REV04352 - Laserfiche WebLink

Home Browse Search

iiiiiiiiiiiiiiiiiii 999 December 20, zool RECEIVED DEC 242001 Mr. Byron Walker Environmental Protection Specialist Division of Minerals 8 Geolaov Colorado Division of Minerals and Geology ' 1313 Sherman Street, Room 215 Denver, Colorado 80203 Re: Comments Reaarding Colowyo Coal Comoanv L.P. Permit C-81-019 TR-52 Dear Mr. Walker: The following comments are made regarding the subject Technical Revision. General comments: As the Division is aware until recently, I was the environmental engineer responsible for the reclamation of all lands at Colowyo. As such, I have superior knowledge regarding reclamation at Colowyo. Colowyo reclamation has been shown, through recent approved Phase I and II bond releases, to be well on the way to meeting ultimate reclamation liability release standards. I am concerned that many of the TR-52 proposals, if adopted, will severely jeopardize the mine's ability to meet reclamation performance standards, will cause reclamation failures, cause increased erosion and will adversely effect the postmining land uses of rangeland and wildlife habitat. Overall, as the CMA/CDMG reclamation working committee has discussed on many occasions, the concept to use different, less competitive seed mixes, in a topsoil reduced environment is going to be essential to solve the woody plant establishment issue. Until the results of the 3-year CSU/CDMG woody plant study are finalized and published it is premature and risky to start implementing these concepts now. Only until after the results of the study are in should major changes to the Colowyo reclamation plan be approved. In addition, it is also essential that any reclamation plan changes also be accompanied by appropriate changes to the bond release criteria. Colowyo's current bond release criteria may no longer be valid for projected changes to the reclamation plan. • The proposal's numerous seed mixture shortcomings can easily be overcome by the version of TR-52 submitted earlier in the year and subsequently withdrawn. Specific comments: The proposal to change the topsoil redistribution plan by varying topsoil depths from 0-18" is virtually no topsoil redistribution plan at all. Carte blanch approval to replace topsoil depths in a helter skelter manner throughout the reclaimed areas is quite problematic. For example, limited topsoil replacement on fill outslopes will adversely effect the ability to provide adequate vegetative cover to control erosion on these important steep slope areas.