REV05324

• Permit No: C1982057
• IBM Index Class Name: Revision
• Doc Date: 7/1/2002
• Doc Name: Vegetation Review Memo
• From: Grand Junction Dan Mathews
• To: Mike Boulay
• Type & Sequence: PR3
• Media Type: D
• Archive: No

STATE ~F COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
DATE: July 1, 2002
TO: Mike Boulay
RE: Seneca II-W, Permit Revision No. 3 Adequacy Review
Review of SCC PAR Response of 4/30/02 (Vegetation/Itevege[ation Issues)
Permit C-82-057 ~~
DIVISION OF
MINERALS
GEOLOGY
RECLAMATION
MININ G•SAFETY
Bill Owens
Governor
Greg E. Walther
Executive DirecYOr
Ronald W. Cattany
Atting Division Director
I have reviewed SCC's responses of 4/30/02, to your PAR letter dated 4/02/02. I discussed some of the
issues regarding aspen establishment with Dr. WayneShepperd, an acknowledged aspen authority with the
U.S. Forest Service, Rocky Mountain Reseazch Station, via email and telephone. Also, to supplement my
revegetation review, I reviewed relevantsoils baseline information and minesoil reconstruction plans, that
you recently forwarded to me. SCC responded to each of the vegetationtevegetation items contained in the
4130/02 PAR letter, and my comments on the itemized responses and amended permit information are
listed below. Also included are several additional comments related to theminesoi] reconstruction plan and
other aspects of the reclamation plan My comments also reflect observation of shrub establishment test
plots and permanent revegetation areas at Seneca II, Seneca II-W, and other Northwest Colorado surface
mines during the week of June 24, 2002, as well as review of pertinent Seneca II and II-W monitoring data,
and discussion of shrub establishment issues with Seneca Coal Co. and CDOW personnel.
6. Original adequacy item requested that operator amend text on page 22, Tab 22, to include reference to
concentrated shrub seeding within some portion of the shrub planting areas depicted on Exhibit 22-1A,
as appropriate.
In response, operator did amend page 22, to reference Map 22-1A However, further clarification is
warranted to eliminate ambiguity. Also, based on observations of shrub seeding success and
discussion with operator, it is recommended that any areas planted with List 1 or LisI2, also be seeded
with Seedmix 6. Provision of additional "seeding only" shrub establishment areas might also be
warranted. Inclusion of shrub seeding in combination withtubeling planting would be expected to
enhance over-all establishment success, but shrub seeding would not pose the problem of excessive
competition that occurs with seeding of faster growing herbaceous species.
To eliminate confusion, it is requested that the subject sentence on page 22 be amended as follows
Within the original !!-W permit area, shrub seeded areas will be approximately one to three acres in
size and will primarily be scattered in the two areas illustrated on Exhibit 22-1 (in addition to the
specified seedling planting areas). Within the II-W South Mining Area, upland shrub establishment
areas are designated on Exhibit 22-1A, as either "Upland Planting Area 1 " "Upland Planting Area 2"
or "Seedmix No. 6'; with planting list and establishment method based on post-mine site
characteristics and desired community, The treatment for Upland Planting Area 1 is combined
planting with Planting List 1 and seeding with Seedmix 6, rite treatment for Upland Planting Area 2 is
combined planting with Planting List 2 and seeding with Seedmix 6, while areas designated as
Seedmix 6, are seeding only.
7. This item is related to Item 6 above, and requested that the operator amend specific text on page 22 to
reflect consideration of the results of monitoring to date, and to address any resultant changes with
respect to the use of concentrated seeding and seedling transplanting methods of shrub establishment.
The text that we had requested the operator to amend stated that, "if monitoring indicates a greater