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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman 5t., Room 215 <br />Denver, Colorado 80203 <br />C O L O R.A D O <br />Phone: (303) 866r3567 <br />D I V I S I O N O F <br />RECLAMATION <br />FAX: (303) 832 -8106 <br />MINING <br />SAFETY <br />John W. Hickenlooper <br />March 4, 2011 <br />Governor <br />Mike King <br />Tonya K. Hammond Executive Director <br />Snowcap Coal Company, Inc. Loretta E. Pineda Director <br />P. O. Box 1430 <br />Palisade, CO 81526 <br />Dear Ms. Hammond: <br />Re: Roadside Mine Permit No.C- 1981 -041 <br />Technical Revision No. 60 (TR -60) <br />The Division of Reclamation, Mining and Safety (Division) has completed our review of TR -60 <br />regarding the request to change the revegetation success criteria for vegetation cover, herbaceous <br />production and species diversity. Snowcap Coal Company (SCC) submitted TR -60 to address the <br />persistent invasion/dominance of cheatgrass on reclaimed land and corresponding reference areas at <br />the Roadside Portals Mine. Herbicide treatment and interseeding were done in 2005 -07 in an attempt <br />to reduce the dominance of cheatgrass. Despite repeated attempts, it appears at this time there is not <br />sufficient technology to control the persistent invasion of cheatgrass. With TR -60 SCC is proposing to <br />change the cover, production, diversity standards and sampling methods for the purposes of bond <br />release in Tab 14 of the approved permit. The Division has the following comments. <br />1. Page A14 -11 -4, Species Diversity— SCC is requesting to add a new requirement to compensate <br />for the reduction in warm - season grass cover. The new requirement is "for the presence of two <br />different species in each life -form category." Please list the life -forms in which two species <br />will be required. <br />2. Page A14 -11 -4, Sampling Methodology — The text states that SCC "intends to implement <br />Cedar Creek's [CCA] recormnendation regarding sampling design and procedure for final bond <br />release evaluation starting in 2011." The Division feels the methods used by CCA are justified <br />and superior to the currently approved method. If SCC wants to change the sampling design <br />and procedures that are outlined in the approved permit, then the following items need to be <br />addressed: <br />a. Remove the sentence stating "...DRMS will be contacted for approval of final <br />sampling methodology" in the Revegetation Success Criteria section on page 14 -22. <br />b. Amend the text in Tab 14 to reflect the new sampling design and procedures <br />outlined by CCA. <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines <br />