REV07034

• Permit No: C1994082
• IBM Index Class Name: Revision
• Doc Date: 5/15/2005
• Doc Name: Revegetation Plan Review
• From: Dan Mathews
• To: Mike Boulay
• Type & Sequence: PR2
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman St., Room 215 C O L O RA D O
Denver, Colorado 80203 D I v t 5 t O N D F
Phone: [phone] MIN &RA L $

FAX: [phone]
GEOLOGY
DATE: May 15, 2005 RE SAFETYI OCIENICENG
TO: Mike Boulay
sill ovens
~ Governor
FROM: Dan Mathews Russell George
Executive Director
RE: Yoast Mine Permit Revision No. 2 (PR-2) Ronald w. canany
Permit C-1994-082 Division Director
Revegetation Plan Review Natural Resource Trustee
Per your request, I have reviewed the amended Tab 22 (Revegetation Plan) submitted by
Seneca Coal Company (SCC) in association with their application for Permit Revision No. 2
(PR-2). My itemized review comments are listed below. I have tried to word the comments
so that you can insert them directly into the PAR letter if you choose. Please let me know if
you have questions.
One item to be aware of is that SCC is proposing various changes to the plan with respect
to woody plant reestablishment. Amendments include changes in the location and
arrangement of planting sites, elimination of mature shrub clump transplants as a method of
shrub reestablishment, and reduction of the over-all woody plant density standard from 450
stems per acre to 200 stems per acre. The standard for specified shrub establishment areas
(2000 stems per acre) would remain unchanged, but all seven mature transplant
establishment areas have been withdrawn, three or four upland shrub planting areas and
one aspen planting area have been eliminated. Rule 4.15.817) requires consultation with
the Division of Wildlife (DOW) regarding woody plant stocking levels, planting
arrangements, and methods of mitigation. Given the changes proposed to the previously
approved standard, methods, and planting arrangements, it is important that we contact
DOW, and give them the opportunity to comment on these proposed changes to the
revegetation plan.
Revegetation Plan
Postmining Land Use and Postmining Land Use Management
Paragraph 2 of page 3 states that "selected areas will receive supplemental shrub
seeding, will have shrubs and trees planted, or will receive mature shrub
transplants". Based on comparison of current and amended Post-Mining Vegetation
Map Exhibit 22-1, it appears that seven mature shrub clump transplant sites were
originally approved, but apparently none were implemented and no mature
transplant clumps are proposed on amended Exhibit 22-1, Please address why no
mature shrub clump planting was conducted, and why the plan is (apparently) being
amended to eliminate the requirement for mature transplant clumps? If the
technique is being withdrawn from the plan, the reference on page 2 should be
deleted.
Office of Office of Colorndo
Mined Land Reclamation Active and Inactive Mines Geological Survey