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J. E. STOVER & ASSOCIATES, INC. <br />2352 NORTH 7th SREET, UNIT B <br />GRAND JUNCTION, COLORADO 81501 <br />PHONE: (970) 245-4101, FAX 242-7908 <br />MINE ENGINEERING <br />MINE RECLAMATION <br />March 23, 2011 <br />Mike Boulay <br />Division of Reclamation, Mining & Safety <br />101 South 3`d, Suite 301 <br />Grand Junction, CO 81501 <br />Re: Snowcap Coal Company, Inc. <br />Technical Revision No. 60 (TR-60) <br />Adequacy Review Comments <br />Permit No. C-81-041 <br />Dear Mr. Boulay: <br />CIVIL ENGINEERING <br />CONST. MANAGEMENT <br />/?ZCz1V,e® <br />25Z011 <br />41111;nv 0170f /8fe Ab <br />The DRMS' letter dated March 4, 2011 transmitted its adequacy comments regarding <br />TR-60. Following are Snowcap's responses to the DRMS' comments and concerns: <br />1. DRMS: Page A14-11-4, Species Diversity - SCC is requesting to add a new <br />requirement to compensate for the reduction in warm-season grass cover. The new <br />requirement is "for the presence of two different species in each life-form category." <br />Please list the life-forms in which two species will be required. <br />SCC: Please note paragraph 3 of new permit page 14-24 that was submitted <br />with the original technical revision application on January 17, 2011. The life-forms in <br />question, cool-season grasses, warm-season grasses, and forbs and suffrutescent (sub- <br />shrub) species, and the new criteria "at least two species present in the reclamation <br />(observed)" are more fully discussed. <br />2. DRMS: Page A14-11-4, Sampling Methodology - The text states that SCC <br />"intends to implement Cedar Creek's (CCA) recommendation regarding sampling design <br />and procedure for final bond release evaluation starting in 2011." The Division feels the <br />methods used by CCA are justified and superior to the currently approved method. If <br />SCC wants to change the sampling design and procedures that are outlined in the <br />approved permit, then the following items need to be addressed: <br />a. Remove the sentence stating "... DRMS will be contacted for approval of <br />final Sampling methodology" in the Revegetation Success Criteria section on <br />page 14-22. <br />SCC: The sentence has been removed from permit page 14-22 and revised <br />page is enclosed. <br />b. Amend the text in Tab 14 to reflect the new sampling design and <br />procedures outlined by CCA.