2017-06-05_REVISION - C2010089 (2)

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TRI-STATE GENERATION AND TRANSMISSION ASSOCIATION, INC. HEADQUARTERS: P.O. BOX 33695 DENVER, COLORADO 80233-0695 303-452-6111 June 1, 2017 Mr. Brock Bowles Environmental Protection Specialist Colorado Division of Reclamation, Mining and Safety RECEIVED 1313 Sherman Street, Room 215 Denver, CO 80203 JUN 0 5 2017 RE: New Horizon North Mine pMsion of Reclamation, Permit No. C-2010-089 Mining & satety Technical Revision No. 14 Dryland Reference Area Second Adequacy Response Dear Mr. Bowles: Tri-State Generation and Transmission Association, Inc. (Tri-State) is the parent company to Elk Ridge Mining and Reclamation, LLC New Horizon North Mine. The New Horizon North Mine operates under Division of Reclamation, Mining and Safety (DRMS) Permit No. C-2010-089. Tri-State received your adequacy review for TR -14 on April 25, 2017. Tri-State on behalf of the New Horizon North Mine has the following response to your comment: 1. ERMR submitted a statistical demonstration in its March 1, 2017 response showing that the proposed Old Peabody Sage RA is comparable to the baseline data of the disturbed dryland pasture area. After a review of the data, it was noted that the sample variance was not pooled' as required by Guidelines for Compliance with Land Use and Vegetation Requirements of the CMLRB for Coal Mining, Oct 1988. ERMR was contacted by a phone call on March 20 to discuss the miscalculation. ERMR re- calculated the reference area statistical comparison with the pooled variance and re- submitted the data in a March 20 email. The updated calculations demonstrated that the cover values of the two areas are not statistically comparable. The production values remained comparable. The perennial cover of the dryland reference area was significantly greater at 25.15% than the dryland pasture baseline cover which was 16.67%. ERMR is proposing to use the dryland reference area as the reclamation standard for the dryland pasture reclaimed areas even though the two areas are not statistically comparable. The Division agrees with the philosophy of reclaiming the land to a capacity greater than what existed before disturbance, but it also does not want to approve a standard that may be unachievable. Please submit a discussion, for inclusion in the permit, which provides justification for a reclamation cover standard that is significantly greater than the baseline cover value. Response: Section 4.0 in Attachment 2.04.1 OC has been updated with a justification to accept a reclamation cover standard that is greater than the baseline cover value as requested. AN EOUAL. OPPORTUNI F Y /AFFIRMATIVE ACTION EMPLOYER A Touchstone EnerWCooperative O>i CRAIG STATION ESCALANTE STATION NUCLA STATION P.O. BOX 1307 P.O. BOX 577 P.O. BOX 698 CRAIG, CO 81626-1307 PREIMTT, NM 87045 NUCLA, CO 81424.0698 970-824-4411 505-876-2271 970-864-7316