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• iii iiiiiiiiiiiiiii ' <br />DIVISION OF MINERALS AND GEOLOGY <br />D~•parlmem of Natural Re+ources <br />111 {Sherman SL, Ronm ? I S ' <br />D~~m-c:. Coloiarb 802UJ <br />P'nune: f)D's7 R55-7 i57 <br />Fi~~l UDSI N i:~H106 <br />April 26, 1999 <br />Jerry Koblitz <br />Greystone Development Consultants <br />X231 South Quebec Street <br />Englewood CO 80111 <br />RE: CCMC Draft Phase III Bond Release, #C-S1-024 <br />Dear Mr. Koblitz: <br />DIVISION OF <br />MINERALS <br />GEOLOGY <br />R E C L A M A T I O N <br />MININ G•SPFETY <br />Ili Owens <br />Curunor <br />e,es e. walcner <br />Evecuo~e Oircaor <br />michael B Long <br />Diriann Daeanr <br />Please find below comments from Janet Binns of our office concerning the Drafr Phase III bond <br />release submitted for review for the CCMC No. 1 mine. <br />I. Please review the Division's April 18, 1995 Guideline Regarding Selected Coal Mine Bond <br />Release Issues. <br />a) The 1995 guidance document states the that application should contain a map showing locations <br />and dates of seeding. This was not included with the "application". <br />b) Page 11 of this guidance document allows for annual and biennial species to contribute up to l0 <br />percent relative cover and production, or the relative cover and production of such species in the <br />associated reference azea or standazd, whichever is higher. <br />The 1998 reference area sampling had 5.3% relative cover attributed to annual grass and forb <br />species. The guidance document allows up to 10% annuals or biennials to contribute to the <br />relative cover value. Kaiser chose to eliminate the annual cover values from their 1998 data, then <br />indicated that the cover on the reclaimed area was less than the reference area standazd. Inclusion <br />of the annual and biennial cover in the reclaimed azea data would indicate that Kaiser was above <br />the 90% cover value of the reference area. <br />The Division also disagrees with Kaiser's elimination of cover transect No. 2 from the June <br />sampling data. Transect No. 2 recorded a high concentration of an annual grass, Bromus <br />tectonfm. This observation was substantiated by the Division inspector recorded in the June 18, <br />1998 inspection report. By eliminating this transect the operator is mis-reporting the sampling <br />data. The operator needs to include the results of all transects collected. <br />• <br />STATE OF COLORADO <br />