2008-04-29_REVISION - C1981019

• Permit No: C1981019
• IBM Index Class Name: REVISION
• Doc Date: 4/29/2008
• Doc Name: Preliminary Adequacy Review
• From: DRMS
• To: Colowyo Coal Company
• Type & Sequence: TR72
• Email Name: JRS
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
29 Apri12008
Mr. Kurtis Blunt
Colowyo Coal Company, LP
5731 State Highway 13
Meeker, CO 81641
Re: Colowyo Mine C-1981-019
Preliminary Adequacy Review -Technical Revision 72
Dear Mr. Blunt:
COLORADO
DIVISION O F
RECLAMATION
MINING
- &-
SAF ETY
Bill Ritter, Jr.
Governor
Harris D. Sherman
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
The Division has received your 14 March 2008 submittal of Technical Revision 72. Thank you for
the timely submittal of this revision. The Division has reviewed the submittal and has consulted
with the Colorado Division of Wildlife with regards to the proposed reclamation plan. A letter from
DOW regarding the proposed reclamation plan is attached.
In general, the TR-72 plan as submitted addresses many of the objectives and approaches discussed
in relation to Stipulation 8. The plan includes seedmix and seeding technique modifications, and
references the use of numerous strategies that would likely enhance woody plant establishment and
species diversity. However, an over-all concern the Division has is that the plan in a number of
instances does not include an acceptable "bottom line" commitment to practices that will be
implemented. Many aspects of the plan would be left to the discretion of the reclamation manager
or field supervisor, to be applied "where possible", or "depending on available materials and
equipment". The Division recognizes the need for a certain amount of flexibility to allow for "field
fitting", but the plan needs to incorporate a level of specificity, with defined commitments regarding
techniques that will be employed on appropriate (approximate) locations on the regraded surface,
along with description of the topographic site characteristics or other factors that defines where the
techniques will be applied, and the approximate, or minimum acreage associated with particular
practices. It is the operator's responsibility under the permit to ensure that needed materials and
equipment are available to implement the appropriate enhancement measures. The Division has
reviewed your submittal and has the following adequacy questions.
Backfilling and Grading_[2.05.4(2)(c) and 4.141
On amended page 2.05-42 there is reference to creation of topographic features as a
component of the ecological reclamation approach, including "site specific opportunities for
development of convex and concave surfaces to encourage snow entrapment". The Division
Office of Office of
Mined Land Reclamation Denver Grand Junction Durango Active and Inactive Mines