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2012-07-30_REVISION - C1981019 (3)
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2012-07-30_REVISION - C1981019 (3)
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Last modified
8/24/2016 5:04:21 PM
Creation date
8/6/2012 1:31:30 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981019
IBM Index Class Name
REVISION
Doc Date
7/30/2012
Doc Name
Preliminary Adequacy Review
From
Colowyo Coal Company
To
DRMS
Type & Sequence
RN6
Email Name
RDZ
DIH
Media Type
D
Archive
No
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COAL <br />•COMPANY <br />b. Permit page 2.05 -20 and 2.05 -21 appear to duplicate the same information. <br />Please remove this redundancy. <br />Response: This issue is likely the result of a repagination error. Colowyo has <br />corrected the issue and is including a new Section 2.05 in its entirety. The <br />Divisions copy of Colowyo's PAP still includes Table 2.05 -3 — Equipment List <br />(handwritten page numbers 5a and 5b) which are not correct. It appears <br />under MR -105 the Division inserted Table 2.05 -3 into the wrong location in <br />the text and not within the tables section of Volume 1. Additionally, Section <br />heading 2.05.4 is a duplicate and the duplication has been eliminated under <br />this replacement. This entire replacement of Section 2.05 allows the <br />Division's version of 2.05 (with the removal of Table 2.05 -3 and duplicate <br />2.05.4 Introduction) and Colowyo's version to match correctly. Pagination has <br />been updated throughout the entire section. <br />c. Page 2.05 -23 states that that the wildlife PMLU is targeted for at least 20% of <br />the Post -2008 reclamation, "with the goal of achieving success on at least <br />half of this acreage." CCC's goal should be to achieve reclamation success on <br />100% of the lands reclaimed. Please explain how achieving reclamation <br />success on 50% of a reclaimed community meets the requirements of Rules <br />4.15.1(1), 4.15.1(2), 4.15.8(1), and Section 34- 33- 120(2)(s) of the Act. CCC <br />states that success criteria of only meeting reclamation success criteria on <br />50% of the Post -2008 acreage established to Sagebrush steppe is also stated <br />on 4.15 -29. The cover and production criteria are already depressed for the <br />reclaimed Sagebrush steppe community. If the reclaimed Sagebrush steppe <br />community fails to meet the reclamation success criteria on half of the <br />reclaimed area, would CCC use the grazing land success criteria to determine <br />reclamation success on those portions of the logical management unit that <br />fail to meet Sagebrush steppe criteria? <br />Response: The process for reaching agreement on the most recent update to <br />the current reclamation plan identified collectively for discussion purposes <br />here as Section 2.05.4 (Reclamation Plan) and Section 4.15 (Revegetation <br />Requirements) was a multi- stakeholder, multi -year process, beginning prior <br />to permitting efforts for PR -02. Ultimately, PR -02, TR -72, TR -82 and TR -84 <br />were fully vetted for compliance with the rules referenced above. As can be <br />observed on page 2.05 -25, Colowyo has specifically made "the commitment <br />to establish sagebrush steppe (comprised of both core and ecotonal areas) on <br />approximately 450 acres (minimum of 225 acres core) of the post -2008 <br />reclamation for the original and South Taylor permit areas, or as otherwise <br />agreed upon between Colowyo and CDRMS." In order for Colowyo to ensure <br />this happens, Colowyo has targeted most of the area that exhibits < 10% <br />slope to receive primarily shallow topsoil and a specific seed mix designed to <br />A Western Fuels-Colorado, LLC mitring property <br />
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