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iii iiiiiiiiiiiiiii <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY RFG~~VED <br />Deparmiem of Natural Resources <br />1113 Sherman 51., Roum 215 <br />Denver, Colorado 80203 JUN 2 9 1998 <br />Phone: (7071 R66 1567 <br />FAti: (3(131 832-H 106 Division of ~Ylmerals 6 Geology <br />DATE: June 23. 1998 <br />TO: Mike Boulay /~ <br />FROM: Dan Mathews ll~~[-~~-~ <br />RE: Seneca II-W Midterm Review <br />~~ <br />I~~~~ <br />DEPARTMEt~1T OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Governor <br />lames S. Lochhead <br />E ~ewiive Dnrclur <br />Michael B. LOnR <br />Division Director <br />I have reviewed various documents pertinent to the Seneca II-W mid-term review, with respect to <br />Soils, Vegetation, and Wildlife, as previously requested by Erica Crosby. Materials I reviewed <br />included applicable sections of the permit application package, revisions approved since approval <br />of the permit renewal in 1996 (TR-26, Stip 23 Response), the 1996 Renewal Findings, and '95. <br />'96, and `97 Annual Reclamation Reports and Revegetation Monitoring Reports. I have the <br />following questions and comments. <br />There appears to be a discrepancy between "seedmix 1", in the permit (revised 5/95), and <br />the seedmix listed in the annual reclamation reports. No explanation is provided in the <br />reports for why the approved mix was altered. In the permit application, Mix 1 contains <br />11 grasses, 8 forbs, and 4 shrubs, and permit narrative states that any substitutions will be <br />chosen from "adapted and desireable native species" listed in the baseline data species <br />list. Permit narrative further states that such changes would be noted in the ARR, and <br />indicates that "substitutions will only occur when availability of any of the listed species <br />is a problem." <br />The seedmix listed in the ARR's contains 12 grasses and 4 forbs, plus "supplemental" <br />species including 5 forbs and 6 shrubs. Species included in the ARR list which are not in <br />the approved pennit seedmix include the introduced grass, Russian wildrye, and the <br />introduced leguminous forb, cicer milkvetch. Two native grasses, slender wheatgrass and <br />basin wildrye, are seeded a[ lower rates than specified in the approved mix. One native <br />forb included in the approved seedmix (arrow leaf balsamroot) is not listed in the ARR <br />specified mixes. <br />These changes are not addressed or explained in the annual reports. Some explanation <br />should be provided, and the operator should ensure that the approved seedmix is used in <br />1998 and future seeding, unless the seedmix is amended through appropriate revision to <br />the permit. <br />2. Revgetation reporting and evaluation conducted by Peabody and included in the annual <br />