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. +'~:. ~ III IIIIIIIIIIIII III <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />DeVarimenl of Natural Resources <br />1313 Sherman 51., Room 215 <br />Denver, Colorado R0201 <br />Phone: (3031 R66 3567 <br />FAX: (3071 833-81 OG <br />DATE: September 7, 1995 <br />TO: Susan Burgmaier <br />FROM: Larry Routten ~~ <br />RE: Minor Revision No. 34 <br />Edna Mine (C-80-001) <br />Here are a few questions you night pass on to P&M regarding MR-43. <br />~~~~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Governor <br />lames S Lochhead <br />Execwive Director <br />Michael R. Long <br />Division Director <br />P&M is proposing to use cattle to repair erosion features by trampling Bullied areas and <br />incorporating mulch into the soil. Cattle are also proposed as land imprinting implements <br />on revegetated areas to be interseeded. The Division has two general concerns with these <br />proposals. <br />1. If P&M identifies erosion features of significant enough extent to require repair, how <br />will fencing cattle into. areas of undetermined size ensure timely repair and <br />minimization of erosion? <br />2. What impact will cattle have on two and three year old stands of revegetation if they <br />are used as "land imprinters" during interseeding operations? <br />Some specific questions which should be addressed prior to a decision on the revision <br />application are: <br />1. The cover letter accompanying the revision application mentioned the technique of <br />using cattle to repair erosion features has been used successfully at other sites. The <br />Division is not aware of successful use of cattle to repair gullies by incorporating <br />mulch and seed into erosion features. Can P&M provide any literature or other <br />information documenting the effectiveness of this proposal? <br />2. Revised page 4.3-27 indicates the proposed use of cattle to control erosion on <br />reclaimed areas should not be considered as a grazing plan. The coal regulations do <br />not require that a grazing plan be included in mine permits. However, unless areas <br />where this practice is proposed are identified in advance, it might be beneficial to <br />describe the general numbers, duration, and intensity of grazing to be conducted in <br />the permit application package. <br /> <br />