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~ ~ III IIIIIIIIIIIII III <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Departmem of Natural Resources <br />1313 Sherman Sf., Room 215 <br />Denver, Colorado 80203 <br />Phone: 13031 866-3567 <br />FAX: (3031 832-8106 <br />April 1, 1994 <br />Jim Morris <br />Wildlife Biologist <br />Colorado Division of Wildlife <br />711 Independent Ave. <br />Grand Junction, CO 81505 <br />RE: Seneca II Mine, Technical Revision 27 (C-80-005) <br />Dear Mr. Morris: <br />I~~~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCE <br />Rav Romcr <br />Gncernnr <br />Ren Salazar <br />E.ennive Dneuur <br />Michael B Long; <br />Division Di rec iur <br />Thank you for your comments regarding the above-referenced <br />revision. The Division received letters from your office addressed <br />to Peabody Western Coal Company (PWCC) and to our office. We have <br />issued a second adequacy letter to PWCC with a list of topics the <br />Division feels have not yet been adequately addressed. That letter <br />instructs PWCC to provide additional documentation of the utility <br />of their proposed plans for wildlife habitat. A copy of that <br />letter is enclosed for your reference. <br />The Division is interested in encouraging mine operators to <br />continue to explore successful methods of reestablishing wildlife <br />habitat on reclaimed mine lands. As indicated in our letter to <br />PWCC, the Division is not opposed to reducing the current 1000 <br />stems per acre standard if an alternative plan offers an <br />opportunity to further improve the utility of post-mine wildlife <br />habitat. We would like to continue a dialogue on this matter with <br />PWCC and the CDOW. <br />We agree with the CDOW that shrubs and trees are an essential <br />component on reclaimed land with post-mine land uses which include <br />wildlife habitat. Unfortunately, there is a shortage of available <br />literature discussing establishment and use of woody plants on <br />reclaimed mines. Experience in this area has only been accumulated <br />over a relatively short time span. During that time, it has become <br />readily apparent that establishment of woody plants on reclaimed <br />areas where erosion must also be minimized is a difficult task. In <br />light of these factors, the Division is encouraging the operator to <br />supply additional documentation and/or commitments to monitor <br />establishment of shrub clumps on site. <br />