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DEPARTMENT OF NATURAL RESOURCES Davin h. GetcheA Executive Director MINED LAND RECLAMATION DIVISION DAVID C. SHELTOH, Dlnctor RicheN D. Lemm Governor March 8, 1984 Mr. Mike Campbell Pittsburg and Midway Coal Mining Company P.O. Box 176 Oak Creek, Colorado 80467 Dear Mr. Campbell: As the result of my recent assignment as lead Inspector for the Edna Mine, I have received some correspondence from you concerning the need for a grazing plan at this mine. The need for such a plan is based upon the Dlvison's regulation 4.15.5, which requires that: "(1) when the approved postmining land use is range or pasture land, the reclaimed land shall be used for livestock grazing at a grazing capacity, and using management techniques approved by the Division approximately equal to that for similar properly managed non-mined lands, for at least the last two full years of the liability period required under 4.15.7. when approved by the Division, simulated grazing studies may be substituted for the use of livestock. (2) Grazing must not commence until the permittee has demonstrated, to the satisfaction of the Dtvlsion, that the vegetation on the reclaimed surface is adequately established, and could be expected to withstand grazing". A review of the grazing plan submitted to the Dtvlsion by you on January 10, 1984, showed the following areas of concern: 1)There was no deScriptlon of what management techniques are currently in use for similar, properly managed, non-mined lands 1n the mine area, or how the operator was proposing to use similar techniques. 2) The plan does not address how the operator will determine the proper duration of grazing on any specific areas to prevent overgrazing and subsequent deterioration of the vegetation. 3) The plan does not discuss how newly reclaimed areas will be protected from damage by livestock. 423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. (303) 866-3567 ~II ~I~~I~~I~~~~~~I~ 999