation plan, and AVF restoration of the essential hydrologic functions for <br />the Gossard Loadout area." (TR -82 rev. 9128109) Has this re- evaluation occurred? If so, this <br />statement needs to be revised to reflect that these issues have been re- evaluated. If not, RN6 <br />is an appropriate time to re- evaluate these concerns. <br />e. 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 direct <br />seeding. Therefore, all previous shrub- metrics indicated for use at the Colowyo mine are <br />hereby remanded." This declaration is counter to the agreement between CCC, DRMS and <br />Parks and Wildlife (please see TR84, approved 7/15/2011) and the subsequent installation of <br />the 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 />