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f r <br /> <br />Cyprus Yampa Valley Coal Corporation <br />An AIlllla(e of CypruN Mlnera/N Compeny <br />October 29, 1998 <br />Janet Binns <br />Environmental Protection Specialist <br />Division of Minerals and Geology <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />RE: Phase III Bond Release <br />Permit No. C-84-062 <br />Dear Ms. Binns: <br />Mine 3 parcel. <br />• <br />DECEIVED <br />III IIIIIIIIIIIIIIII <br />sss <br />48587 Roull County Roetl Nor <br />Oek Creek, CO 80187 <br />PSOne (303) 8743800 <br />PIOV ~ 6 1998 <br />~ 1,•,~s~on of Minerals & Geology <br />The following responds to the questions presented in the Division's letter on the above referenced <br />topic. The two hay types, meadow and brome, were combined to reflect the fact that the <br />reclaimed areas would be returned to a pastureland and not imgated meadow. The attached table <br />provides the diversity values for the reclaimed areas and the reference areas. As shown on the <br />table, the southern end of Mine 3 meets the diversity standard. The northern end of Mine 3 <br />passed in 1995, however the index value for 1996 was .613. This is slightly lower than the 90% <br />value of the weighted diversity index value of .6Z8. CYCC requests that the Division proceed <br />with approval of the southern Mine 3 parcel and hold in abeyance the decision on the northern <br />In regards to the northern parcel, it is CYCC's opinion that a review of the diversity standard for <br />this area may be in order. The northern parcel is being returned to pastureland, and as such it is <br />appropriate to look at the diversity standard in [his light. A strong comparison for modifying the <br />diversity standard can be made by looking at the standard approved in permit C-81-071. The <br />postmining land use for this permit is pastureland, the same as in permit C-84-062. This standard <br />states that "alfalfa shall not exceed 75% of relative production, and perennial grasses provide at <br />least 25 percent relative production, and no shingle species shall exceed 75 percent relative <br />cover'. <br />It is evident that other diversity standards besides the Shannon-Weiner diversity index can be <br />used to measure this parameter. Also, the literature indicates that application of a diversity index, <br />such as the Shannon-Weiner, may not be the best approach for determining if this parameter has <br />been successfully met at a reclaimed mine site. For example, see Chambers, 1983, "Measuring <br />Species Diversity on Revegetated Surface Mines: An Evaluation of Techniques". <br />CYCC will submit a revision to modify the permit allowing use of an alternate diversity standard, <br />such as the one currently approved in permit C-81-071. This standard will be applied to the data <br />generated during 1995 and 1996 for the northern parcel of Mine 3. <br />c~RUs <br />