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Savage and Savage Environmental <br />practical solutions for environmental issues <br />4610 Haystack Drive 970 674 8080 telephone <br />Windsor, Colorado 80550 970 674 8088 facsimile <br />savageandsavagena gwest.net <br />August 13, 2008 <br />RECEIVED <br />AUG 14 2008 <br />Ms. Janet Binns, Environmental Protection Specialist Divisluta vi ?:ation? <br />Mining and S*ty <br />Colorado Division of Reclamation, Mining, and Safety <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />Re: Request for Suspension of 2008 Vegetation Monitoring and Phase III Vegetation <br />Sampling: Coors Energy Company Keenesburg Mine (CDRMS file C-1981-028) <br />Dear Janet: <br />On behalf of Coors Energy Company, we are requesting the Division's concurrence for <br />suspension of annual vegetation monitoring for calendar year 2008 and second year <br />vegetation sampling for eligible Phase III areas (1985/1986/1987 and 1995/1997 <br />reclaimed areas) at the Keenesburg Mine. <br />As you observed during your last inspection, the lack of late spring and summer moisture <br />has resulted in little significant growth of vegetation on the reclaimed areas at the mine. <br />Our site inspection on August 7, 2008 confirmed your observations and discussions with <br />Don MacDonald and Danny Kipp regarding the condition of revegetation at the site. <br />While there was little significant growth of perennial (and annual) species, it was noted <br />during our inspection that the long-lived cool and warm season graminoids were present <br />and alive, simply stunted this year due to the lack of moisture. A review of the <br />precipitation records from the mine revealed a 56.4% below average total of precipitation <br />this year (January-July 2008) and a 27.2% deviation below the average for September- <br />July precipitation (from which we calculate cover and production success criteria). <br />For this reason we are requesting that the Division concur in writing with our request to <br />suspend vegetation monitoring for the 2008 calendar year. Based on my reading of rule <br />4.15.7(5), Phase III vegetation sampling at the mine may be suspended for 2008, with the <br />understanding that in order to be eligible for Phase III bond release, vegetation sampling <br />must take place in either 2009 or 2010 and meet the revegetation success criteria (when <br />combined with the Phase III data from 2007).