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INTEROFFICE MEMORANDUM TO: KF..N"1' GORFG\b( FROM: JANET AINNS SUBJECT: NEW ILK I P A.'1'E I LE STUUY DATE:: 04/25/03 CC: Ur\N HIiRNANUI~;% I have reviewed Picketwire Processing, LLC's 1992 Reclamation Area, Revegetation Success Study. Picketwire Processing, LLC. Submitted this study to show that reclamation of a coal waste pile with less than 4 feet of cover, as required by Rule 4.10.4((5), can still achieve reclamation success. Picketwire Processing, LLC concludes that the study indicates that successful reclamation of a coal waste pile in this locality can be achieved with only one foot of cover. The Division has to question this conclusion. The "study azea" was reclaimed in 1992 by the Inactive Mine program (IMP) of the CDMG. The IMP focuses on land stabilization and protection of environmental health and safety. IMP's goals do not aim to meet the reclamation goals of the Division's Coal program. The CDMG's Coal Program requires operators to "establish on regraded areas and all other affected lands, a diverse and permanent vegetative cover capable of self-regeneration and plant succession and at least equal, in terms of cover, to the natural vegetation of the area." (Section 34-33-121(2)(f) of The Colorado Surface Mining Reclamation Act) Results presented in the report show the vegetative cover on the reclaimed study area at 30% cover while the vegetative cover on the reference are was measured at 49% (2001 data). This would only account for 61% of the reference azea cover. If the Division were evaluating this study site with regards to a bond release request, the data would not support that reclamation success standazds were being achieved. Picketwire proposes several reasons for the relatively low vegetative cover on the study area in comparison with the reference area. Picketwire concludes that, "The reason why the Survey Area does not meet these standards are believed to be lazgely related to actions taken as a part of the previous reclamation program and not to the depth of the topsoil layer." Based upon the information presented in the report, the Division does not consider that effects the soil cover depth over the coal waste can be eliminated. Picketwire cites grazing, soil fertility, and seed-mix as reasons for the failure of the reclaimed study area to achieve similaz cover and diversity characteristics as the reference azea. However, Picketwire did not provide enough information regarding the soil to show that there was no impact from the waste material to the topsoil. Picketwire did not sample into the waste material except for one location, SS2- SS3. No samples were collected on the eastern waste pile in the study azea, and no SAR