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<br />~~I I~~I~~~~~~~~~ I~~ <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanmem of NaNral Resources <br />13i 3 Sherman St.. Room 215 <br />Denver, Colorado 80203 <br />Phone: 1303)866-3567 <br />FA%: (303) 832-8106 <br />April 21, 1995 <br />TO: Christine Johnston <br />FROM: Tony Waldron ~~ <br />MEMO <br />~~ <br />DEPARTMEN'T' OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Governor <br />lames 5. LochheaA <br />Faecmrve Director <br />Michael B Long <br />Division Director <br />RE: Minor Revision No. 154, West Elk Mine, Permit No. C-80-007 <br />Per your request, I have reviewed West Elk's proposed seed mix for <br />the fill slope of their recently constructed material storage fill <br />bench. From reading their proposal it sounds like they are more <br />concerned about the aesthetically pleasing aspects of the proposed <br />cover than its ultimate function of controlling erosion and <br />providing stability for the fill outslope. <br />The first question I have is whether there will be any perennial <br />grasses planted with the seed mix submitted in MR-154? If so, what <br />are they? The operator does make reference at one point in the <br />cover letter about a "permanent seed mix" and indicates that this <br />seed mix will be adjusted accordingly, however, it is not clear to <br />me from reading this letter exactly what the proposed mix is, only <br />what the wildflower and shrub component is. Please have the <br />operator submit the entire seed mix in the same format as the one <br />attached to MR-154 and advise them that the mix will be required to <br />contain perennial grass species. The wildflower and shrub species <br />MCC selected for use in the seed mix are acceptable. Once this mix <br />is received, I will review it for approval. <br />Another comment is that generally speaking, either a cover/ <br />companion crop or a mulch is used, but usually not both. If MCC <br />sews oats in with the permanent seed mix, the oats should establish <br />quickly and provide erosion control and protection for the <br />establishment of the perennial cover, which is also what a properly <br />applied mulch will do. The one disadvantage to a companion/cover <br />crop compared to a mulch is that it is competing for the same <br />limited soil moisture that the permanent vegetative cover is, <br />whereas a mulch provides protection and erosion control without <br />drawing on the limited soil moisture reserve. MCC may have a good <br />reason to use both, but you may want to let them know it is <br />probably not necessary. <br />Please have MCC submit the actual seed mix they will be applying <br />and inform them that it must contain at least 30% perennial <br />