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INTEROFFICE MEMORANDUM <br />TO: <br />ZACH TRgILLO <br />FROM: <br />JANET BINNS <br />SUBJECT: <br />DESERADO MINE C1981 -018, MR -154 <br />DATE: <br />8/10/2012 <br />CC: <br />I have reviewed Blue Mountain Energy's (BME) application for a minor revision to the <br />Deserado Mine permit (MR -154). Specifically, I have reviewed the proposed changes to <br />Seed mixes V -10 and V -11. <br />Changes to seed mix on Table V -10 entail eliminating Crested wheatgrass, eliminating <br />Sand dropseed and Smooth brome, and adding Canada wildrye (Elymus canadensis)to the <br />mix. Canada wildrye is an acceptable addition and meets the requirements of Rule <br />4.15.2. BME also proposes to reduce the seeding rate of Rubber Rabbitbrush slightly. <br />The Division finds these changes acceptable. <br />BME also proposes changes to Table V -11 seed mix. BME proposes to remove Crested <br />wheatgrass, Smooth brome and Sand dropseed from this seed mix, as well as reduce the <br />rates for Thickspike wheatgrass, Desert wheatgrass, and increase the seeding rates for <br />Western wheatgrass, Bearless bluebunch wheatgrass and Bluebunch wheatgrass <br />(Psuedoroegeneria spicata). These proposed changes are acceptable to the Division. <br />Of note, page V -35 in the PAP states that, "the locations for which these mixes [seed <br />mixes] apply are further explained on Table V -15." Table V -15 provides detail on the <br />Revegetation success criteria and does not indicate which seed mix is used on which <br />reclamation area. I was unable to locate where BME defines when Table V -10 seed mix <br />is used during reclamation efforts and when Table V -11 seed mix is used. Table V -11 <br />seeding rate is significantly lower than Table V -10 rate. Please have BME direct the <br />Division to where it is defined which seed mix will be used for reclamation areas, or <br />clearly define the appropriate seed mix per reclamation area. <br />