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INTEROFFICE MEMORANDUM <br />TO, TOM KAILDENBA <br />FROM: JANET BI <br />SUBJECT: PEABQDY S GE EK MINE APPLICATION; CROW LETTER DATED 8/31/2009 <br />DATE: 12/16/2009 <br />CC: DAN E ERNANDEZ <br />On August 31, 2009, the Division received a letter from The Colorado Division of Wildlife (CDOW) <br />regarding their review of the Peabody Sage Creek Mine (PSCM) application. This letter was forwarded to <br />me for my review on October 22, 2009. Please find my review of CDOW's comments along with concerns <br />that need to be addressed by the operator. <br />Seed mixes proposed by Peabody Sage Creek Coal Company (PSCCC) for reclaimed areas, 2.05.4-T1, <br />2.05.4-T2, topsoil stockpile stabilization 2.05.4-T3, and drill pad reclamation 2.05.4-T5, are the same as the <br />seed mixes previously approved in the Seneca II permit (C1980-005). The PSCM application proposes to <br />re-disturb reclaimed portions of the Seneca II Mine. The underground workings of the PSCM would <br />continue westwards from the facilities and portal area and undermine Routt County Road No. 27 (RCR27) <br />and lands west of RCR27. The current application proposes room and pillar development and portal <br />development only. No longwall mining is currently proposed, nor are any ventilation boreholes or other <br />surface disturbances proposed aside from the portal and facilities area disturbance. <br />Peabody personnel met with CDOW representatives on July 31, 2009. CDOW acknowledged that <br />ventilation shafts are not currently a part of this PSCM application, but the need for ventilation shafts is <br />anticipated as the mine progresses. The CDOW's comments regarding ventilation shaft construction <br />impacts are based upon this projection. The CDOW identified that mining under the Noftsteger and <br />Noftsteger Zeigler reservoirs on the Twentymile State Trust Lands may necessitate the need to drain these <br />two reservoirs. The CDOW stocks these reservoirs with trout. Hunting of big game (pronghorn and elk) <br />and game birds (Columbian sharp-tailed grouse) also occur on the state trust lands. Construction of <br />ventilation shafts and access roads potentially may impact these activities. The CDOW provided ten <br />requirements to activities associated with construction of surface disturbances associated with ventilation <br />shaft construction on the Twentymile and Grassy Creek State Trust Lands. Since ventilation shafts or <br />access roads are not currently proposed on state trust lands in this permit application, these requirements are <br />not germane to this permit application. At such time that surface disturbance is proposed on the state trust <br />lands, these mitigation measures will need to be followed by the operator. The mitigation measures required <br />by DOW for the State Trust lands are not adverse to the DRMS Rules and Regulations (Rule 4.18). <br />CDOW also provided comment regarding reclamation efforts. The first two comments, "on-non-croplands, <br />establish a uniform vegetative cover that reflects pre-disturbance or reference area forbs, shrubs, and <br />grasses." is in agreement with DRMS requirements of Rule 4.15.1(1), Sections 34-33-120(2)(c), and 34-33- <br />120(2)(s) of the Act. The third reclamation requirement identified by the CDOW is to "Census and assess