APPCOR11061

• Permit No: C1981026
• IBM Index Class Name: Application Correspondence
• Doc Date: 9/14/1981
• From: WYOMING FUEL CO
• To: MLR
• Media Type: D
• Archive: No

sandstone, siltstone and shale sequence with the sand fraction being
the greatest percentage. This sandy zone is almost always separated
from the coal by up to as much as 30 feet of rather impervious
siltstone". Our contention is that generally speaking, this
impervious siltstone will act as a confining bed to isolate the
groundwater within the underlying Upper Sandy Member of the Pierre
Shale. Page 73 of Appendix C further states "Experience with the
existing pit...indicate total groundwater seepage into the pit will
be very minimal if any". Since past experience within known fracture
and fault systems have encountered no problems with respect to
groundwater flow into the pit from the underlying sediments below
the coal, we maintain that:
1) There is no appreciable hydrologic connection
between the underlying Upper Sandy Member of the Pierre Shale and
the Sudduth Coal, and
2) That mining will, therefore, have negligible
impact on the Upper Sandy Member with respect to groundwater.
VEGETATION
2.04.10(4)
WFC would like to point out that the ACR by the OSM is not
interpreting WFC's original response to shrub production correctly.
WFC stated that the, "Current regulations specify only herbaceous
production for evaluation of revegetation success." WFC was not
referring to vegetation baseline. To reiterate why WFC did not
collect shrub production in 1980 for baseline resulted from
correspondence with the Division's staff prior to initiating the
1980 sampling season. Therefore WFC cannot submit 1980 shrub
production data. WFC also feels shrub production would not provide
any significant information to the vegetation baseline presented,
for the following reasons.
WFC feels the purpose of vegetation baseline is to first
collect vegetation information to make decisions for species selec-
tion for revegetation and secondly provide a standard for revege-
tation success. Since shrub production is not used in the evaluation
of revegetation success, WFC does not see any value in collecting
this information. If the rationale for collecting shrub production
is simply for determining the relative contribution of each lifeform
to the plant community this can be achieved through cover estimates
which WFC has provided.
Furthermore, the OSM is referred to the 1979 growing season
data Tables 3F and 4F, Appendix F of the application for shrub
production estimates. If necessary, this data should suffice for
vegetative baseline information.
Regarding a species list this has been provided (see Exhibit 1).
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