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DEPARTtv1~OF NATURAL RESOURCES <br />D Monle Pascoe EteCUlive DneCIUr <br />~ III IIIIIIIIIIIIIIII <br />MINED LAND RECLAMATION DIVISION <br />DAVID C. SHELTON Director <br />Ric na~tl D Lamm <br />Governor <br />August 9, 1982 <br />Mr. Larry Damrau <br />Colorado Yampa Coal <br />P.O. Box 772129 <br />Steamboat Springs, <br />Company <br />Colorado 80477 <br />Re: Responses to State Program <br />Submission.of Permit No. 79-177 <br />Dear Mr. Damrau: <br />The Division has reviewed Colorado Yampa Coal Company's response to the <br />adequacy concerns for the state program submission. All concerns have <br />been adequately addressed except for the Revegetation Success Criteria, <br />Rule 9.25.8, a species diversity standard. <br />The Division is unfamiliar with the species diversity evaluation method <br />proposed by CYCC and little explanation is given in the test to describe it. <br />Clem Parkins was contacted to answer some of the questions regarding the <br />method proposed by CYCC. He explained that vegetation cover data from five <br />vegetation communities was combined to obtain the standard. The data was <br />not separated by species, growth forms or seasonality. All dominant species <br />were arranged together. The Division feels this approach will require <br />further explanation, since vegetation data is generally tabulated by species <br />within a community, individual species, life-form and/or seasonality. Therefore, <br />CYCC should provide a detailed explanation substantiating the method and the <br />basis upon which it was founded. Any references used in developing this <br />method could be included in the response. <br />I will be happy to discuss this with you if you have questions. <br />Sincerely, <br />J r <br />Sandra L. Emrich <br />Reclamation Specialist <br />SLE/mab <br /> <br />423 Centennial Building. 1313 Sherman Street Denver, Colorado 80203 Tel (303) 866-3567 <br />