REV12807

• Permit No: C1981041
• IBM Index Class Name: Revision
• Doc Date: 10/3/2001
• Doc Name: POWDERHORN COAL CO TR 38 SPECIES DIVERSITY PN C-81-041
• From: DMG
• To: J E STOVER AND ASSOCIATES
• Type & Sequence: TR38
• Media Type: D
• Archive: No

III IIIIIIIIIIIIIIII
STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Depanment of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
~~
DIVISION OF
MINERALS
GEOLOGY
RECLAMATION
MINING•SA FETY
Bill Owens
Governor
Greg E. Walther
October 3, 2001 Executive Dtrecwr
Michael B. Long
Division Director
].E. Stover and Associates
2768 Compass Drive, Suite ]Ol
Grand Junction, Colorado 81506
RE: Powderhorn Coel Company
Technical Revision 38 (Species Diversity)
Permit C-81-041
Dear Mr. Stover:
The Division has reviewed the referenced technical revision application, which includes an evaluation of
reference area and reclaimed refuse area vegetation cover and species composition, proposes a remedial
seedmix for reclaimed portions of CRDA-2, and proposes a revised species diversity success standard for
Roadside Mine reclaimed areas.
The evaluation was thorough and well presented. We have only two requests, which follow:
1. The diversity standard as proposed more closely reflects species composition documented in the
reference areas, and is a more realistic goal than that represented by the current standazd.
However, the proposed standard would not specifically mandate a warm season grass component,
cool season grass component, or a perennial forb component on the revegetated areas. These life
forms are present in the native semi-desertshrublands on the permit area, and they should be
represented on the reclaimed areas. The shrub requirement is adequately addressed by the current
woody plant density standard, and does not need to be addressed in the diversity standard. Based
on the reference area data presented, we request that the species diversity standard be amended as
follows:
• Tolal perennial cool season grass species > 0.5% relative cover.
• Total perennial warm season grass species > 2% relative cover.
• Tola! ojperennial jorbs and sujjrutescen! species > 0.5% relative cover.
• No reclaimed area shall have a single species that represents > 70% relative cover.
2. Remedial revegetation treatment for CRDA-2 (including aninterseeding seedmix) and an
amended seedmix for future primary seeding on the CRDA refuse areas are presented as