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Matthew S. Heyec <br />Hayes F.nvimnmenral Services, Inc. <br />3t70 Lnftryrru Sr. <br />Denver, CO 80218 <br />(303) 733-5368 <br /> <br />March 9, 1996 <br />Mr. Tony Waldron <br />Division of Minerals end Geology <br />1313 Sherman St., Room 2l5 <br />Deaver, CO 80203 <br />RECEIVED MAR 1 11996 <br />RE: Vegetation Study for Prolwsed Coal Mine Waste Bank; Somerset Mine; Permit <br />Number C-81-022. ' <br />gear Mr. Waldron: <br />Oxbow Carbon and Minerals (OCM) plans to submit a revision to allow the <br />placement of mine waste in an area that is adjacent to the existing west yard at the Elk <br />Greet facilities area (West Valley Fill). Disturbance is expected to occur in a location <br />that has F>een previously napped as having troth the mountain shrubland and the juniper <br />woodland community, though the latter community is expected to be disturbed in very <br />small amounts. Several of the specifics of the proposed operation end tltr costing <br />permit support a finding that txrsehne sampling sufficiently addresses the vegetation <br />requirements associated with~tltis new disturbance. These are addressed below. . <br />1. The proposed disturbance is relstlvely small. <br />Page 2.05-20 of the a oved permit document indicates that a wtal disturbance <br />of 71.8 acres is associated with the Somerset end Santarn Creek mitring operations. At <br />the time of the baseline study, over 75% of the disturbance was estimated to fall within <br />the mountain shrub community. The pptr~eseennt disturbance is expected to be 4'.6 acres. <br />As it is drawn now, most of the new disttubartce will fall in the mwntain shrub <br />community. It is OCM's position that the proposed amount of disturbance is small <br />enough wm4tared to the existing disturbance and the size of the permit (5529 acres) <br />that no additronal sampling be reyuired as part of the permitting process. <br />2. Baseline satrtplmg in the mountain shrubland and juniper woodland commtmides <br />occurred within a short distance of the proposed disturbance. <br />Although the proposed disturbance presently falls outside the existing permit <br />area, the area was mapped as part of the baseline study (see Drawing E8-3391 3/3 of <br />Volume 3). As noted above, most of the disturbance would occur within the mountain <br />shrubland community. In fact, part of whet was mapped as reference area would be <br />disturbed. This means that the area to be disturbed can be expected to be very similar <br />m what is presently mapped as part of the reference era. The portion of the reference <br />area that could beotrrmpacted by the o~xratioa was not actually sampled as pert of the <br />baseline study (th gbh sample 3 is close) and therefore will not be consequential if it <br />were to be impacted end deleted from the reference area: <br />• <br />