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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 />March 16, 2011 <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 (Permit No. C-1982-057) <br />Technical Revision No.70 (TR-70) <br />Aspen/Woody Plant Density Standards <br />Dear Mr. Karo: <br />COLORADO <br />D IV IS I ON OF <br />RECLAMATION <br />MINING <br />SAFETY <br />Mike King <br />Executive Director <br />John W. Hickenlooper <br />Governor <br />Loretta E. Pineda <br />Director <br />The Division of Reclamation Mining and Safety (Division) has received the Seneca Coal Company's <br />(SCC) re-submittal and responses to TR-70 at the Seneca II-W Mine dated June 15, 2010. The <br />response was received by the Division on June 17, 2010. <br />The following five items are revisions that the Division would like to have included in TR-70 - <br />Aspen/Woody Plant Density Standard. <br />Aspen and Tall Shrub Establishment Areas <br />Page 57 - In the currently approved restoration plan, the overall woody plant density <br />standard for concentrated planting areas is 2,000 stems/acre. This standard was determined <br />at the time of the original permit without understanding the difficulty of getting shrubs <br />established. The Revegetation Monitoring Reports of 2007, 2008 and 2009 indicate that <br />shrub establishment areas have had a moderate amount of success creating shrub habitat. It <br />is clear that 2,000 stems/acre will prove to be a difficult goal even with the latest shrub <br />technology. Some areas have far exceeded expectations with densities greater than 13,000 <br />stems/acre while many areas have not achieved 1,000 stems/acre after two to four growing <br />seasons. According to the 2008 Revegetation Monitoring Report, the area-weighted <br />average of all shrub concentration areas is just under 1700 stems/acre. Given these results, <br />the Division agrees with the five woody plant density standards proposed by Seneca Coal <br />Company with the following exceptions: <br />a. The secondary standard no. 1 - 10% of the unfenced, shrub concentration areas <br />have at least 1,000 shrubs per acre should be a mandatory standard. <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction Durango Active and Inactive Mines