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STATE OF COLORADO DIVISION OF MINERALS AND GEOLOGY Department of Natural Resources 1313 Sherman St., Room 275 Denver, Colorado 80203 Phone: (303) 866.3567 FAX: (303) 832-8106 February 14, 2005 RE~~FR4~® COLORADO DIVISION OF MIN&RALS GEOLOGY REGEAM ATION•M IN ING SAFETY•SCIENCE Tonya Hammond J.E. Stover & Associates 2768 Compass Drive, Suite 101 Grand Junction, Colorado 81506 Uialston °\ Miner°\s and Geo\o9V RE: Snowcap Coal Company 2004 Annual Reclamation Report and Revegetation Evaluation Permit No. C-1981-041 Dear Ms. Hammond: Bill Owens Governor Russell George Executive Director Ronald W. Cottony Division Director Natural Resource Trustee The Division has reviewed the 2004 Annual Reclamation Report (ARR). We have also reviewed the revegetation report prepared by Cedar Creek Associates, based on the.August 2004 monitoring of specified reclaimed areas (Revegetation Fva/nation -2004).- Our: ,. comments pertinent to these reports are separately addressed below: . 2004 Annual Reclamation Report The report adequately addresses all applicable requirements of Rule 2.04.13, and includes the required standardized reporting form. The report narrative and tables, together with the updated map (Annua/ Rec/emotion 2004) present very clear and detailed documentation of the extent, nature, and date of reclamation work performed. The map this year was modified to delineate disturbed areas that have not been reclaimetl. It appears that the combined acreage of delineated reclaimed areas, areas not yet reclaimed, and permanent .. road areas depicted on the map, correspond to the total "acres disturbed by mining activities" (241.7 acres) indicated on page 2 of the report narrative. We have two concerns specific to the information provided in the reclamation report, and one related concern regarding tamarisk control. We believe it would be appropriate to include all of the acreage listed as "Remaining Reclamation" (97.4 acres) plus "Permanent Disturbance Areas" (8.5 acres), on the standardized reporting form under "Acreage in Long Term Facilities". Thus, "105.9" should be listed in this space on the form, rather than "21.8". Please amend the standardized reporting form accordingly. There is a delineated "area not reclaimed" of roughly 10 to 12 acres on the east/southeast side of Haul Road 3, that extends from the lower segment of Coal Creek to the loadout loop track. The area is primarily west of the reclaimed conveyor route, but extends in some areas to the east of the conveyor route. Based on review of the permit and field observation, it is clear that portions of this delineated area were disturbed or have been used in support of the Roadside mining operations subsequent to August 3, 1977. These areas and tacilities include Haul Road 3, which is to be reduced in width under the approved reclamation plan, the truck scale, which is to be removed, and Topsoil Stockpile 4, which will be utilized Office of Ofice of Colorado