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• COLORADO <br />Division of Reclamation, <br />Mining and Safety <br />Department of Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Date: June 8, 2016 <br />To: Tabetha Lynch, DRMS <br />From: Jared Ebert, DRMS <br />RE: Keenesburg Strip Mine; C-1981-028, Permit Renewal RN7 — Review Memo <br />On May 5, 2016, I was requested to review portions of the Keenesburg Strip Mine permit application for <br />compliance with a number of the Rules listed in the May 5, 2016 e-mail. Below is a list of the Rules I <br />was requested to review, any adequacy review items that I identified are bulleted. Coors Energy <br />Company is here after referred to as CEC or Coors. <br />2.04.9(1)-(3) Soils Information <br />No adequacy review issues noted. The information required by this rule is discussed in section 2.04.9 of <br />the permit and the supporting data and maps are located in Appendix L-1 and L-2. <br />2.04.10(1)-(5) Vegetation Information <br />The information required by Rule 2.04.10(4) is not contained in Section 2.04.10(4) of the permit and has <br />been removed from the permit text. According to the permit, this information was removed and filed with <br />TR30. I looked through the Division's files for TR30 and this information could not be located. <br />According to Page 90 of the permit, Section 2.04.10(4) plant community measurements was <br />"removed and filed" with "Technical Revision 30; Historical Data" and then indicates the current <br />plant community measurements can be seen in Section 2.05.4 of the permit. Rule 2.04.10(4) <br />requires specific information to be included in the permit for baseline vegetation information. It <br />is unclear why this required information was removed from the permit and Section 2.05.4 of the <br />permit does not address the requirements of Rule 2.04.10(4). The Division requests that Coors <br />revise section 2.04.10(4) of the permit to include the information that was taken out and "filed" <br />with TR30. <br />I conducted a review of the potential threatened and endangered plants that could be found within the <br />permit area. Using the United State Fish and Wildlife Service's (USFWS) IPaC program on their <br />website, there are three endangered plant species that have the potential to be found within the permit <br />area. These species include Colorado Butterfly Plant, Ute Ladies' -tresses, Wester Prairie Fringed Orchid. <br />Based on the RN7 application, it does not appear the permittee is requesting to disturb additional land <br />within the permit boundary. If the permittee were to change their operation and that change results in <br />additional disturbance area, section 2.04.10(5) and 2.05.6(2) of the permit will need to be updated to <br />address the requirements of the corresponding rules. <br />Cp Coz <br />C <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us <br />John W. Hickenlooper, Governor I Mike King, Executive Director I Virginia Brannon, Director <br />