REV97804

• Permit No: C1980005
• IBM Index Class Name: Revision
• Doc Date: 1/12/2007
• Doc Name: 3rd Response to Adequacy Comments
• From: Dan Mathews
• To: Mike Boulay
• Type & Sequence: TR40
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
DATE: January 12, 2007
TO: Mike Boulay
FROM: Dan Mathews
RE: Seneca II Mine TR-40
File C-1980-005
3`d Response to Adequacy Comments
COLORADO
DIVISION OF
RECLAMATION
MINING
- &-
SAFETY
Bill Owens
Governor
Russell George
Executive Director
Ronald W. Cottony
Division DirecYar
Natural Resource Trustee
I have completed my review of the referenced response submittal, dated December 27, 2006, and
I discussed the submittal with Liza Rossi of the Division of Wildlife (DOW) earlier today. Liza
indicated that DOW would provide a letter shortly, indicating their concurrence with the
proposed woody plant establishment plan and success standards, pursuant to Rule 4.15.8(7). My
understanding is that DOW will not be requesting further amendments to the revision plan, but
their letter will likely include language indicating that DOW will not be receptive to further
reduction of the woody plant standard in the future.
My specific review comments aze set forth below. Let me know if you have any questions.
Due to the relatively young age of revegetated stands within BRB-4, SCC argues that
shrub patch mapping and density sampling throughout the block as early as 2008 might
be premature. They further indicate that SCC plans to submit bond release applications
in a timely manner, as lands within the block become eligible for final bond release
("year 9" would be 2012 for the most recent parcels, initially seeded in 2003). SCC
points out that interim shrub density monitoring (though not shrub patch mapping) is
conducted on an annual basis for individual revegetation parcels in yeazs 2, 4, and 7. The
plan also includes sampling of "concentrated woody plant establishment areas" within the
2, 4, and 7 year old pazcels.
I have come to the conclusion that the currently approved interim revegetation
monitoring plan is adequate, and further modification is not warranted at this time.
However, it is important for both SCC and the Division to closely review the interim
monitoring data and check apparent shrub establishment success in the field within BRB-
4 azeas over the next several years, to assess the appazent success of woody plant
establishment. If monitoring and field inspection indicate that shrub stands likely to meet
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