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Savage and Savage Environmental <br />practical solutions for environmental issues <br />4610 Haystack Drive 970 674 8080 telephone <br />Windsor, Colorado 80550 970674&0&& facsimile <br />savageandsavage®earthlink.net <br />March 15, 2011 <br />Ms. Janet Binns <br />Colorado Division of Reclamation, Mining & Safety <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />MAR 1 ? 2011 <br />Division of <br />Wining and Safely <br />RE: Mountain Coal Company LLC West Elk Mine (CDRMS Permit C-1980 -007) <br />Historic Record Study Area 2010 Sampling <br />Dear Janet: <br />We have completed a summary report on quantitative vegetation sampling conducted in <br />2010 at the West Elk Mine Historic Record Study Area (HRSA). In order to further <br />discussion of finalization of the revegetation success criteria for the West Elk Mine, <br />Savage and Savage undertook quantitative vegetation sampling last summer using the <br />same methods and criteria we did in 1996, 1997, and 1998. We also collected <br />precipitation data from the last ten years from the Paonia 1 SW station. <br />The vegetation data from 2010 reveal similar vegetation cover, herbaceous production, <br />species composition, and woody plant density as the data from the later 1990's. The <br />vegetation of the HRSA has matured, with the increased presence of native perennial cool <br />season range grasses and native forbs, as well as an increase in woody plant numbers <br />over the last decade. <br />In 1999, the Division requested Mountain Coal Company LLC (MCC) sample a defined <br />"wet" year in order to characterize a spectrum of precipitation regimes at the HRSA. <br />Since that time, no defined "wet" years have been recorded. <br />Absent a defined "wet" year, and given the similarities of the HRSA vegetation to that <br />from the late 1990's, we request, on behalf of MCC, that the Division review the <br />appended 2010 report and accept the proposed revegetation success criteria.