PERMFILE67186

• Permit No: C1981028
• IBM Index Class Name: Permit File
• Doc Date: 6/15/2006
• Doc Name: Revegetation Success Criteria
• Section_Exhibit Name: Appendix TR-37
• Media Type: D
• Archive: No

Savage and Savage ENVIRONMENTAL
• practical solutions for environmerrtal issues
4610 Haystack Drive 970 674 8080 telephone
W(ndsor, Colorado 80550 970 674 8088 facsimile
savagea ndsavageCaearthltnk.net
December 20, Zoos RECEIVED
Ms. Janet Binns, Environmental Protection Specialist DEC 2 0 2005
Colorado Division of Minerals and Geology pivision.f Minerals and GeulogY
1313 Sherman Street, Room 215
Denver, Colorado 80203
Re: Application for Technical Revision to Modify Revegetation Success Standards at the
Keenesbwg Mine (CDMG file C-1981-028)
Dear Janet:
• Attached is background information, a CDMG revision application form, and proposed
public notice for a revision to modify the revegetation success criteria at the Coors
Energy Company Keenesbwg Mine. As I mentioned in ow October meeting, we propose
to use precipitation data from on-site to predict yearly growing season values for total
vegetation cover and total herbaceous production based on mathematical formulae
derived from vegetation sampling begun in 1994. The mathematically predicted values
would serve as the revegetation success criteria for total vegetation cover and total
herbaceous production at the Keenesburg Mine. Additionally, we undertook a review of
the relative cover data from 1994 to present to critically evaluate the current species
composition revegetation success criterion for the Keenesburg Mine. We concluded that
the current species composition success criterion does not reflect species composition at
the Osgood Sand Reference Area or successfully revegetated areas at the mine. Based on
the quantitative data collected from 1994 to present, we are proposing to revise the
species composition success criterion. With acceptance of these proposed revegetation
success criteria by the Division, Coors Energy Company proposes to discontinue use of
the Osgood Sand Reference Area at the Keenesburg Mine.
Given the unique nature of this proposed revision, and our anticipation that significant
discussion will occur between Coors Energy, Savage and Savage, and the CDMG staff,
we have not provided replacement pages for the Keenesbwg mine permit documern at
this time. We anticipate providing replacement pages prior to a decision by CDMG on
the technical revision application.