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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 />April 15, 2010 <br />Roy Karo <br />Seneca Coal Company, LLC <br />37796 Routt County Road 53 <br />P.O. Box 670 <br />Hayden, CO 81639 <br />Re: Seneca II-W Mine (Permit No. C-1982-057) <br />Technical Revision No. 70 (M-70) <br />Aspen/Woody Plant Density Standards <br />Dear Mr. Karo: <br />COLORADO <br />DIVISION OF <br />RECLAMATION <br />MINING <br />SAFETY <br />Bill Ritter, Jr. <br />Governor <br />James B. Martin <br />Executive Director <br />We have received your application for a technical revision to your permit to conduct coal mining in Colorado. Our initial <br />review indicates that all preliminary items required by Rule 2.08.4(5) have not been submitted. Thus, your application is <br />Incomplete for the purposes of filing as of April 14, 2010. <br />Specifically, we find that the application does not contain sufficient information and explanation to allow for a thorough <br />evaluation of compliance. Information requested in the following three items will need to be provided in order for the <br />application to be deemed Complete. <br />The woody plant density standard proposed would retain an "overall" standard of 200 woody plant stems per acre, but <br />would limit the requirement for a "concentrated planting area" standard to six fenced planting sites (concentrated <br />aspen/woody plant sites) shown on Exhibit 22-1. The proposal is confusing because Exhibit 22-1 depicts four fenced <br />aspen planting areas, plus an additional four upland planting areas designated "to be fenced" on the map (a total of <br />eight, rather than six fenced planting sites). It may be the case that four of the aspen planting areas delineated on <br />Exhibit 22-1, plus two of the fenced upland planting areas also contain aspen, and would be subject to the proposed <br />concentrated planting area standard. Specific locations to which the proposed "concentrated aspen/woody plant <br />site" standard would apply need to be defined. Revision of narrative and Exhibit 22-1 is warranted to provide <br />for the necessary clarification. <br />2. In the currently approved plan, a standard of 2000 woody plant stems per acre is specified for concentrated planting <br />areas, with the exception of the (4) concentrated aspen planting sites, where "the density standard was to be based on <br />future test plot results and planting strategies based on those results". The intent was that a standard for aspen stem <br />density would be established for the aspen planting sites, based on test plot results. The revision plan proposal of an <br />850 stem per acre standard is based on study results applicable to aspen, but it is not clearly stated in the narrative that <br />the proposed standard for the "concentrated aspen/woody plant sites" is 850 asr n stems per acre. As the aspen <br />planting sites are also planted with tall shrub species and seeded with a shrub/forb mix that includes big sagebrush and <br />snowberry, it is necessary that this point be clarified. The density standard for aspen planting areas needs to be <br />clarified, and should include both a general woody plant standard and an aspen stem density standard for the <br />concentrated aspen/shrub planting sites (similar to the approach approved for mesic drainage planting sites, which <br />include a mixed treelshrub component). Please amend the density standard for "concentrated aspen/woody plant <br />sites" to specify both a proposed woody stem density standard and an aspen stem density standard for such <br />sites, along with supporting rationale. <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines