REV13027

• Permit No: C1982057
• IBM Index Class Name: Revision
• Doc Date: 7/5/2006
• Doc Name: Draft Revegetation Success Testing Memo
• From: Dan Mathews
• To: Roy Karo ‎(SCC)‎, Sandy Brown
• Type & Sequence: SL1
• 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 DIVISION o E
Phone: [phone] MIN &RA L S
FAX: [phone] G E O L O G Y
0.ECLANATION•NINING
SAFETY•ECIfNCE
DATE: July 5, 2006
Bill Owens
Govenror
TO: Roy Karo (SCC), Sandy Brown
Russell George
Executive Director
FROM: Dan Mathews Ronald W. canary
Division Director
RE: Draft Revegetation Success Testing for Bond Release Natural Resource Tmstee
Seneca II-W Mine (Permit C-82-057)
I have reviewed the hand delivered "Drafr 1"proposal dated 6/7/06, which was prepared by
ESCO Associates. I compazed the proposal against the detailed "Testing for Successful
Reclamation" section of Tab 22 in the approved permit application package. My comments aze
listed below. Let me know if you have any questions.
The final proposal will need to include several maps, which are referenced in the
"Draft 1"proposal, but are not included.
2. On page 2, the acronym "LRU" is used but is not defined; definition should be
included in the final proposal.
3. The "Summary of Sampling Design" Table on page 2 indicates 50 quadrats (and to
adequacy) for woody plant density sampling. Text in a later section indicates there
would be two separate woody plant density samples ("background" and "within
patch"), both of which would include a minimum of 50 belt quadrats to adequacy.
The Table should be amended to correspond to the text.
4. The species diversity "Alternative Test C" discussion on page 11 diverges from the
approved permit method in a couple respects. First, the "Draft 1"proposal would
allow for use of either species density or species cover value by life form in the
assessment; whereas the approved permit specifies that species density by life form
would be the parameter to be assessed. Second, the approved Motyka similarity
standazd for density by life form is "0.9 * 75% = 67.5%". This differs from the
"Draft 1" proposal of "63% (0.9*70%)".
Unless the permit is revised by technical revision (with adequate justification),
the proposal will need to be amended to be consistent with the permit.
5. The "Shrub Evaluation" section of the proposal differs in some respects from the
"Woody Plant Density" evaluation section of the permit (current text page 48 and
PR-5 map Exhibit ZZ-1), although the over-all concept is consistent.
Office of Office of Colorado
Mined Land Reclamation Active and Inactive Mines Geological Survey