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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />DATE: October 10, 2008 <br />TO: Marcia Talvitie <br />COLORADO <br />D IV IS I ON OF <br />RECLAMATION <br />MINING <br />SAFETY <br />Bill Ritter, Jr. <br />Governor <br />Harris D. Sherman <br />Executive Director <br />FROM: Joe Dudash ?? Ronald W. Cattany <br />Division Director <br />Natu I Resource Trustee <br />RE: New Horizon me, Permit Number C-1981-008, Western Fuels Colorado <br />SL-11, Partial Phase 1 and 2 Bond Release, Soil Loss Comparison Adequacy <br />Review <br />As you had requested, I have reviewed the soil loss comparison submitted by Western Fuels <br />Colorado for the Partial Phase 1 and 2 Bond Release (SL-11) at the New Horizon 2 Mine. My <br />review has shown that the Division can accept the soil loss comparison methodology and <br />conclusions as submitted. <br />The Division's guideline document for bond releases, as well as the Rules and the Act, require <br />that, for a phase 2 bond release, no suspended solids in excess of pre-mining levels for the same <br />area or in excess of suspended solids levels found on adjacent undisturbed areas can be generated <br />from the reclaimed area. Western Fuels Colorado used the revised universal soil loss equation <br />(RUSLE) to demonstrate compliance with this requirement. No sediment ponds are proposed to <br />be reclaimed in SL-11. <br />The reclaimed land proposed for phase 2 bond release consists of approximately 60 acres of <br />dryland pasture and approximately 240 acres of irrigated pasture. Vegetation cover data from the <br />1987 baseline vegetation studies, found in Section 2.04. 10 of Volume 2 of the permit application, <br />were used in the RUSLE pre-mining sediment loss demonstration while the vegetation cover <br />data gathered in the 2007 vegetation sampling study submitted in SL-11 were used in the <br />RUSLE postmining sediment loss demonstration. <br />Western Fuels Colorado used conservative and well documented values for the parameters they <br />used in RUSLE. The general conclusion drawn from the soil loss comparison is that sediment <br />loss from the reclaimed area is less than that from the same area before mining. The calculated <br />annual sediment loss from the pre-mining dryland pasture land is 0.817 tons per acre while that <br />from the postmining dryland pasture land is 0.472 tons per acre. The calculated annual sediment <br />loss from the irrigated pasture land is 0.217 tons per acre in the pre-mining condition while that <br />of the postmining condition is 0.194 tons per acre. <br />cc: Sandy Brown <br />c:/word/newhorizon/sl l l memo 1 <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines