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Y - <br />DIVISION OF MINERALS AND GEOLOGY <br />Depsmrent of Natural Resources <br />1 31 1 Sherman 51., Rnom 215 <br />Denver, Colorado N0203 <br />Phone: 003) Ahb-356: <br />FAX: 1303)83?-8106 <br />DATE: July 31, 1998 <br />TO: Harry Ranney <br />FROM: Dan Mathews ~~ <br />Ft~:~,:..:''iIED <br />au~~: ,a <br />DIV. OF M:NY~ ~: ~i.S <br />8 GEOL.q~a __ <br />RE: New Horizon TR-36 (Revegetation Standards) <br />Permit No. C-81-008 <br /> <br />,~ <br />II~~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Governor <br />lames S. Luchhead <br />Executive Director <br />Michael B. Long <br />Derision Director <br />I have reviewed the amended revegetation section of the New Horizon Permit; submitted under <br />cover letter dated July 15, 1998. Various pages were amended in response to an adequacy letter <br />you issued back in March, which I am assuming incorporated adequacy comments I made in <br />memos of March 1 1, and March 16. The operator did not respond to the adequacy comments <br />item by item, but 1 attempted to scour the amended plan to determine which issues were <br />adequately addressed,and have organized this memo accordingly. <br />Issues from March 11 memo <br />la. Questions raised in this item were not specifically addressed. A response is requested. <br />lb. Narrative on amended page 2.05.4(2)(e)-16 addresses, in general, the concerns identified <br />in this item. The success standard approach (technical standazd based on average <br />production levels provided by local farmers, and confirmation from NRCS based on soil <br />types and regional practices) would appear to be acceptable; however a specific <br />explanation regazding why the current soil type based standard is inappropriate should be <br />provided. <br />lc. Reference to three year average yields was deleted, as appropriate. <br />2. As with question la and lb,justification for why the current soil series based standard is <br />not considered appropriate should be specifically addressed. Apparently, the original <br />standards were based on more intensive management inputs than typically practiced in the <br />region, and were based on the assumption of three cuttings per year, which is also not <br />typical. These factors should be explicitly stated, either in the application text or in an <br />accompanying letter. <br />3a. Text was satisfactorily anrended. <br />III IIIIIIIIIIIII III ~ <br />STATE OF CC~~~iv~v0 <br />RECEIVED <br />~ ~ <br />DIV Of MINERALS <br />