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iii iuiiiiiiiiiiiii <br />999 <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />i } I3 Sherman St.. Room ? 15 <br />Denver, Colorado 80203 <br />Phone: U03186rr7567 <br />FA?(: (303) 8J2-8106 <br />February 3, 1999 <br />Michael G. Altavilla <br />Seneca Coal Company <br />P.O. Drawer D <br />Hayden, CO 81639 <br />Rr. Seucca II ~imc (Permit No. C-30-005) <br />Review of 1997 Revegetation Monitoring and Shrub Establish men[ Reports <br />Dear Mr. Alt:tvilla: <br />uioitloN ur <br />MINERALS <br />-&- <br />GFOLOGY <br />~lECLPM1ATION <br />n INiNG•SAfETY <br />Bill Owens <br />Governor <br />GregE vfalcher <br />E.ecwive Director <br />•v~chael B. long <br />O~rectnr <br />The Division has reviewed the Seneca II 1997 Revegetation Monitoring Report, Jated April, 1993, and the <br />1997 Shmb Establishment Monitoring Report dated January 23, 1998. General comments regarding these <br />repons are provided below. We have also identified certain apparent deficiencies (see Items I - 4 under <br />"Missing information"), and have questions concerning the shrub establishment study. <br />1997 Reveeetation Monitoring ReDOr[ <br />In this report, Seneca Coal Company (SCC) submitted results and i;nerpre[a[ion oC 1997 vegetation cover, <br />production, and woody plan[ density sampling conducted within reclaimed units initially seeded in 1990, <br />as well as corresponding data from the Mountain Brush and Sagebntsh Reference Areas. [n addition, sltmb <br />density data for the Wadge Pasture :eclamation area was 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 strntpling. Tlris approach may Rave widespread <br />applicability for satnplhtg 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 thatintroduceLi perennial Forbes and Brasses account <br />far 70°,% of the relative vegetation cover in the 1990 reclamation. The narrative points out that titer <br />milkvetch increased in relative cover from 4.9°/n in 1994 to la.l"a in 1997, and that alfalfa increased [rom <br />6.2%o relative cover to 13.1°'o 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 repeatedl}' demonstrated the ability to <br />overwhelm native species in Seneca 11 reclaimed areas. The utility of a~ non-native <br />species in the long-term goals of [he reclamation needs to be carefully examined in <br />light of the probability that even small antottnts of non-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 seedinix, the estimated woody plant <br />density mean is well below the permit standard (134 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 [he reference areas), three <br />