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<br />STATE OF COLORADO <br />Roy Romer, Governor <br />DEPARTMENT OF NATURAL RESOURCES <br />MINED LAND RECLAMATION DIVISION <br />FRED R. BANTA, Dlreator <br />PATE: February 2, 1988 <br />T0: Jim Stevens <br />FROM: Gregg Squire P Q <br />RE: Wyoming Fuel Company's Response to Stipulation 21 - File No. C-81-012 <br />I have reviewed the material submitted by the applicant (Vegetation Report for <br />New Elk Mine - Grey stone Development Consultants, Inc., October, 1987) in <br />response to the requirements of Stipulation 21 of the findings document. My <br />comments are as follows: <br />11. The requirements of section A of the stipulation have been met, the <br />report has been submitted as required. <br />2). The requirement of section 8 of the stipulation does not appear to <br />have been met. The report does not demonstrate the equivalence of <br />the reference areas to the respective affected areas. <br />The applicant's permit application (pages 2.05-50 and 51) states that <br />revegetation standards "will be judged according to Sections 4.15.8 and <br />4.15.10 of the regulations". If these standards are followed the applicant <br />will have to base the shrub density standards on baseline counts of 19,522 <br />shrubs/acre in the willow carr area and 16,52.8 shrubs/acre in the disposal <br />area. Achieving these standards will be very difficult. There is a possible <br />alternative to meeting these standards. <br />Section 4.15.8(7) of the Regulation's allows fora lesser or greater shrub <br />density standard "when evidence provided by the permittee demonstrates that <br />such lesser or greater standard would better achieve the goals of the approved <br />primary postmining land use or uses". The applicant could provide such a <br />demonstration and request a lower shrub density standard in these areas. <br />/bdc <br />5029E <br />423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203-2273 Tel. (303) 866-3567 <br />