REV92967

• Permit No: C1981028
• IBM Index Class Name: Revision
• Doc Date: 2/15/2006
• Doc Name: Adequacy Concerns
• From: DMG
• To: Savage & Savage
• Type & Sequence: TR37
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
February 15, 2006
Mr. Michael Savage
Savage and Savage Environmental
4610 Haystack Drive
Windsor, CO 80550
Re: Keenesburg Mine, C-1981-028, TR-37 Adequacy Concerns
Dear Mr. Savage:
RAD O
O N O F
RALS
GEOLOGY
0.EC LAM ATION•NINING
EAFETT•ECIENCE
sal owems
Governor
Russell George
Executive Director
Ronald W. Utw,y
Division Director
Natural Resource Trustee
I have reviewed Coors Energy Company's (GEC) application for technical revision No. 37. This revision proposes
revisions to the reclamation success standazds for vegetative cover, herbaceous productivity, and species diversity.
Upon review of the proposed changes, the Division has the following comments:
1. Rule 4.15.7(2)(d) provides detail pertaining to acceptable comparisons for determining reclamation success
standards. This rule limits comparisons to reference areas, standards based upon approved technical
documents, standards based upon pre-mining data of the lands to be disturbed, or standards based on
historic record of pre-mining conditions.
CEC is proposing a mathematical standard derived from data collected on reclaimed lands that have not
achieved phase III bond release. The mathematic formulae derived from the sample data links the
reclamation success standards for vegetative cover and herbaceous productivity to precipitation measured
from September through July.
Rule 4.15.7(2)(d) requires that determination of reclamation success standards be based upon comparisons
between reclaimed and undisturbed areas. With the exception of croplands and previously mined lands
(Rule 4.15.9 and Rule 4.15.10), the regulations do not allow for reclamation success standards to be derived
from data collected on disturbed lands. The Division contends that using data from areas that have yet to
achieve reclamation success to devise a reclamation success standard is not permitted by the regulations.
Data collected historically (for example; eleven years of data from the Osgood Sand Reference Area) might
be considered within the scope of Rule 4.15.7(2)(d)(v). This approach would require the formula be
derived from data collected on undisturbed lands only.
2. CEC provided a table of precipitation data collected at the Keenesburg mine site over a 13-year period.
Please describe how precipitation data would be collected and reported for the purposes of a reclamation
standard formula should no mine personnel remain on site in the future.
3. Diversi .Based upon eleven years of data CEC collected at the OSRA, CEC proposes the following
diversity standard:
A minimum of four perennial species: three species shall be warm season perennial grasses, and
one species shall be a cool season perennial grass. No one species will comprise greater than 40%
relative importance or less than 3°/m relative importance.
Relative importance will be measured by calculating relative cover of the revegetation species.
Vegetation species used in species composition calculations may be any plant not defined as
noxious or prohibited, and may be native or introduced.
Office of Office of Colorado
Mined Land Reclamation Active and Inactive Mines Geological Survey