2019-12-27_REVISION - C1981035 (6)

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S.Vance,T. Bird Page 2 of 3 December 27,2019 Colorado Mined Land Reclamation Board for Coal Mining-October, 1988", as found on the Division's website. We believe the operator is referring to the statement on page 3 of the guidelines, describing sampling for major and minor plant communities; `B. Major and Minor Communities: The Division generally requires quantitative sampling only within major vegetation communities. Quantitative sampling and reference areas (or other success standards) are usually not required for minor communities (those communities whose total aggregate area occupies less than 5% of the permit area or less than 10 acres, whichever is smaller). Such communities should be qualitatively described in the permit application." The proposed disturbance within the Pinyon-Juniper vegetation community is estimated to be 0.17 acres for MR50. The Pinyon-Juniper community was qualitatively described in the 2005 baseline study in Appendix 7(1), and a determination was made with consultation with the appropriate agencies that, there were "No candidate or federally listed plant species identified within or adjacent to the permit area."(Appendix 8). The Division agrees that the proposed disturbance for MR50 is very small and that the qualitative description of the vegetative community shall be adequate for this minor revision. We just want to clarify that the guidance regarding quantitative versus qualitative sampling in the guideline refers to the size of the vegetative community, not the size of the anticipated disturbance. This potentially could be an important distinction for future revisions. No response is necessary for King II, Section 2.04.10,p. 3, 3. KII Section 2.04.9,P. 5. One minor typo. Please correct the word "tome"in the last paragraph to "ton". 4. The Division conducted a cost estimate for reclaiming this minor disturbance. Due to the limited scope of the proposed work, a cost for backfilling the estimated 0.17 acres of disturbance using the excavator used to conduct the exploratory work,estimating an average of 10 feet deep. And the cost of reseeding the disturbance. Seeding would be broadcast due to the challenge of access and minimal disturbance area. The Division's estimated cost for reclaiming MR50 proposed activity is$2,158.00. The Division's records indicates that GCC currently holds $1,796.00 in excess of the currently required surety. GCC will need to submit additional bond,or provide additional information to the Division to show why the current bond ill be adequate. The Division's reclamation cost estimate is attached to this letter. Please provide corrections to the text as soon as possible, in order for the Division to review the revised paged in advance of the proposed decision date of January 6, 20120. Please e-mail of call me should you have any questions. Sincerely,