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Brown, Sandy <br />From: ~ Mathews, Dan <br />Sent: Monday, October 24, 2005 5:21 PM <br />To: Stark, Jim <br />Cc: Brown, Sandy <br />Subject: Colowyo Annual Reclamation Report <br />Jim, I have reviewed the impressively thorough and well documented revegetation monitoring report included in Section 9 <br />of the Colowyo 2004 Annual Reclamation Report. Various 1st, 2nd, 4th, and 7th year stands were quantitatively sampled <br />and evaluated in accordance with the approved monitoring plan. The data, evaluations, and recommendations provide a <br />good foundation for a thorough reassessment of Colowyo's revegetation plan and success standards, and I believe it <br />would be appropriate to request that the operator submit a technical revision application addressing various issues <br />addressed in the report, including: <br />• Heavy grass dominance and low potential for achievement of woody plant success standard in older reclaimed areas <br />(need for establishment of a reasonable standard for these areas, with possible need for certain remedial efforts); <br />• Alternative approaches to be applied in future reclamation efforts to enhance woody plant establishment and <br />vegetative diversity; <br />• Re-assessment of woody plant density and species diversity standard targets for recent and future reclamation, to <br />more closely reflect current reclamation objectives and state of knowledge; <br />• A plan for management of annual brome, which has become established in significant densities in some areas, and <br />could significantly impact revegetation efforts. <br />I also reviewed the regraded overburden sampling documentation. It appears that the approved plan has been properly <br />implemented, and no problems are evident. One item of note is that certain of the parameter suspect levels seem to be <br />somewhat liberal, in comparison to levels of concern typically recommended in current state guidelines and relevant <br />literature. These suspect levels were apparently set back in 1983, and as noted in the letter I wrote dated January 24, <br />1983, "...the suspect levels...are based on the fact that 18 inches of non-saline, non-sodic topsoil will be replaced over <br />regraded spoils". <br />It is my understanding that Colowyo may be submitting a revision in the near future to allow for shallower topsoil <br />replacement thickness es. It might be appropriate to request that they reevaluate and amend the overburden suspect <br />levels as appropriate, in association with that revision application. <br />Dan <br />