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~~" ~"~ III IIIIIIIIIIIIIIII <br />999 <br />Matthew S. Hayes <br />Hayes Environmental Services. /nc. <br />300 Lafayette St. <br />Denver, CO 80218 ~: <br />(303) 733-5368 '~ <br />.. . <br />March 9, 1996 RC(`~I\/~f1 <br />~ ~~ 1 19y6 <br />Mr. Tony Waldron <br />Division of Minerals and Geology Division of Mir~o,„,„ _ „~ology <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />RE: Vegetation Study for Proposed Coal Mine Waste Bank; Somerset Mine; Permit <br />Number C-81-022. <br />Dear Mr. Waldron: <br />Oxbow Carbon and Minerals (OCM) plans to submit a revision to allow the <br />placement of mine waste in an area that is adjacent to the existing west yard at the Elk <br />Creek facilities area (West Valley Fill). Disturbance is expected to occur in a location <br />that has been previously mapped xs having both the mountain shrubland and the juniper <br />woodland community, though the latter community is expected to be disturbed in very <br />small amounts. Several of the specifics of the proposed operation and the existing <br />permit support a finding that baseline sampling sufficiently addresses the vegetation <br />reyuvements associated with this new disturbance. These are addressed below. <br />1. The proposed disturbance is relatively small. <br />Page 2.05-20 of the approved permit document indicates that a total disturbance <br />of 71.8 acres is associated with the Somerset and Sanborn Creek mining operations. At <br />the time of the baseline study, over 75% of the disturbance was estimated to fall within <br />the mountain shrub community. The present disturbance is expected to be 4.6 acres. <br />As it is drawn now, most of the new disturbance will fall in the mountain shrub <br />community. It is OCM's position that the proposed amount of disturbance is small <br />enough compared to the existing disturbance and the size of the permit (5529 acres) <br />that no additional sampling be reyuved as part of the permitting process. <br />2. Baseline sampling in the mountain shrubland and juniper woodland communities <br />occurred within a short distance of the proposed disturbance. <br />Although the proposed disturbance presently falls outside the existing permit <br />area, the area was mapped as part of the baseline study (see Drawing E8-3391 3/3 of <br />Volume 3). As noted above, most of the disturbance would occur within the mountain <br />shrubland community. In fact, part of what was mapped as reference area would be <br />disturbed. This means that the azea to be disturbed can be expected to be very similar <br />to what is presently mapped as part of the reference area. The portion of the reference <br />area that could be impacted by the operation was not actually sampled as part of the <br />baseline study (though sample 5 is close) and therefore will not be consequential if it <br />were to be impacted and deleted from the reference area. <br />