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F • -2- -- The Division recognizes that forb reestablishment iE often harder than grass reestablishment. Forbs formed an important component of the pre-mining vegetative community at the mine site and to exclude them from the post-mining community would be inappropriate. Coors has incorporated three (3) fortis into the approved seed mix, and it is the Division's belief that the reestablishment of one at 3% relative importance is a feasible minimum goal. It should be pointed out that Coors is not restricted to the utilization of the species in the seed mix for the calculaCion of species diversity. The Division and many operators have noted significant contributions by volunteer species on revegetated surfaces. In the. instance that a forb (or grass) which was not in the seed mix has reestablished itself at a level greater than 3% and less than 40% of the relative importance, this species should be included in the species diversity determination. The Division's proposed standard evaluates only on the basis of species present on the reclaimed surface. Additionally, Coors may wish to revise the approved seed mix in order to enhance the probability of attaining the species diversity goal. Revision should be in consultation with the Division, and should be carefully weighed with respect to attaining the further goals of cover and productivity. Due to the dynamic changes in state-of-the-art reclamation technologies and increasing knowledge with respect to these techniques, the Division realizes that standards set at a given time may need to be changed. To this end it is accepCable to the Division that periodic review of the pertinence and acceptability of standards take place. To the agreed standard for species diversity, Coors may wish to add such a.request as this (e.g.): "Coors Energy Company and the Division agree to periodically reevaluate the species diversity standard for the Keenesburg mine and adjust it as warranted by new site-specific data obtained during operations at the mine." At this point I would restate the Division's proposal for a species diversity standard at the Keenesburg mine: The operator shall establish a minimum of seven (7) perennial species, of which fbur (4) are warm season grasses, two (2) are cool season grasses, and one (1) is a forb, to be measured using relative frequency (taken by species). No one component (species)of the above should comprise greater than 40% relative importance, nor less than 3% relative importance. Sandsage is to be reestablished as the woody plant species to the woody plant density standard. This standard is subject to periodic reevaluation and adjustment as warranted by site-specific. data provided by the operator to the Division. In order to reach agreement on this matter as soon as possible, I would appreciate your response by mid July. If you have any questions please feel free to contact me. Sincerely, ~C Q,ypy s~ Michael S. Savage Reclamation Specialist MS:ep cc: 6. Liddle ~