2006-03-22_REVISION - M1988044

• Permit No: M1988044
• IBM Index Class Name: Revision
• Doc Date: 3/22/2006
• Doc Name: Responses to adequacy letter of 03/14/06
• From: Southwestern Ecological Services
• To: DMG
• Type & Sequence: AM3
• Media Type: D
• Archive: No

Southwestern
Ecological
Services
Vegetation Analysis
Wetland Ecology
Land Rehabilitation Planning
Photodocumentation
37 East Colorado Avenue Denver, Colorado 80210-3105 [phone] Fax [phone] (toll free)
March 22, 2006
Berhan Keffelew
Division of Minerals and Geology
Room 215
1313 Sherman Street
RECEI!/EC
MAR 2 2 2~~~
Denver, CO 80203
RE: Respon" ses to adequacy letter of March 14, 2006.
Coal Creek Resource M-1988-044, ~ M#3,
Dear Berhan: `~~
Division ~f Minerals and GaolagY
Thank you fox your letter of March 14, 2006, and your kind comments regarding the application. Many
people have been involved in the development of the application and they all deserve considerable credit
for the quality of the plan and its details. In particular I believe the State Land Board and their able staff
deserve considerable credit. Schmidt worked closely with them in developing a plan that would help
protect the unique resources of this Stewardship Trust land.
It appears from your letter that only a few items need to be addressed in this response. Following axe our
responses to your points.
Item III 1. Basically what the statement you cite means is that the affected land boundary will be
established to exclude land within 100 feet of the edge of the channel. The edge of the channel does not
include just the center of the channel, but the outer edges of the normal high water line. This varies
considerably from place to place. In some areas this channel is quite wide while in other places it may be a
narrow corridor. But no matter what the width of the channel, that normal high water line can be defined
by on the ground evidence of water flow in the past few years as well as microtopography. In general, the
flow channel would include all land inside the highest definite terrace. In some places though two or three
sets of terraces have been established with only the lowest ox the second terrace showing evidence of
recent flow in a somewhat entrenched channel. Also, keep in mind that this requirement is actually a part
of a larger definition. This requirement applies only to locations where there are no trees beyond the
normal high water line. If, for example, trees extend 150 feet beyond the normal high water line then this
requirement is replaced by the tree setback requirement. In this example, the setback from the stream
channel would be 250 feet because the 100 foot tree setback replaces the stream setback. Of course, there
might be incidental disturbance in this zone, but that would only involve such things as weed control. No
actual ground disturbance that would damage the vegetation would occur.
Item III 2. In the past it has always been thought that excavations up to the drip line was safe.
Unfortunately, the primary roots inside the drip line, other than a tap root, axe mostly support roots and
does not include the majority of the critical feeder roots. It has been found that excavating to the drip line
only keeps the tree from falling over, but it does not necessarily protect its life. If the feeder roots axe
damaged to a great extent the tree will die unless it is able to develop sufficient feeder roots in undisturbed
areas. In situations such as very large drainages such a perennial river bottoms, excavating to the drip line
on one side of the tree will often not kill the tree because there is sufficient feeder root support elsewhere