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2011-03-16_REVISION - C1994082
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2011-03-16_REVISION - C1994082
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Last modified
8/24/2016 4:31:48 PM
Creation date
3/16/2011 9:32:00 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1994082
IBM Index Class Name
REVISION
Doc Date
3/16/2011
Doc Name
Adequacy Review Letter
From
DRMS
To
Seneca Coal Company
Type & Sequence
TR48
Email Name
SLB
SB1
Media Type
D
Archive
No
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b. The woody stem average of 850 stems/acre in standards 2-4 should be increased to <br />945 stems/acre. This increase in stem density count will account for the allowable <br />density of 90% of approved statistical average standard stated in Tab 22, page 49, <br />paragraph 3. This makes the minimum possible allowable stem density to be 850 <br />stems/acre. <br />2. The following comments pertain to Exhibit 22-1 Post Mining Vegetation Map: <br />a. The 2006 version of this map shows Annand Draw and drainage YPM-12 (shaded <br />in purple) as mesic drainages and were seeded with mesic seed mix no. 2. The 2010 <br />version of the same map depicts these same areas as mostly undisturbed sagebrush <br />or mountain brush communities which are not associated with mesic conditions. <br />Please clarify what work/reclamation has been done and what the plan is for these <br />areas. <br />b. Some vegetation types were not included in the `Undisturbed Island and Border <br />Area Vegetation Chart.' Please include the definitions for IPU, IPD and any other <br />abbreviation used but not included on the chart. <br />c. Many different naming conventions are used to identify the shrub concentration <br />areas but none are consistently used throughout the map. Please re-label the shrub <br />concentration areas using a consistent labeling convention that includes: date of <br />planting (proposed panting date for those areas still under construction), shrub <br />community type and whether the area is fenced or unfenced. <br />d. Shrub concentration areas C, D, E, L and I (which are included in Map 5 of the 2008 <br />Revegetation Monitoring Report) were not drawn on the latest version of Exhibit <br />22-1. Please insert them in Exhibit 22-1 and include a description of each site in the <br />text with which plant community they will be grouped. <br />3. The descriptions of the fenced areas on page 48 are not congruent with Exhibit 22-1. <br />Please fix the discrepancies listed below: <br />a. The text says there are six fenced shrub plots, but seven are described. <br />b. Two fenced riparian areas are described in the text but only one is shown on the <br />map. <br />c. The text says there are three fenced upland woody shrub plant sites and the map <br />shows four. <br />d. The text says there are two unfenced upland woody plant sites but the map shows <br />three. Also, specifically reference these areas in the text by a name or community <br />type rather than `remaining two upland woody plant sites' for clarity. <br />4. The text makes reference to Exhibit 22-1 A - Post-mining Vegetation Map for the locations <br />and designations of woody plant concentration sites. The map the Division received is <br />called Exhibit 22-1 sheet 2 of 2. Please fix the map and/or text for con'si-t _ <br />please provide an updated version of Exhibit 22-1 - Post-mining Vegetation Map, sheet 1 <br />of 2 that reflects any previous revisions and those proposed in TR-48. <br />5. Rule 4.15.8(7) requires that for areas with a wildlife postmining land use the minimum <br />stocking levels ... must be determined on the basis of local and regional conditions after <br />consultation with and approval by the Colorado Division of Wildlife (CDOW). Since
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