|
To: Jim Stark
<br />From: Janet Bi s
<br />Re: Colo SL4 h a II B d Release Request Vegetation Review
<br />Date: January 21,
<br />Colowyo Coal Company L.P.'s (CCC) provided responses to the Division's November 23, 2010 adequacy letter on
<br />December 27, 2010. This memo is the result of my review of the operators response to the Division's concerns.
<br />Vegetation related adequacy concerns were numbered 1 through 4. 1 have included the original adequacy concern in
<br />this memo, followed with the operator's response. SL4 application requests phase II bond release on a portion of the
<br />Colowyo permit area consisting of 432.7 acres. Twenty -eight reclaimed parcels are included in the bond release block
<br />(BRB). The post- mining land use is rangeland as defined by Rule 1.04(71)(c). The locations of the parcels are shown in
<br />Exhibit 2, Phase II Bond Release map in the SL4 application package. Seventeen of the parcels are located at the
<br />reclaimed East Pit, and account for 365.89 acres. Nine parcels are located at the reclaimed West pit (or West pit fill), and
<br />accounts for 49.44 acres. The remaining two parcels are located in the Section 16 reclamation consisting of 17.37 acres.
<br />Vegetations Success standard: Phase II bond liability release acceptable if vegetation established on the reclaimed land
<br />meets the requirement of 90% herbaceous cover of the reference area standard with 90% statistical confidence (SL4
<br />app. P. 13) and Rule 4.15.8(3)(a).
<br />Colowyo Coal Company is requesting phase II bond release on Twenty-eight reclamation parcels: EP028, EP029, EP030,
<br />EP031, EP031 EP032, EP033, EP034, EP036, EP037, EP038, EP039, EPD40, EPO41, EPO42, EPO43, EPO44, WP003, WP004,
<br />WPD05, WP006, WP007, WP008, WP009, WPO30, WPO31, 516010, and 516014.
<br />Reclaimed areas were sampled in 2006, 2007, 2008, and 2009 in accordance with the permit sampling methodology.
<br />1. Adequacy concern: Data from 2006 and 2007 sampling also includes data from parcels not included in the
<br />phase II bond release block. These parcels include; FA001, FA002, FA003, 516002, 516005, 516009, 536031,
<br />536012, 536013, 516015, and 516016. In order for the Division to consider data from 2006 and 2007 as
<br />achieving reclamation success, data collected from these parcels will need to be removed from the data set. The
<br />Division requested that Colowyo Coal Company remove data from parcels not included in SL4 bond release block
<br />from the vegetation monitoring report for consideration of SL4.
<br />Operator response: Colowyo Coal Company (CCC) provided responses to the Division adequacy letter (dated
<br />November 23, 2010) on December 27, 2010. CCC provided revised vegetation reports for sampling conducted
<br />on the proposed Phase II reclamation block in 2006, 2007, 2008 and 2009. CCC removed the sample data from
<br />the reclamation parcels not included in the SL4 Bond Release Block. Mean cover, percent relative cover,
<br />standard deviation, and statistical sample adequacy were recalculated based on the data from the parcels
<br />included in the requested bond release block. This response is acceptable.
<br />
|