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b. In the 1983 Annual Hydrologic Monitoring Report Kerr Coal requested <br />a revised surface and ground water monitoring plan. The revised plan <br />proposes monitoring areas to be affected by mining through phases tied <br />to mine expansion. The Division does not perceive any problem with <br />granting this request and is processing it as a minor revision. <br />4. Vegetation <br />a. During the course of the permit review a number of decisions were <br />made concerning revegetation success standards for the Walden tipple. <br />Kerr Coal established a reference area approximately 1500' east of the <br />tipple for the purposes of sampling and establishing revegetation <br />success criteria. The information obtained from the July 1981 sampling <br />and Included in the November 10, 1981 correspondence to the Division was <br />never incorporated Into the permit document. In order to maintain a <br />complete record, Kerr Coal Should Incorporate this Information into the <br />permit document. <br />b. Within the November 10, 1981 correspondence regarding revegetation <br />standards at the tipple, a species diversity standard was proposed by <br />Kerr Coal. The Division's record does not indicate that the tipple <br />species diversity standard was ever accepted by the Dtvislon. At this <br />time the Division does acknowledge the acceptance of that proposed <br />standard with the proviso that at least one of the three dominant plant <br />species be a forb, and that no one of those dominant plant species shall <br />comprise less than 3% of the total plant composition. <br />c. On page 816.161aaaa and 1n correspondence to the Division dated <br />January 73, 1981 (p. 13) Kerr Coal outlines their proposed revegetation <br />monitoring program. In part, it is stated, "results of data collected <br />from the general revegetation program will be submitted to both Colorado <br />MLRD and OSM in the form of an annual reclamation report (emphasis <br />added) from Kerr Coal." To date, the Dtvislon has not received any <br />reclamation reports. Kerr Coal should submit any previously prepared <br />reports to the Division. Future reports should be submitted at the same <br />time as the annual hydrology report. <br />5. Fish and Wildlife <br />During the permit review, numerous concerns were raised regarding <br />mitigation of Impacts to sage grouse wintering range. Kerr Coal <br />proposed a fertilization mittgatlon plan and stipulation No. 10 was <br />written to modify the plan. Subsequent to the permit approval, Kerr <br />Coal submitted Technical Revision No. 1, which requested termination of <br />the mittgatlon plan. This technical revision was approved by the <br />Division and relieved Kerr Coal of the requirements of Stipulation No. <br />10, since it was determined that this mining and reclamation operation <br />would not significantly impact the sage grouse. <br />6. Operations Plan <br />Since permit issuance Kerr Coal has greatly reduced the scope of <br />operations at the Marr Strip, due to economic conditions. The projected <br />timetables present to the permit application no longer accurately <br />reflect the scope or timetable for mtning and reclamation at the Marr <br />Strip. Kerr Coal should submit a revised (proposed) schedule for <br />mtning, backfilling and grading, and reclamation activities at the mine. <br />