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III IIIIIIIIIIIIIIII <br />999 <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resour[es <br />131 J Sherman 51 ,Room 215 <br />Denver, Colorado 80207 <br />Phone 1303) 866-3567 <br />FAX. {1031812-8106 <br />February 3. 1999 <br />Michael G. Altavilla <br />Seneca Coal Company <br />P.O. Drawer D <br />Hayden, CO 81639 <br />Re: Senecall dine (PermitiVo.C-80-U05) <br />Review of 1997 Revegetalion Monitoring and Shrub Esablishment Reports <br />Dear Mr. Altavilla: <br />u lvls~oN os <br />MINERALS <br />-& <br />GEOLOGY <br />iEC L~>I /~TION <br />Y.ININ V'SAf ETY <br />all Owens <br />Governor <br />Greg E. Walther <br />E.rcmwe Dueaor <br />mlchael a Long <br />Olreao. <br />The Division has reviewed the Seneca II 1997 Reve~etation Monitoring Report, dated April, 1993, and the <br />1997 Shrub Establishment Monitoring Report dated January 23, 1993. General comments regarding these <br />reports are provided below. We have also identified certain apparent deficiencies (.see Items l - 4 under <br />"Missing Information"), and have questions concemin;; the shrub establishment study. <br />1997 Reve°etation Monitorine Report <br />In this report, Seneca Coal Company (SCC) submitted result; and imetpretation of 1997 vegetation cover, <br />production, and woody plant density sampling conducted within reclaimed units initially seeded in 1990, <br />as well as corresponding data from [he Mountain Brush and Sagebrush Reference Areas. In addition, shrub <br />density data for the Wade Pasture reclamation area vrLS submitted. The data was collected using a two <br />stage sampling procedure which allowed for attainment of sample size adequacy with significantly fewer <br />quadrants than would be required for simple random sampling. This approach may have widespread <br />applicability for sampling woody plant density on reclaimed lands. <br />Introduced Species. Species Diversity and Woody Plant Establishment <br />The Discussion section on page 21 of the report notes that introduced perennial Forbes and grasses account <br />for 7(I% of the relative vegetation cover in the 1990 reclamation. The narrative points out that titer <br />milkvetch increased in relative cover from 4.9% in 1994 to I u.l',o in 1997, and the[ alfalfa increased from <br />6?0.o relative cover to 13.1;'° relative cover. "fhe noxious weed, Canada thistle, decreased slightly from <br />5.5°io to 4%, over the period. The section concludes with the following paragraph: <br />The aggressiveness ofnon-native species has repea[edl}' demonstrated the ability [o <br />overwhelm native species in Seneca Il reclaimed areas. The utility of env non-native <br />species in the long-term goals o(Ihe reclam:tlion needs to be carefully examined in <br />light of the probability that even small amounts ofnon-natives in original seed mixes <br />will lead to non-native dominance as they continue year after year to overwhelm <br />natives. <br />The 1990 reclamation easily surpasses permit standards for cover and herbaceous production, but as <br />typically has been the case for areas seeded with the general upland seedtnix, the estimated wood}• plant <br />density mean is well below the permit standard (184 stems per acre reclaimed, vs. 1000 stems per acre <br />standard). While average total species density for the reclaimed area approaches reference area values (30 <br />species/ 100 sq. m. for the reclaimed area vs. 36 to 38 species/ 100 sq. m. for the reference areas), three <br />