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Technical Revision No. 67 - PAR 1 Page 2 February 17, 1994 5. MCC's permit application should be updated to include a discussion of the materials storage bench. 6. MCC should include maps SB-101 and SB-102 in an appropriate location in the permit. 7. With the increase of potential storage area for equipment and materials with this revision and the new storage area between FW-1 and MB-1, the Division believes the statement on Maps 53 and 54, stating that materials may be stored, along roads and other open, previously disturbed areas, be removed. CULTURAL The Division has reviewed MCC's cultural resource survey report prepared in September 1993 by Metcalf Archaeological Consultants, Inc., and notified the Colorado State Historic Preservation Officer (SHPO) of MCC's proposed disturbance. Consistent with the conclusions in the Metcalf report, the SHPO has concluded that there are no known cultural resources within the project area. The letter from the SHPO is enclosed for your information. VEGETATION. SOILS, AND WILDLIFE 1. The Grand Mesa Penstemon Survey, dated August 17, 1993, does not cover all areas to be disturbed by this construction. The study, conducted for other proposed actions, does overlap some of the area proposed to be disturbed, but the area between the portal access road and the light use road to the upper meadow has been neglected. If it is MCC's intention to disturb this area (as discussed in #1 under general comments), then a survey for the Grand Mesa Penstemon should be conducted prior to construction of the material storage bench. 2. Please detail the tasks to be employed in reclamation of the eastern portion of the light use road leading to the upper meadow from Sylvester Gulch (ripping, grading, topsoiling, seeding, mulching, timing, etc.). 3. The Division suggests that MCC utilize a Rotoclear or a chipper to reduce the cleared shrubs to a size conducive to use for mulch. If not, then all brush should be cleared and disposed of. The Division also recommends that MCC live haul loader buckets of shrubs and transplant them on areas of the coal refuse pile that are due to be reclaimed. Shrub clumps that are approximately 2 acres are preferable. If MCC is interested in this reclamation technique the Division would be glad to provide more information.