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'1f - <br />III III III III IIII III • <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanmem of Natural Resources <br />1313 Sherman 51., Room 215 <br />Denver, Colorado 80?03 <br />Phone: 1303)866-3567 <br />FA%: (303) 83'_-8106 <br />• <br />STATE OF COLOlZADO <br />MEMO <br />~~~~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Rome <br />Governor <br />June 22, 1994 lames S.lochhead <br />E.ecutive Director <br />TO: Wally Erickson Michael Q. Lonp <br />FROM: Tony Waldron '` ~ Division Dueaor <br />RE: Colorado Coal Mine No. 1 (C-81-024), Technical Revision-013 <br />Per your request, I have reviewed technical revision 013 from <br />Colorado Coal Mine No. 1 (GCMG). The revision requests changing <br />their species diversity standard for vegetative success to <br />eliminate the warm season grass component. Following are my <br />comments and recommendations for this proposal. <br />The current vegetative success standard for species diversity is; <br />two cool season grass species, two warm season grass species, two <br />forb species, and two shrub species, each comprising at least 3$ <br />relative cover but less 40% relative cover. The proposed change is <br />for; two cool season grasses and two forbs each with at least 3$ <br />and less than 40% relative cover and a minimum of an average of 333 <br />stems per acre on a postmining land use of pasture. <br />As you will note the proposed standard eliminates the warm season <br />grass component completely and provides for a new shrub density <br />standard. The new standard also states that the postmining land <br />use is pasture which I think is incorrect. The reasoning behind <br />eliminating the warm season grasses is that there were actually an <br />abundance of cool season grasses ( in theory) prior to intensive <br />overgrazing which caused the warm season grasses to become <br />dominant. Therefore, by restoring the cool season grasses it will <br />more closely resemble the vegetative community that existed prior <br />to the overgrazing which caused the warm season grasses to become <br />dominant. <br />I have contacted Don Martin of the Walsenburg SCS office to discuss <br />what the potential plant community would be in the mine area. Mr. <br />Martin indicated that the Range Site Description for the mine area <br />is Loamy Foothills and it is probably correct that the community <br />that existed prior to any cattle grazing contained more cool season <br />grasses than warm season grasses. Mr. Martin indicated that it was <br />probably 60/40 cool season to warm season. I checked the Loamy <br />Foothills range description and it did indicate that the vegetative <br />potential for that area was dominated by cool season grasses. <br />However, the warm season component is still 25% by cover and this <br />