2013-09-09_REPORT - C1981014

• Permit No: C1981014
• IBM Index Class Name: Report
• Doc Date: 9/9/2013
• Doc Name: DRMS response to Linda Saunders vegetation sampling questions e-mailed 9/2/2013.
• From: DRMS
• To: George Patterson
• Permit Index Doc Type: Reveg Monitoring Report
• Email Name: JHB
• Email Name: DIH
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
C O L O RA D O
D I V I S I O N o f
Denver, Colorado 80203
RECLAMATION
Phone: [phone]
M IN I NIN G
N
FAX: [phone]
SAFETY
September 9, 2013
John W. Hickenlooper
Governor
Linda Saunders
K2T
Mike King
Executive Director
34315 Forest Park
Elizabeth CO 80107
Loretta E. Pineda
Director
Re: Southfield Mine (Permit No. C- 1981 -014)
DRMS response to Vegetation Sampling Questions e- mailed September 2, 2013
Dear Ms. Saunders:
On September 2, 2013 you e- mailed questions to the Division regarding planned vegetation monitoring at the
Southfield Mine. September 2, 2013 was a State Holiday, so I did not received your e -mail until September
3, 2013.
Your e -mail, dated September 2, 2013, questions statements made in the Division's July 19, 2013 memo to
EFCI regarding proposed reclamation success sampling. The July 9, 2013 memo was in response to a scope
of work memo that EFCI had sent to the Division on July 19, 2012. In 2012, EFCI chose not to sample the
vegetation for reclamation success due to droughty conditions in 2012, but chose to conduct the vegetation
sampling in 2013.
EFCI has an approved sampling plan in the Southfield permit. As the July 9, 2013 memo states, "The scope
of work appears to follow the approved sampling methods described in the Southfield permit."
"The Division also concurs that shorter transect lengths may be preferred in certain instances. If the operator
conducts the sampling consistently, with random transect location and direction, and the data are collected to
sample adequacy as defined in Rules 4.15.11(2) and (3), a shorter transect length is acceptable. (Rule
4.15.11(1)(a)(1) allows for cover transects to be a minimum of 5 meters in length.)"
As you are aware, the Plot B reference area is extremely small for a vegetation reference area. It would be
highly unlikely to randomly distribute a minimum of fifteen 50 Meter long transects in the Plot B reference
area without overlapping transects, and potentially double sampling individual plants. A better solution in a
small area is to reduce the length of the transects. This could result in the operator needing to collect a larger
number of transects in order to meet sample adequacy. The Division recommends operators collect a
minimum of 15 transects even if adequacy is achieved with fewer samples (DRMS Guideline Regarding
Selected Coal Mine Bond Release Issues, April 18, 1995).
The operator will submit maps showing the start point locations of the vegetation sampling transects at the
time they submit the vegetation sampling report to the Division. The maps will include sampled reclaimed
areas as well as all sampled reference areas. At this time the Division does not know when the operator will
submit the 2013 vegetation sampling report. When it is submitted to the Division, the report will be scanned
into laserfiche and available to the public. EFCI's scope of work discussion is available on laserfiche. The
proposed sampling plan is in accordance with the Southfield permit and the Regulations.
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Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines