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AV;COLORADO <br />Division of Reclamation, <br />I Mining and Safety <br />Department of Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />November 22, 2016 <br />Miranda Blomquist <br />Moffat County Mining, LLC. <br />29515 Routt County Road 27 <br />Oak Creek, CO 80467 <br />RE: Williams Fork Mines; C-1981-044; Technical Revision No. 37 (TR37) <br />Adequacy Review No. 1 <br />Dear Ms. Blomquist: <br />The Division has completed its preliminary review of TR 37. The revision was received on November 1, <br />2016, and found complete on November 9, 2016. The revision modifies the procedures of sampling <br />vegetation cover and production. Also, Moffat County Mining, LLC. (MCM) is proposing to revise the <br />revegetation success standard for the Utah Tact. MCM will need to address the following items prior to <br />approval of the revision. <br />1. Regarding herbaceous production sampling, please revise proposed revised page 2.05-33, the first <br />sentence of the third paragraph to indicate that within each sample plot only the current annual <br />growth of herbaceous species will be clipped in accordance with Rule 4.15.11(1)(b)(i). <br />2. The standard to be used to judge revegetation success for vegetation cover and productivity for <br />the Utah Tract is not clearly defined based on the proposed revision. The text would indicate <br />success will be based on a comparison of the reclaimed area to a reference area but then the text <br />indicates the revegetation success criteria for cover will be based on a proposed technical <br />standard. Also, a technical standard for productivity is discussed. Overall, the text is confusing <br />as to which standards will apply. Based on a meeting with Jerry Nettleton that occurred last year, <br />the Division assumes MCM would like to use the technical standards. Please revise the text to <br />clearly indicate what revegetation success criteria will be used for cover and productivity for the <br />Utah Tract. <br />It appears MCM would like to utilize a technical standard that is currently used at the adjacent <br />Trapper Mine (C-1981-010) to evaluate revegetation success at the Utah Tract in terms of <br />vegetation cover and productivity. This request is in accordance with Rule 4.15.7(2)(d)(v). <br />Based on this rule, such standards must be derived from statistically adequate samples collected <br />over a period of several years. Given this, the justification for using the proposed success <br />standard should be included in the permit application package. The Trapper Mine Permit section <br />4.4, specifically pages 4-101 to 4-111 discusses how these standards were developed from <br />historic data from 1979 through 1985. Please include a copy of these pages as a separate exhibit <br />Of' Coto <br />o <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 s 1876 <br />