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INTEROFFICE MEMORANDUM <br />TO: BYRON WALKER <br />FROM: ).1NET B1NNS <br />SUBJECT: KEENESB G _ A UAL RECLA \fATION REPORTS <br />DATE: 09/03/03 <br />CC: DAN tIERNANDEL <br />Coors Energy Company submitted the 2002 ARR on February 28, 2003. Submittal was two weeks after the <br />February 15'" due date as stated in Rule 2.04.13. The Keenesburg Mine permit, C-1981-028, page 117, has <br />committed to submitting the Annual Reclamation Report by the end of February each year. The submitted report <br />is in compliance with the approved permit. <br />Vegetative success is based on comparison with the approved Osgood Reference area. Cover success is based on <br />total vegetative cover, which includes woody plant cover. Production is based on herbaceous vegetative cover. <br />Species composition is based on relative cover of the individual plant species compared to a composition <br />standard. There is no woody stem density requirement for the Keenesburg Mine reclamation success standard. <br />In 2002 Colorado experienced a significant drought statewide. Precipitation data reported by CEC indicates that <br />precipitation amounts were roughly 60% of what would be received in an average precipitation year. Timing of <br />when precipitation is received is as significant as the quantity received. 2002 experienced a very dry spring and <br />summer. Vegetation response would be expressed by reduced growth, earlier drying up, and inhibited <br />germination. Though CEC's data reflect the plant communities' response to drought conditions, comparison with <br />the Osgood reference area shows similar response in the undisturbed reference area as well. <br />In 2002, total cover measured in the Osgood reference azea was 22.6%. This is less than 50% of the recorded <br />cover value of 48.8% that was measured in 2001. CEC measured total vegetative cover in the 1995 Reclaimed <br />azea at 23.2%, 1997 Reclaimed area at 23.2%, and the 1998 reseeded/intexseeded area at 29.8%. Based on this <br />data, all sampled areas would meet the cover standard. The data represents the 7`h growing season for the 1995 <br />Reclaimed azea and the 5'" growing season for the 1997 Reclaimed area. The significant reduction in vegetative <br />cover during the 2002 sampling is indicidve of the drought conditions. <br />Herbaceous productivity measured in the Osgood reference area in 2002 was 26.26 grams/MZ (2341b/acre). <br />Herbaceous productivity measured on the 1995 Reclaimed, 1997 Reclaimed, and 1998 Reseeded areas was 52.13 <br />grams/MZ (465 lb/acre), 61.15grams/MZ (545 lb/acre), and 79.1 grams/MZ (705 lb/acre) respectively. <br />Productivity values are drastically reduced from preceding year values as a result of the severe drought conditions. <br />All three measured reclaimed azeas exceed the herbaceous productivity standard based on reference area <br />production. <br />2002 sampling data show that species composition was not met for any of the sampled areas. Not even the <br />Osgood reference area would meet the required vegetation diversity standard found in the permit. The diversity <br />standard calls fox 7 perennial non-noxious species with greater than 3% relative importance but less than 40% <br />