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REP33202
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Entry Properties
Last modified
8/25/2016 12:09:31 AM
Creation date
11/27/2007 6:26:26 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981041
IBM Index Class Name
Report
Doc Date
3/19/2007
Doc Name
2006 ARR Review Letter
From
DRMS
To
Snowcap Coal Company, Inc.
Permit Index Doc Type
Annual Reclamation Report
Media Type
D
Archive
No
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;{ <br />2006 ANNUAL RECLAMATION REPORTlREVEGETATION <br />EVALUATION REVIEW <br />Annual Reclamation Report <br />On page 2 of the report, under Item (e), please include reference to the <br />herbicide used in association with the tamarix removal project. <br />Revegetation Evaluation Report <br />2. Toward the end of page 2 and continuing on page 3 of the revegetation report <br />prepazed by Cedar Creek Associates, Inc., there is discussion of the species <br />diversity standard. Narrative on page 2 does not accurately reflect one aspect of <br />the standard. The report references the standard as specifying that "no reclaimed <br />azea shall have a single species that represents > 70% relative cover". In <br />actuality, the approved standard states: <br />No reclaimed area shall have a single species that represents <br />greater than 70% relative cover, with the exception of annual <br />grasses. The annual grass component shall not exceed 70% <br />relative cover unless the annual grass component in the <br />corresponding reference area also exceeds 70%. In such <br />instances, the relative cover of the annual grass component of the <br />reclaimed area shall not exceed the relative cover of the annual <br />grass component in the reference area by more than 5%. <br />The report narrative on page 3 recommends modification of the standazd, to <br />reflect the fact that cheatgrass (an annual grass) may exhibit relative cover values <br />surpassing 70% in some years, in reference areas as well as reclaimed areas. We <br />acknowledge this point, however the currently approved standard includes an <br />allowance to address this concern. As such, we do not believe the modification <br />recommended in the report is warranted. Please respond as to whether you <br />concur that the issue raised is adequately addressed by the current standard. <br />On Table 3 (Relative Cover Summary) for the various sampled aeeas, as well as <br />individual cover tables for specific reclaimed areas, intermediate wheatgrass <br />(Thinopyrum intermedium) is listed as a significant cover component for several <br />sites (North Decline Mine Dewatering System, Substation "B", CRDA-1 Upper <br />Benches, and South Fan-West (Borrow Area). Intermediate wheatgrass has not <br />been included in the approved seed mixes for any of the Roadside Mine areas, and <br />it seems unlikely that it would have established at the rates indicated for multiple <br />
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