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III IIIIIIIIIIIIIIII <br />999 <br />SUN COAL COMPANY RECEIVE® <br />10200 West 44th Ave., #120 <br />Wheat Ridge, CO 80033 ApR 2 2 <br />(303) 422-8064 1991 <br />FAX (303) 467-0714 Mined Land <br />April 15, 1991Reclamation Division <br />Steve Renner <br />Colorado Division of Mined Land Reclamation <br />1313 Sherman St. <br />Denver, CO 80203 <br />Re: Technical revision for the Meadows No. 1 mine, No. C-81-029 <br />Dear Mr. Renner: <br />This letter accompanies Sun Coal Company's application for a technical revision for the <br />permit for the Meadows No. 1 mine, No. C-81-029. Approval of this technical revision <br />would modify the revegetation success standards in this permit by eliminating woody plant <br />density as a success criterion. <br />Sun Coal has made every effort to provide complete and detailed information regazding this <br />application in accordance with regulatory requirements and pursuant to our conferences on <br />this matter with Carl Mount. We hope it will facilitate review of the application by your <br />staff. <br />Sun Coal believes approval of this technical revision would be in the best interest of both <br />the Division and Sun Coal. The application succinctly documents the inappropriateness of <br />a woody plant density standard in this case, and documents as well the benefits of the <br />existing reclaimed area vegetation to wildlife. Regulatory aspects are also discussed. <br />On a much more practical level, enforcement of a woody plant density success criterion <br />would seriously jeopardize final bond release for this project~leazly an unhappy situation <br />both for you and us. It is our belief, based on our vegetation sampling during 1990, that <br />achieving a woody plant density standard at the Meadows No. 1 mine would require either <br />a substantial effort in planting shrubs or an indefinite wait for shrub density to increase by <br />natural invasion. Sun Coal considers either alternative unacceptable. The approved pemut <br />cleazly states that there has been no intention or requirement to reclaim the Meadows No. 1 <br />mine to a woody vegetation type. <br />Thank you for your attention to this matter. Please do not hesitate to let me know if you <br />need anything further from us. <br />Sincerely, <br />Bryan .Archer <br />Manager <br />encl. <br />