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III IIIIIIIIIIIII III <br />crpRUs <br />Yampa Valley <br />Cyprus Yampa Valley Coal Corporation <br />29587 Routt County Road N27 <br />Oak Creek, Colorado 80467 <br />303-879-3800 <br />June 16, 1994 <br />R~~EIVEp <br />Kent Gorham JUN <br />Environmental Protection Specialist 2'2 1994 <br />OfficeoofoMinedeLand Reclamation Cr~~r`~oncr+t:rr,~,r,SauCLU~ <br />1313 Sherman Street, Room 215 y <br />Denver, Colorado 80203 <br />RE: Mine 1, 2 and Eckman Park, Permit No. C-81-071, Phase II <br />and Phase III Bond Release, Block A, Response to Division <br />Concerns <br />Permit No. C-81-071 <br />Dear Mr. Gorham, <br />Enclosed are additional responses pertaining to concerns raised <br />during our meeting with the Division to discuss issues associated <br />with the pending bond release application, particularly those <br />relating to sample allocation in Block A. <br />There was concern about the clumping of transects in certain <br />parcels, specifically OEJ8-5, OA5-4, PEK23-0. The nature of parcel <br />OEJ8-5 is a reclaimed haul road, therefore it is long and narrow. <br />Because of that the samples were systematically allocated. It was <br />decided that a better overall representation would be achieved with <br />more transects than the one per four acre standard. The clumping <br />in parcel OA5-4 was to insure that the whole parcel was <br />represented. It is unclear why the density of transects in parcel <br />PEK23-0 is greater than the standard. It should be noted that in <br />1991 the transect to acre ratio is correct. As discussed, this was <br />the first year Phase III sampling and CYCC was working with the <br />Division to establish sampling procedures. I can assure you that <br />there was no underlying agenda to clump transects in seemingly <br />higher quality reclamation. <br />In reviewing the data it has come to my attention that for 1990 in <br />parcel ODJ97-3 the cover and production means were below that of <br />the reference areas. Looking back through the actual field data <br />sheets, there are comments on each one, that grazing had occurred <br />before sampling. A further review of notes in the log of the <br />sampling crew for that year indicates the that a neighbor's sheep <br />had found a hole in the fence. CYVCC cattle had not been in this <br />area. This would account for the low mean. <br />Additionally looking at the areas where the transect to acre ratio <br />