2009-09-04_REPORT - C1981041 (2)

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STATE OF COLORADO I]I1?I?lDN OF RECLAMAT`I?N, MINING ANQ SAFETY Department of Natural Resources ? ? 13 Sherman St., Room 2i 5 Denver, Colorado 8?2?3 ?hor?e: ?3?3} $6?-3567 SAX: X303} 832-8i 06 September 4, 2009 Tonga K. ?Iammod J. E, stover ? Associates ?nov?cap foal company, Inc. ?? ?. Boy 1430 palisade, 0 152 Ike: roadside 14Yine ?Perrr?t No. -1?1?04?} 200$ Revegetation ?valuatio?a Report Dear s. Hammond: GOLORADG DIVISION 0? R??LAMATt?N N?INtN &? ?AF?TY Bil[ Ritter, Jr, Gavernar Harris D. S[?erman ?X?C17iIY? Director Ronald 1N, Cottony Division Director Natural Resource Yrustee The Division of Reclamation, Mining and safety ?Divlion}has completed Its review of the 2005 Revegetation Evaluation Report. The report was submitted by J.E, stover and Associates, Inc., on behalf of no?vcap foal company ?nav?cap}, as part of nocap?s 2008 Annual Reclamation Report. The report was prepared by cedar creek Associates, Iris, ACA}, the vegetation consultant to nacap. The report vas very thorough and Drell organized. arripling methods and locations mere fully described using narrative, maps, and illustrations, and data ?verc clearly presented using charts and tables, supplemented v?rith solar photos of the various sampled areas. summary narrative vas concise and ?e11 supported. Mr, Dan Niathe?us of our office reviewed the report and has vne paint of clarification regarding section 1.2 Bac]? ?a?nd aid Standards o? '?cces?, and a number of conunents regarding Section 4,Q .Recom?n??d?tions. Section 1.2 l . At the bottom of page 2, continuing onto page 3, A presents the species diversity standard and recommends a modification to the standard. The rnodi?ication ?A recommends is argued to be necessary, because ".. ,the ubiquitous and invasive annual grass, cheatgrass ??4nisa??a ?ec?or?n}, has relative saver values approaching or surpassing 70?/o in years favorable to growth in both reference areas, as e11 as se?reral revegetated units". The Division does not dispute the heavy presence o? cheatgrass over much of the permit area, reclaimed and undisturbed areas alike, but the provision of the diversity standard CAA expresses concern with is no longer in effect. The current standard, approved in 200, includes the folla?ving provision ??ODS revised language is in bald}: ?ffi?? of Office of Mined Land E?e?lam?tion Denver * Grand J?n?tion • Durango Active and Inactive Mines