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a,, _. n . <br />Savage and Savage ENVIRONMENTAL <br />practJcsl eolutbna far anvtronmerKal leeues <br />4610 Haystack Drive 870 6748080 telephone <br />Windsor, Colorado 80550 970 6748088 facsimtle <br />savages ndsavage®earChllnk.net <br />:~ 'a q~ ~~ 1' f <br />,> ~ '~ '"~ <br />October 31, 2005 <br /> <br />Mr. Tom Kaldenbach, Environmental Protection Specialist ` ~~ ~ 3 2~~ <br />Colorado Division of Minerals and Geology <br />1313 Sherman Strcet, Room 215 <br />Denver, Colorado 80203 <br /> <br />Re: King Coal Mine (CDMG Sle C-81-035) TR09 Preliminary Adequacy Review <br />Response <br />Dear Tom: <br />The following answers are provided in response to questions in yoyr Preliminary <br />Adequacy Review dated September 27, 2005 and October 4, 2005. The order and <br />numbering of the responses corresponds to that in your docwnents. <br />September 27, 2005 PAR <br />1. The Division's assertion that the standards of Rule 4.15.10 must be augmented by <br />requiremerts for additional standards for species diversity and herbaceous production due <br />to the "Division's general policy" is not supported by the rule of law contained in the <br />statute and regulations. .While we agree that the Rule is pote~ially ambiguous, we <br />contend that the only revegetation success criterion required for the previously disturbed <br />areas of the King Mine is vegetation cover. However, to facilitate completion of TR09, <br />we propose the following revised revegetation success criteria as we discussed in our <br />October 27, 2005 meeting. 'f®iYs: <br />• Total Live Vegetation Cover equal to or greater than thirty (30) percent. <br />• Total Herbaceous Production (annual) equal to or greater than 300 pounds per <br />acre (dry weight). <br />• Species Composition comprising three (3) cool season perennial graminoids and <br />one (1) perennial fort, with no qualifying single species accounting for more than <br />forty (40) or less than one (1) percent relative cover. <br />• There will be no woody plant density revegetation success criterion in accordance <br />with the post-mining land use and landowner wishes. <br />