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Date: June 11, 2010 <br />To: Rob Zuber <br />From: Janet Bin <br />Re: Keens g T <br />1981-02k Phase II BoAd Release SL5 application review. <br />I have review?e I?e? us rg Mine application for a phase II bond release application for reclamation areas <br />2, 5, 6, 7, 9, 10, 15, 16, 23 and 29. Coors Energy Company (the operator) sampled these reclaimed areas as <br />combined Bond Release Block (BRB). This is acceptable the Division based upon topsoil replacement <br />thickness and methods, dates and timing of seeding, topography, seed mix used and land management. This <br />BRB meets the definition of a logical land management unit as defined in the Division's Guideline Regarding <br />Selected Coal Mine Bond Release Issues (April 18, 1995). The operator sampled the BRB Between August 5 <br />and August 15, 2009. <br />I have one question for the operator: <br />1) Table 3, titled "Vegetative Cover: 2006 Reclamation Area (2009)" indicates that this data was collected <br />from Area 29. Area 30 was reseeded in 2006 and Reclamation Area 29 was reseeded in 2003. Is this <br />Table 3 data meant to represent data from Area 30 or Area 29? Please provided a corrected Table 3 for <br />the record. <br />The following is my review of the presented data: <br />Reclaimed areas seeded in 1998, 1999, and 2000 (Reclamation areas 2, 5, 6, 7, 9, 10, 15, 16 and 19) meet <br />the reclamation standard for cover. In 2006 the operator requested a revision to the reclamation success <br />standards from comparison to an approved reference area, to comparison to calculated cover and production <br />standards derived from historic reference area data. Precipitation from September to July immediately <br />preceding the sampling event is incorporated into the standard formula as the variable. The Division approved <br />this revision (TR37, approved 6/15/2006), thereby removing any direct comparison with species composition in <br />a reference area. The calculated live vegetative cover (LVC) value using the measured 13.71 inches of <br />precipitation for the preceding September to July resulted in a cover standard of 35.69% LVC. <br />The operator reported in the 2009 vegetation sampling report that the overall vegetative cover for this <br />sampling block was 60.96% live vegetative cover. However, reference to Rule 4.15.1(2) and the Division's <br />1995 Bond Release Guidelines, noxious species can not contribute to reclamation success. Therefore, the cover <br />attributed to Bromus tectorum (Downy brome) must be subtracted out of the live vegetative cover value. Table <br />2 shows that Bromus tectorum contributed 8.3% to the live vegetative cover (LVC) on this block. Therefore, <br />60.96% cover minus 8.3% cover attributed to Bromus tectorum results in LVC of 52.66% LVC. Furthermore, <br />Division policy and direction provided by the Division's 1995 Guideline notes that "the allowable cover <br />contribution of annual and biennial species should not exceed 10 percent or the relative cover of such species in <br />the associated reference area or approved technical standard, whichever is higher." <br />Of the thirty-six plant species sampled on the 1998/1999/2000 Reclamation block, fourteen species were <br />determined to be annual or biennial. After removal of cover attributed to the one noxious species (Bromus <br />tectorum), the Division can allow up to 10 percent relative cover of the remaining annual and biennial species <br />to count towards reclamation success for cover establishment. The fourteen annual or biennial species <br />contributed 13.19% cover, or 28.67% relative cover to the total cover value. Allowing up to 10% relative cover <br />attributed to annual or biennial species to count towards the cover success value, this means that 18.67% <br />relative cover or 8.59% total cover would be removed from the cover values. Therefore, 52.66% LVC minus <br />8.59% LVC, equals 44.07% LVC. The calculated value using the measured 13.71 inches of precipitation for <br />the preceding September to July resulted in a cover standard of 35.69% LVC. The live vegetative cover <br />measured on the 1998/1999/2000 reclaimed block exceeds the calculated cover standard and is considered <br />successful for the 2009 sample year. This bond release block was sampled to statistical adequacy. <br />"No woody species are required for bond release. Coors Energy Company has a noxious weed management <br />plan and actively implements it. Only one noxious weed species, Cheatgrass, was measured in the 2009 <br />vegetation sampling. Cheatgrass, or Bromus tectorum. Coors Energy Company has implemented its approved <br />weed management plan to control Cheatgrass in the reclaimed areas. Bromus tectorum is considered a noxious <br />Keenesburg SL5 Memo 1 June 11, 2010