REP41510

• Permit No: C1981019
• IBM Index Class Name: Report
• Doc Date: 10/2/2006
• Doc Name: 2004 ARR Comments and Responses
• From: Colowyo Coal Company L.P.
• To: DRMS
• Permit Index Doc Type: Annual Reclamation Report
• Media Type: D
• Archive: No

Senior Environmental Engineer
Land Manager
[phone]
Mr. James Stark
~ECE11/~p
OL'T ~ L 2006
Division of Reclamation,
Mining and safety , September 28, 2006
~. ~,~Diyision o£Reclamation, Mining and Safety__ _ _ _~ - ~ _ _ __ ~ _ _ _ _
1313 Sherman St. Room 215
Denver, CO 80203
RE: 2004 Annual Reclamation Report Comments and Responses, Colowyo Coal Mine,
Permit No. C-81-019
Dear Mr. Stark:
Colowyo is submitting their responses to your comments concerning the 2004 Annual
Reclamation Report. Please review the following responses as they respond directly to each of
the items that were sent as part of your initial review.
There is heavy grass dominance and a low potential for achievement of woody plant
success standard in older reclaimed areas of the East Pit. There needs to be the
establishment of a reasonable woody plant standard for these areas and possible remedial
efforts to achieve that end.
Colowyo Response
Colowyo is currently evaluating this issue and has been in correspondence with both
the Division and the CDOW regarding possible resolutions. Topsoil depths, seed
mixes and reclamation plans were reviewed and deemed appropriate for this area
through the permitting process. The reason why Colowyo established a reclamation
plant community that looks like it does is due to the fact that we, the Division and
the seasonal variations have selected it. Pressures working against the development
of a long-term sustainable shrub community are compounded by predation of forbs
and shrubs by elk and deer during establishment years, along with thick topsoil
replacement depths that continues to compound the issue. Due to the circumstances
surrounding this issue, Colowyo deems that there is no change necessary to the 2004
Annual Report regarding this issue, due to the fact that this issue is not an Annual
Report change. A future revision will be submitted and discussed with the division
to address this change in the permit.
2. CCC needs to use alternative approaches future reclamation efforts to enhance woody
plant establishment and vegetative diversity. These may include varying topsoil depths,
reduction of competition from grasses and/or fencing.