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STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 9663567 <br />FAX: (303) 832-8106 <br />15 October 2004 <br />Scott Wanstedt <br />Blue Mountain Energy <br />3607 County Road #65 <br />Rangely, CO 81648 <br />RE: Deserado Mine C-1981-018 <br />Revegetation Issues -Request for a Revision <br />Deaz Mr. Wanstedt, <br />COLORADO <br />DIV [s10N OF <br />MIN 6RALS <br />GEOLOGY <br />REC LAMATION•NINING <br />SAFETYKCIEN CE <br />Bill Owens <br />Governor <br />Russell George <br />Executive Director <br />Ronald W. Cattany <br />Division Direcor <br />Natural Resource Trustee <br />The Division has reviewed the information contained in the permit regazding reference <br />areas for cover and production for the Deserado mine. Several concerns have arisen as <br />described below. <br />The issue concerns reference area comparisons for cover and production. There aze three <br />designated reference areas at Deserado; 110 (Sagebrush/VJheatgrass),140 <br />(Greasewood/Sagebrush), and 150 (Colorado Wildrye). Permit Table V-15, on page V- <br />62 of the application specifies that the "Lazge Permanent" disturbance azeas ("D" Portal <br />Area, Refuse Areas, and Slot Storage Facilities) will be compazed to one or more of the <br />specified reference areas by either direct comparison or acreage-weighted comparison. <br />This is acceptable to the Division. <br />For a second disturbance category "Small & Lineaz Features" the table indicates the <br />comparison would be based on one of the approved reference areas or to an "adjacent" <br />reference site. For a third disturbance category "Drill Site Disturbances", the Table <br />indicates an "Adjacent" reference site would be used. <br />The "adjacent area" reference site concept is not adequately explained in the permit. The <br />Division's interpretation of this statement is that the Operator would run a few transects <br />within each small disturbance azea (or segment of a linear disturbance) and compaze that <br />data to data from a few transects in the immediately adjacent undisturbed area. This <br />approach, however, does not meet the reference azea criteria of 4.15.7(3). In addition, it <br />is not cleaz how the "valid statistical testing" requirement of 4.15.7(2)(c) would be <br />achieved by this method. <br />What the Division would like to see for bond release sampling would be to make logical <br />groupings of the small disturbance areas, to be adequately sampled as a logical unit and <br />Office of Office of Colorado <br />Mined Land Reclamation Active and Inactive Mines Geological Survey <br />