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iii iiiiiiiiiiii iii STATE OF COLC~~v~~v DIVISION OF MINERALS AND GEOLOGY Department M Natural Resources 1313 Sherman 51., Room 215 Denver, Colorado 80203 Phone (303) 866-3567 FAX. (303) 832-8106 Internal Memorandum TO: Jim Burnell FROM: Sandy Brown DATE: May 12, 2000 RE: Revege[ation at Apache Rock Area West Elk Mine ~~ DIVISION O F MINERALS GEOLOGYI RECLAMATION MI NING•SAFETY Bill Owens Governor c.es E. walcnc, Execubvc Dueaor nLChael P. LOng Division Director For all reclaimed areas DMG requires operators to demonstrate revegetation success using the bond release criteria of herbaceous cover, productivity, woody plant density and species diversity. West Elk will be subject to these standards at the Apache Rocks area. Generally, we have operators submit baseline data prior to mining to demonstrate that the reclaimed area will be comparable to the disturbed area. Obviously, Mountain Coal Company (MCC) is not in a position to do so at Apache Rocks. However, a qualitative description of the Apache Rocks area vegetation should be included in their revision application. MCC has established a reference area that is representative of rangeland in good condition. As I understand it, the USFS wants the Apache Rocks area to be reclaimed to rangeland, so the existing reference area should be suitable. Cover and productivity in the reclaimed Apache Rock reclamation could be compared to the existing reference area. I looked at the seed mix recommended by the USFS for the reclamation at the Apache Rocks disturbance azea. The seed mix is a native grass mix; no forbs are included. You also provided me with a copy of the DMG approved seed mix. If the DMG mix is acceptable to the USFS, I would recommend its' use. I do suggest that Cicer milkvetch be eliminated. The DMG contains a mix of native grasses and forbs which will result in a more diverse reclaimed community. The diversity standard requires Mountain Coal Company (MCC) to establish a minimum of 2 cool season grasses and 3 perennial forbs each with relative cover values lying between 3 and 40 percent. MCC would have trouble with the diversity standard using the USFS mix. With respect to shrub establishment, it is my understanding that the USFS does not want shtvbs to be planted in [his primarily wooded area. In order for us to remove the shrub density standard, we will need a written request from the USFS requesting that they not be planted. We will also need to follow up with the Colorado Division of Wildlife and get their concurrence to eliminate the shrub density standard. Please see me if you have additional questions.