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f <br />• • iiiiiiiiiiiiiiiiiii <br />999 <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanment of Nalu ral Resources ~~oF'co~4 <br />1313 Sherman 51., Room 215 ~a ~ ~ <br />Denver, CO 80203 , t~v <br />~O~ <br />Phoney (7071 866-3567 +a~e <br />FAX: p031 83 2-8106 <br />Roy Romer <br />Governor <br />March 31, 1993 Michael s. Fnn~ <br />Division Direanr <br />XTO: Steve Wathen <br />FROM: Janet Binns ~,~ <br />RE: Peabody Coal Company's Responses to Division Adequacy <br />Concerns for Hayden Gulch Loadout Application (C-92-081) <br />I have reviewed Peabody's responses to the concerns I identified <br />during the Division's adequacy review. My concerns were fairly <br />well resolved. <br />1) The operator still insists on the inclusion of Medicaao sativa <br />in the reclamation seed mix. The argument used to show the <br />necessity of this introduced species was a) the Division has <br />approved the proposed rate in seed mixes of Peabody's nearby <br />Seneca II mine, b) this rate has established stands in which <br />relative cover of alfalfa is approximately 2~, and c) <br />commercial availability of native legume seed is generally <br />poor. Investigation into the Seneca II permit and <br />revegetation monitoring reports indicate some differences to <br />this argument. First of all the Division has approved the <br />inclusion of Medicaao falcata in the Seneca II seed mixes. <br />This prostrate alfalfa strain is supposed to be less <br />aggressive than Medicaao sativa. Furthermore, revegetation <br />monitoring data from 1991 shows that MedicaQO falcata seeded <br />at less than 2% of the seedmix in the 1987 Wadge and 1987 Wolf <br />Creek reclaimed areas four years later account for 11% and <br />5.3$ relative cover respectively. Areas seeded in 1989 at <br />these rates did show relative cover of 2& and 1.1%. The 1992 <br />revegetation monitoring report was not yet available to <br />compare relative cover increases or decreases for the fifth <br />year after seeding. If Peabody is unable to obtain native <br />legume seed commercially, I would prefer to see Medicaoo <br />falcata used instead of Medicauo sativa. <br />2) Peabody Coal Company has sufficiently addressed control and <br />management of dryland reference pasture. I have no further <br />concerns with this item. <br />3) Peabody Coal Company has included a map showing the locations <br />of rangeland reference areas as requested by the Division. <br />