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Memorandum To: Byron Walker From: Janet Binns Date: 06/03/200 Re: Colowyo 2003 ARR File: C:/jhb/team/Colowyo/2003 ARR.doc I have reviewed Colowyo's 2003 Annua- Reclamation Report and your Interoffice Memo regazding Colowyo's 2003 ARR, received by DMG on March 25, 2004. Colowyo reports 120.0 acres of new disturbance in 2003, 7.2 acres were backfilled & graded in 2003, 7.2 acres were topsoiled in 2003, and 69.8 acres were seeded. The operator included a table of all reclamation, year of reclamation, status of phased bond release per parcel, along with notes specific to certain pazcels. This type of a table is invaluable to tracking the status of the reclamation parcels throughout a complex operation the size of the Colowyo mine. The Division encourages the operator to continue to maintain this table in future years. Though this table is not required by the Regulations, continued inclusion of this table, Exhibit 3B, Colowyo Reclamation Table, in future ARRs will aid the Division's review of ARRs and future bond release applications. Weed Mana ement: Colowyo documented that weed management measures were conducted in 2003. Herbicides applied included: Tordon, 2,4-D, and Roundup. Inclusion of the areas sprayed on the Annual Reclamation map allows the operator and the Division to track the effectiveness of the weed management efforts. Please include the location of weed management efforts on future Annual Reclamation Report maps. Approved seed mixes and seed mix applied. Colowyo states that no new seed was purchased in 2003. Seed purchased in 2002 was used for the 2003 seeding efforts (2003 ARR Section 4). Due to the limited seed availability in 2002 as a result of the state-wide drought in 2002, and the question of seed viability of seed stored for over a year, the Division questions Colowyo's practice of ordering excessive amount of seed when many substitutions needed to be made to the approved seed mix, then using this excess year-old seed to seed the 2003 reclaimed areas. A visual evaluation of the 2003 seeded areas should be conducted during the 2005 growing season to determine germination and establishment success of these areas. Colowyo did not provide information defining the amount of seed seeded in 2002 or the amount of seed seeded in 2003. The invoice tags provide a total quantity for the seed delivered in 2002. Assuming that all of the seed delivered in 2002 was used between 2002 and 2003, the Division can calculate if the appropriate seeding rates were used over the two-yeaz period. The seed bags provide a bit more information regazding the bulk and PLS quantity of seed, however, nowhere does Colowyo report how many bags (or pounds) of seed were used each year. Nor do they state that they used all the bags over the two-yeaz time period. The operator needs to indicate how much seed was applied to the reclaimed areas on an annual basis.