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.~ <br />SrATt OI COl OF2A00 Nu'H nHD ~MM. Gnvin n n~ <br />DEPARTMENT OF NATURAL gESOURCES <br />H arras D. Su crman. Execullve Director <br />NIINFaI LAND RF.I:LAMA'TION <br />ly23 Centennial Building, 1313 Sherman Street <br />Denver, Colorado 80203 Tel. (303) 8393567 <br />Hamlet J. Barry, I I I, <br />Director <br />June 11 , 198() <br />Mr. Bruce Humphries <br />U[a1T International, Inc. <br />Box 187 <br />Craig, Colorado 81625 <br />Dear Mr. Hamphries: <br />There are two points in your letter of May 30 that I would like to <br />comment on. <br />First, what do you consider to be a "major" vegetation type? <br />The Colorado regulations will allow waiving the reference area re- <br />quirement for those plant communities of limited areal extent re- <br />lative to the size of the disturbed area (tentatively defined as 2 <br />to 3% or less), which do not constitute critical or unique habitat, <br />For these "minor" plant communities, we would allow either the use of o, c~5~ .., <br />premining data as a success standard (4,15,7 (3)(b)):~ As a related <br />question,`Fl~ow does Utah International plan to demonstrate revegetation <br />success for cropland areas? <br />Secondly, I would like additional information concerning your <br />concept of a regression equation relationship between permanent reference <br />sites and "pre-mine reference sites," (What is a "pre-mine reference <br />site?") I know we have discussed this before, but never in sufficient <br />detail to allow me to make a finding as to whether or not your approach <br />will be acceptable under the Colorado regulations.. <br />It would certainly be to your advantage to resolve this matter as soon <br />as possible, I have enclosed a copy of what we hope is the final <br />version of 4.15 (Revegetation Requirements), I would suggest that you <br />send us a written explanation of your proposed regression equati ~:-- <br />approach, including sample calculations to show how it would be applied, <br />An explanation of how the requirements of 4.15.7 would be met should also <br />be included. <br />Once I have had a chance to review your proposal, I will let you know <br />whether or not I think it will be acceptable, If there are any problems, <br />or if I need additional information, I would suggest we set up a meeting <br />at that time. <br />Sincerely, <br />Carol Pahlke <br />Re emotion Specialist ~ t'P• <br />