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STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman SL, Room z15 - C O LO RAD O <br />Denver, Colorado 80203 o t V[ s I O N O F <br />Phone: (30318663567 <br />~ MINERAL S <br />FAX: (3031 a3z-slob G E O L O G Y <br /> 0.ECLANATION•NINING <br /> SAFETY•SCIf NCE <br />29 April 2005 <br /> gill Owens <br />Mr. Jim Stover Governor <br /> <br />Mimec <br />Inc Russell George <br />, <br />. e.ecueve Do-ectnr <br />2768 Compass Drive, Suite 101 Ronald W. Cottony <br />Grand Junction CO 81506 Division Dimctor <br /> Natural Resource Trustee <br />RE: Blue Ribbon Mine (C-1981-047) Comment Letter, 2004 Revegetation <br />Monitoring Report <br />Dear Mr. Stover: <br />The Division has reviewed the submittal of the 2004 Revegetation Monitoring Report for <br />the Blue Ribbon Mine. There are several comments as follow. <br />The 2004 Revegetation Monitoring Report, prepazed by Cedaz Creek Associates <br />includes narrative description and quantitative sampling data to document the <br />vegetative conditions of the Blue Ribbon reclaimed azeas and proposed new <br />riparian and grassland reference azeas. The report also includes data and <br />justification to support replacement of current technical standards for herbaceous <br />cover and production with proposed reference area comparison of same, and <br />justification to reduce the perennial forb relative cover requirement from 5% to <br />3% relative cover. <br />In addition, the report contains within Section 2.5 and Section 3.4, discussion of <br />revegetation success demonstration approaches (including sampling approaches <br />and statistical methods) proposed or recommended for use in future bond release <br />demonstrations. <br />The proposed/recommended success demonstration approaches and sample <br />design layout presented in the report should be consolidated and <br />incorporated into the approved permit. <br />2. Section 2.1 of the report describes sample layout employed in the 2004 sampling. <br />Narrative states that the sample layout protocol "lazgely followed procedures <br />detailed in permitting documents". The 2004 report contains considerably more <br />detail than the approved permit, however, and the sample layout does differ <br />substantially from that described in the current permit. The systematic design <br />with random start differs from the simple random approach that seems to be <br />Office of Office of Colorado <br />Mined Land Reclamation Active and Inactive Mines Geological Survey <br />