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Savage and Savage Environmental <br />practka/ so/utfons forenvlronmerrtallssue5 <br />4610 Haystack Drfve 970 674 8080 telephone <br />Wlndsor,Colondo 80550 9706748088 facsimile <br />savageandsavage®gwest.net <br />Mazch 27, 2006 <br />Ms. Janet Binns, Environmental Protection Specialist R~~' 4.'`6 «'® <br />Colorado Division of Minerals and Geology ~ ~' <br />1313 Sherman Street, Room 215 MAR 3 O 2006 <br />Denver, Colorado 80203 <br />ihsion of Minerals enC Cs~WY <br />Re: Response to CDMG Adequacy Concerns: Technical Revision 3~' <br />Keenesburg Mine (CDMG file C-1981-028) <br />Dear Ms. Binns: <br />This correspondence will provide our responses to concerns and issues raised in the <br />February 15, 2006 adequacy review of the proposed revision of revegetation standards at <br />the Coors Energy Company (CEC) Keenesburg Mine. Our responses follow the order <br />and numbering of the items in your correspondence. <br />1. It is CEC's position that CDMG staff is taking an overly narrow interpretation of Rule <br />4.15.7(2)(d) with respect to the methodology proposed in TR37. Rule 4.15.7(2xd) states, <br />in relevant part: <br />"A discussion of the comparisons to be made between the reclaimed and undisturbed <br />areas in order to demonstrate that the success criteria in 4.15.8, 4.15.9, or 4.15.10 have <br />been met. Upon approval by the Division, such comparisons or vegetative cover and <br />herbaceous productivity, woody plant density, species diversity, seasonai variety or other <br />applicable parameters shall be based on one or more of the following: <br />(i) Reference areas as described in 4.15.7(3); <br />(ii) Standards of vegetative cover or herbaceous productivity, or other <br />applicable parameters, established by reference to technical documents of the <br />United States Department of Agriculture, Unites States Department of the <br />Interior, ar other authorities. These documents must be approved by the <br />Division and the Director,..." <br />The proposed revisions to the vegetative cover and herbaceous productivity success <br />standards are based on both sampling of the Osgood Sand Reference Area and reclaimed <br />areas that, by the admission of a competent authority (Natural Resource Conservation <br />