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<br />III IIIIIIIIIIIII III <br />STATE OF C.ut_,vicr~LO <br />MINED LAND RECLAMATION DIVISION <br />Department of Natural Resources <br />1313 Sherman St.. Room 275 <br />Genver, CO 80203 <br />303 866-3561 <br />FAx~ 303 8328106 <br />Flovember 2, T990 <br />M1tr. t4arcus Ididdl eton <br />Colorado Yampa Coal Company <br />29587 Routt County Rqad No, 27 <br />Oak Creek, Colorado 80467 <br />RE: >tnor Revision No. 61 - Changes in Vegetation M1lonitoring - <br />File No, C-81-071 <br />Dear hir. ~Aiddleton: <br />pF//C~~Or,~~ . <br />e ~ `_~kA'7F1~~^~~O <br />N;.., ~o <br />•~~1~ ~. <br />3"~: <br />/g76 <br />Roy Romer. <br />Governor <br />Fred q. Banta. <br />DniSion Dired~or <br />Dn October 25, 1990, we received the above-referenced minor revision <br />application, The application was conveyed to Dan idathews for review, and <br />this letter summarizes his comments. The proposal contains several important <br />issues, and we must require that they be addressed by way of the technical <br />revision process rather than the minor revision process. Based on this <br />finding, we nust deny the application, <br />Please note that we had indicated that the proposal to eliminate production <br />sampling in the three year revegetation, for this year only, could be handled <br />as a minor revision. It was not our understanding that additional issues <br />would be proposed. <br />Some comments are provided as to aid you in composing a technical revision, <br />1. The concept of grouping two or more adjacent or nearby parcels of <br />the same land use (i.e. pastureland at :nine 2) into a "block" for <br />bond release is acceptable, However, we cannot approve the <br />proposed sample size maximums of 50 transects for the reclaimed <br />blocks and 15 transects for reference areas, OSM has recently <br />indicated that they will require the Division to delete the sample <br />size caps from the vegetation guidelines as a condition of approval <br />of rule changes to be submitted in December, 1990. We anticipate <br />that OSM will object to any bond release proposals for which sample <br />adequacy has not been met, regardless of the number of samples. It <br />is recommended that CYCC achieve sample adequacy in any future bond <br />release vegetation sampling. If sample adequacy has not been met <br />for the sampling already conducted for the pasb~reland bond release <br />request which may be in the works, we will need to meet with CYCC <br />and discuss the available options. <br />