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<br />_ ~: <br />III IIIIIIIIIIIII III ~ <br />STATE OF Cvi,uxxUC~ <br />MINED LAND RECLAMATION DIVISION of ~o~ <br />Department of Natural Resources ~``~yw$ <br />~t <br />7373 Sherman St., Room 275 <br />Denver, CO 60203 ~.~~,~.~ <br />303 866-3567 're~a ` <br />Fax: 303 832-6706 <br />Roy Romer, <br />Governor <br />Freo R. Banta, <br />Division Director <br />Jute 3, 1991 <br />Mr. Bryan J. Archer <br />Sun Coal Company <br />10200 West 44th Avenue, No. 120 <br />Wheatridge, Colorado 80033 <br />RE: Meadows No. 1 Mine, File No. C-81-029, (TR-10) <br />Technical Revision to Revise Woody Plant Density <br />Dear Mr. Archer: <br />The Division has recently compl eted its pr el iminary a~quacy review of <br />Technical Revision No. 10 for the Meadows No. 1 Mine. The revision involves <br />elimination of the revegetation success criteria for the woorJ,y plant density <br />and woody plant diversity from the approved permit. <br />The approved permit currently requires a shrub density of 500 stems per acre. <br />Considering the native plant community, this would seen to be a generous and <br />easy density standard to achieve with minimum effort. Vegetation monitoring <br />should have occured during the first five years after seeding to determine if <br />there were any potential problems with any component of the final standard. <br />In the event there are problem;, this allows for interseeding or special <br />management practices to try and correct the oroblem without restarting the <br />bond release liability period (Rule 4.15.7(5). Unfortunately, it appears that <br />efforts to establish and monitor woody plant density were far from extensive <br />prior to the 1990 monitoring, which was six years after the initial seeding. <br />In the rationale portion of the revision there are several points made which <br />are inaccurate, selective or require additional information. Following are <br />several of those items. <br />1. Revegetation success criterion for woody plant density is a <br />requirement of the Colorado Regulation for Coal Mining. Please <br />refer to Rule 4.15.8(2) ". .woody plant density on the reclaimed <br />surface shall be at least equal to the woody plant density on <br />the approved reference area or to the standards established in Rule <br />4.15.(2)(d)." <br />