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2013-07-02_REVISION - C1981012
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2013-07-02_REVISION - C1981012
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Last modified
8/24/2016 5:22:10 PM
Creation date
7/3/2013 9:32:16 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981012
IBM Index Class Name
REVISION
Doc Date
7/2/2013
Doc Name
Letter Application and Public Notice
From
Gorham Energy Consultants, LLC
To
DRMS
Type & Sequence
TR68
Email Name
LDS
DIH
Media Type
D
Archive
No
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Informational Exhibit A <br />Kent, <br />Mike Trujillo reviewed your comments and replied that he's comfortable moving forward with the new <br />reclamation plan. <br />Please let us know how we can help. <br />Al <br />On Fri, Jan 11, 2013 at 11:00 AM, <kent(,z)gorharnener- consultants.com> wrote: <br />Thanks everyone for meeting with us on Thursday at the New Elk mine to review possible changes to the <br />post- mining land use and the revegetation plan. In attendance representing the CPW were Al Trujillo, Bob <br />Holder, and Bill Velarde. Representing GEC on behalf of NECC were Kent Gorham and Austin Gorham. <br />Our 3.5 hour field visit included site inspection of the following areas; <br />• River relocation riparian area north and west of the prep plant <br />• Pond 7 riparian post- mining land use area (and AML tailings reclamation project to the north) <br />• Pond 4 riparian area <br />• Pond 8 and lower RDA outslope reclaimed some 25 years ago with tubling transplants <br />• West mine area slated for the recently approved DWDA #3 <br />Our discussion included an explanation of the current plan for the three post- mining land uses of rangeland, <br />upland wildlife habitat(32 acres), and riparian wildlife habitat(11 acres) for both seed mix and shrub re- <br />establishment. We also discussed the perceived problems with the current plan, mainly focused on <br />the deficiencies related to tubling transplants and expectations of very limited success without specific <br />methods and treatments, which are currently lacking in the approved plan. We also evaluated the <br />possibility for permanent retention of pond 4 on CPW property and also pond 8 on NECC property. <br />There was general agreement among all parties that the current plan of planting tublings every 25 square <br />feet over the 43 total acres of upland and riparian wildlife habitat has very little chance of long -term <br />success. However, CPW staff believes establishing shrubs is important and a necessary component of the <br />revegetation plan. In was noted during our discussions that proposed changes to the Division coal rules <br />modify the definition of rangeland to mean "land where the land use is a combination of grazingland and <br />fish and wildlife habitat." <br />Without any firm commitment, CPW is conceptually in favor of reviewing a change to the revegetation <br />plan that includes a plan to re- establish shrubs on the reclaimed area in clumps, using specific techniques to <br />ensure the greatest chances of success including clump location and orientation, species selection based on <br />area and location, fencing, weed mats, limiting grass and forb competition, and irrigation in the early stages <br />of replanting. There was also general agreement that the retention of pond 4 and pond 8 for wildlife <br />benefits could be beneficial. The group also agreed that a review of the currently approved seed mix, which <br />includes shrub species, is appropriate to be as consistent as possible with CPW land use plans. <br />Regarding the concern raised during our meeting related to disposal of drilling fluid in pond 4, following <br />our meeting, I spoke with Ron Thompson of NECC. According to Ron, pond 4 was chosen for <br />this approved activity due to its large size (sized for the 100 -year storm), the fact that it seldom holds <br />significant water, and because it has never discharged in the 25 -30 year life of the pond. Drilling at the <br />12303 Airport Way Ste 200 - Broomfield CO 80021 • Phone: 303.327.1525 • kent @gorhamenergyconsultants.com 10 <br />
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