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<br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Deparimem of Natural Resources <br />1313 Sherman SL, Room 275 <br />Denver, Colorado 80203 <br />Phone: 1303) 866-3567 <br />FAX: (303)832-8106 <br />November 28, 1995 <br />Mr. Ross Gubka <br />Chief Engineer <br />Western Fuels-Colorado <br />P.O. Box 628 <br />Nucla, CO 81424 <br />Re: Adequacy Concerns for the New Horizon No. 2 Mine, Permit No. C-81-008 <br />Technical Revision No. 28 <br />Dear Mr. Gubka: <br />Mme.. <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Governor <br />(amen 5. Lochhcazi <br />Eaecmive Director <br />Michael 6. Long <br />oivisiort Dlreaor <br />The Division has reviewed the Western Fuels-Colorado application for a technical revision <br />(TR-28). This revision application proposes to modify Permit Section 2.05.4(2)(e). Western <br />Fuels proposes to change seed mix components, reclamation success standards, and requests a <br />variance from replacement of prime farmland on a portion of the reclaimed area. <br />The Division has identified the following concerns regarding this proposed revision. <br />1. In the approved permit, page 2.05.4(2)(e)-2, Western Fuels has previously committed Yo <br />planting hedgerows between select field boundaries (see also page 2.05.4(2)(e)-11). This <br />portion of the revegetation plan has been eliminated in the proposed revision. Since it <br />appears hedgerows have been included for wildlife utilization, please explain the <br />rationale behind elimination of these plantings and how their elimination will comply <br />with Rule 4.18(5)(j). <br />2. On page 2.05.4(2)(e)-3, seeding methods are described. Discussions DMG has had with <br />Mr. Gubka in September 1995, at the mine site, indicated that drill seeding has <br />presented difficulties in seeding sites with looser soils. Should Western Fuels choose to <br />include the option of broadcast seeding, this would be an appropriate location to include <br />a description of broadcast seeding methods and seeding rates. <br />3. Changes to Seed Mixes <br />a. Seed Mix No. 2: Temporary Reclamation Seed Mix. From the table found on <br />page 2.05.4(2)(e)-5, it is unclear if the temporary reclamation seed mix is composed <br />of one of the three species of annual grain crops or if all three species would be <br />seeded on a "temporary" site. Please clarify in the table how this seed mix would <br />be implemented. <br />