REV14781

• Permit No: C1981035
• IBM Index Class Name: Revision
• Doc Date: 11/3/2005
• Doc Name: Response Letter
• From: Savage & Savage
• To: DMG
• Type & Sequence: TR9
• Media Type: D
• Archive: No

2. The proposed changes to the seed mix and seed rate reflect observations of successful
revegetation over the past 25 yeazs, particulazly in the vicinity of the King Coal Mine
(both at the Blue Flame Mine, La Plata No 1, and Cazbon Junction Mines). Modification
of the seed mix reflects the objective of obtaining significant vegetation cover for control
and minimization of surface erosion as well as providing ancillary wildlife forage value,
as well as fulfilling the objectives associated with modification of the revegetation
success criteria discussed with CDMG on October 27, 2005. The proposed revised
reclamation seed mix is appended.
3. No response is necessary. Prior to issuing a proposed decision, we request a meeting
to review the reclamation cost estimate with Division staff.
4. Within Section. 2.05.4 (page 6, paragraph 4). the commitment is made to measure
vegetation cover "by any approved quantitative sampling method." Given the
unpredictable nature of CDMG regulations and OSM requirements for modification, this
statement was made to reflect flexibility in the event of future changes to the regulations.
However, the following modified language is proposed.
Sampling Methodology
Any CDMG approved sampling methodology may be employed to determine the level of
herbaceous cover on the revegetated areas. If a methodology is proposed that has not
been previously employed or accepted by CDMG, such methodology will be submitted
for approval prior to employment.
Determination of revegetation success in achieving the total vegetation cover and total
herbaceous production success criteria will be based on quantitative statistical means.
The Student's t test is a robust statistical test to evaluate the equivalency of two sample
means or a sample mean with a specified standard (Zaz, 1974). This test will be
employed to test the null hypothesis that the sample mean for revegetated parcel
parameter is equal to or greater than 90 percent of the cover or production success
criterion. Standazd statistical probability ranges will be employed in the determination of
whether the revegetated azea mean is significantly less than the criterion. When the
revegetated area mean is not statistically significantly less than the applicable criterion of
a 90 percent confidence level employing a 10 percent alpha error probability level, the
revegetation will have been demonstrated successful.
5. Please clarify the text to which this request applies.
6. We will ensure that the Division's copy of documents includes documentation of Mr.
Huntington's request for permanent retention of structures after mining.
7. The source and composition of the material for portal backfill is identified on pages 2
and 3 of Section 2.05.4 under the heading Sealing Mine Openines and Drill Holes.
King Coal Mine (C-81-035) Page 2
TR 09 Preliminary Adequacy Review Responses