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IIIIIIIIIIIIIIII <br /> _ STATE OF COLORAD_O__ <br /> MINED LAND RECLAMATION DIVISION <br /> Departmem of Natura'Resources <br /> e%ltAyrfi . <br /> N , <br /> 1313 Sherman Room 215 <br /> Denver.CO 8020303 <br /> 303 866-3567 <br /> FAX. 303 B32 8106 rg°6 <br /> Roy Romer. <br /> Goe , <br /> March 16, 1990 Fred R.Banta, <br /> Drvis.on DireClor <br /> Mr. Robert Sherman <br /> ROCKcastle Coal Company <br /> C/o Mr. Mark Korb <br /> Korb and Carroll <br /> 106 Oak Street <br /> Fort Collins, C0 80524 <br /> RE: 1989 Vegetation Sampling Report, Rockcastle Coal Company, <br /> Grassy Gap Mine, File No. C-81-039 <br /> Dear Mr. Korb: <br /> The Division commends Rockcastle on the quality of the 1989 vegetation <br /> report. The IMS report is complete and concise and contains vegetation <br /> information in a format sufficient to support a Phase II bond release <br /> request. The information submitted consists of raw data from plant cover and <br /> production sampling, values for sample adequacy, a summary of statistics used <br /> and summary tables for cover and production values of each pit area by plant <br /> species. A reasonable and accurate write up explains exactly what was done <br /> and the results of the sample analyses. The sampling methods and results <br /> sections are well thought out and backed up by the numbers presented. The <br /> discussion section aenerally has good suggestions. The Division does take <br /> issue witn several ODservdti0ns in the study. <br /> Forb cover numbers were very low. This could be attributed to the late <br /> sampling date (October) and/or to grazing by sheep. The IMS assertion that <br /> the light grazing of the area did not significantly compromise the sampling <br /> effort may not be valid. Inspection reports documented that grazing was done <br /> by sheep. In general , sheep selectively prefer to eat forbs over grasses. <br /> Tnis could have significantly affected the fore cover values. Because of <br /> this, the recommendation that grazing exclosures be used in the future is a <br /> good one. However, Rockcastle snould be aware that the permit states that <br /> there will not be grazing on reclaimed areas. <br /> The staff wouid refute the statement which says "The success criteria for <br /> species diversity is rather arbitrary, and perhaps not entirely realistic." <br /> The permit application document states that for any area to be considered <br /> successfully reclaimed, there must be at least four perennial grass species <br /> and one perennial forb species comprising 3% relative importance (importance <br /> equals cover in this case) each, with no one species comprising more than <br /> 40% relative [cover]. None of the reclaimed pits meets these criteria, but <br /> the reference area fits it quite well (see Table 2 - Summary of Vegetation <br /> Cover Data). Thus, as most reclaimed areas come close to meeting the success <br /> criteria the Division is not inclined to modify the present success criteria <br /> based on the information provided. — <br />