Laserfiche WebLink
CAWED <br />NOV 0 9 2010 <br />Divajar, u, <br />ENERGY COMPANY <br />P.O. BOX 467 GOLDEN, COLORADO 80402 <br />November 08, 2010 <br />Ms. Janet Binns <br />Colorado Division of Reclamation, Mining and Safety <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />Re: SL-05 Findings Document <br />Keenesburg Mine (CDRMS file C-1981-028) <br />Dear Janet: <br />During Coors Energy Company's (CEC) review of the Division's Phase II Bond Release; <br />Proposed Decision and Findings of Compliance for the Keenesburg Strip Mine SL-05 <br />(permit Number C-1981-028), comments in Section III Observations and Findings <br />regarding the criteria for judging revegetation success caused us concern. <br />The author of this section states: <br />"CEC reported in the 2009 vegetation sampling report that the overall <br />vegetation cover for reclaimed areas seeded in 1998, 1999, and 2000 <br />(reclamation areas 2, 5, 6, 7, 9, 10, 15, 16 and 19) was 60.96% live <br />vegetation cover. However, per Rule 4.15.1(2) and the Division's 1995 <br />Bond Release Guidelines, noxious weed species cannot contribute to <br />reclamation success. Table 2 in CEC's revegetation report shows that <br />Bromus tectorum (cheatgrass) contributed 8.3% to the live vegetation cover <br />(L VC) on this Bond Release Block (BRB), and this amount must be removed <br />from the value of 60.98% for a sub-total of 52.66% L VC. <br />Furthermore, in measuring reclamation success the allowable cover <br />contribution of annual and biennial species should not exceed 10 percent <br />(based on Division policy and the Division's 1995 guidelines). Of the 36 <br />plant species sampled on the 19981199912000 BRB, 14 species were <br />determined to be annual or biennial. The 14 species contributed 13.19% of <br />the total cover and 28.67% of the relative cover (from Table 2). To limit the <br />relative cover of annual and biennial species to exactly 10 percent, a