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Rule 2.05 <br />4. The language at the end of ease 2.05 -6 is not consistent with the top of panes 2.05 -7 or <br />2.05 -7a. Please clarify the language. <br />Oxbow Response: Oxbow's page 2.05 -6 (modified for PR -05) appears consistent with page 2.05 - <br />7a (modified for PR -07). <br />5. Three different descriptions of the Elk Creek Coal Handling. Support and Ancillary <br />Facilities are located on vases 2.05 -7, 2.05 -7a and 2.05 -13. A fourth section labeled Elk <br />Creek Mine Facilities starts on vase 2.05 -21 and has many bulleted items that are <br />duplicates of the bulleted items on page 2.05 -13. Please update, combine and number <br />these sections /pages for consistency. <br />Oxbow Response: The current pages, while containing some redundancies, is intended to provide <br />details relative to the historic facilities starting in 1997 through 2003 facility modifications. <br />6. In Section 2.05.5 Postminine Land Use, page 2.05 -70, it states that the post mining <br />topography and land use are illustrated in Maps 2.05 -M6 through 2.05 -M8. Maps 2.05 - <br />M6 and 2.05 -M7 show the post mine topography with cross - sections and May 2.05 -MS is <br />no longer in the permit. There is no may throughout the permit showing the post - mining <br />land use for the Elk Creek Mine. Please submit a map showing the post mining land uses <br />that is consistent with the written descriptions on page 2.05 -70 and with the revegetation <br />plan. <br />Oxbow Response: Please see the attached Post - Mining Land Use Map 2.05 -M8, Sheet 1 of 2 and <br />2 of 2 showing the Permit area and highlighting the Upper Hubbard Site, the west valley road <br />access to the Potable Water treatment facility and Cemetery, the road leading up Elk Creek to the <br />Methane project, the East Elk Creek/Sanborn Creek road (old Highway 133) and Hubbard Creek <br />Fansite culvert. Otherwise all other areas are undeveloped rangeland/recreation/wildlife lands. <br />7. Some areas are designated as wildlife habitat and recreational use for the post mining <br />land use. These designated land uses require the establishment of woody plant species <br />according to Rule 4.15.8(7). In Exhibit 2.05 -E6 - Revegetation Plan, a standard for <br />cover, diversity and productivity are described but there is not a standard for woody plant <br />density. Please submit a revegetation standard for woody plant density or a letter from <br />the surface land owner(s) requesting that the woody plant standard be waived. <br />Rule 2.05.4 <br />Oxbow Response: Oxbow would disagree with the Division's interpretation of the subject Rule <br />that wildlife habitat and recreational use require the establishment of woody plant species. The <br />Rule merely sets forth requirements for successful demonstrations of woody plant establishment <br />efforts should they become part of a reclamation plan. Please see the attached May 23, 2013 <br />USFS letter, the June 05, 2013 BLM letter and the July 22, 2013 Hotchkiss Ranches waiving the <br />woody plant standards for the Elk Creek Mine. Oxbow mining also does not desire wody plant <br />establishment on its lands as well. It is no coincidence that landowners located in woody plant <br />• Page 2 <br />