REV91335

• Permit No: C1981018
• IBM Index Class Name: Revision
• Doc Date: 2/2/2007
• Doc Name: Revegetation Issues Memo
• From: Dan Mathews
• To: Kent Gorham
• Type & Sequence: MT5
• Media Type: D
• Archive: No

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STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman SC, Room 215
Denver, Colorado 00203
Phone: [phone]
FAX: [phone]
INTERNAL MEMORANDUM
DATE: February 2, 2007
TO: Keni Gorham
FROM: Dan Mathews
RE: Deserado Mine Mid-term Review
Revegetation Issues
Permit C-1981-018
COLORADO
DIVISION OF
RECLAMATION
MINING
- &-
SAFETY
Bill Owens
Governor
Russell George
Executive Director
Ronald W. Cattany
Division Dlreetor
Natural Resource Trustee
Pursuant to your request, I have reviewed information pertinent to the Deserado Mine revegetation
plan, including Section V.I of the permit application package, the 2005 renewal findings document,
and qualitative vegetation survey reports submitted each year with the Deserado Annual
Reclamation Report (2000 through 2005 reports). My specific review comments are listed on the
following pages.
The main issue here is that I think certain stated and implied goals of the revegetation plan relating
to species diversity and shrub density establishment and future expansion are not consistent with the
current seed mixes, which contain numerous aggressive, introduced grasses. Use of the introduced
grasses may be warranted, given the extent of the cheatgrass problem in the mine vicinity, but it is
not realistic to think that we can have it both ways (use the introduced grasses for cheatgrass control
but still expect diverse native communities to ultimately develop). I think it will be necessary to
make a more definitive choice regarding objectives, seedmixes, and revegetation approaches.
Note that I am recommending in Item 1 that we solicit the input of BLM and DOW regarding the
revegetation emphasis/seedmix issues. My thinking is that we should send a letter to both agencies
concurrent with submittal of our review letter to BME, requesting their input and inviting their
participation in a field tour this spring. I think it would be appropriate that agency comments be
provided following the field tour, but I would like to go ahead and send the letters out at this time,
to bring the matter to their attention, and to get the appropriate people involved. I would
recommend that our letters to the agencies include a copy of the mid-term review letter, directing
their attention to Item 1. I would also recommend that the letter to DOW include a copy of the
Reclamation Plan and Wildlife Plan from the permit application.
Let me know if you have any questions.
REVEGETATION PLAN MID-TERM REVIEW COMMENTS
Office of Office of
Mined Land Reclamation Active and Inactive Mines