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Mr. Mike Boulay -3- March 23, 2011 <br />that the next feasible step would be to submit a Technical Revision application <br />requesting to revise the revegetation success criteria in order to facilitate reasonable <br />standards which recognize and include the invasive nature of cheatgrass in the <br />reclaimed and surrounding areas. <br />4. DRMS: On February 15, 2011, the Division received comments from the <br />Colorado Division of Wildlife (CDOW) regarding TR-60. Please refer to the enclosed <br />comment letter and provide substantive response to each of the concerns identified by <br />the CDOW. <br />SCC: A "blanket change" to the revegetation reclamation standards is not being <br />requested. In this revision application, there are minor clarifications made to the cover <br />and production reference area comparisons to facilitate a more reasonable and <br />repeatable test for each variable. Appropriate ecological rationale was provided to <br />explain this need for clarification. <br />In regard to the minor changes to diversity criteria, those changes were made to provide <br />a more equal level of testing among the life-forms, and to better represent the ecological <br />potential for the site. Because a minor reduction in one variable occurred, compensation <br />was offered that resulted in more species (ecological resilience) being necessary for the <br />reclamation to be successful. <br />Snowcap Coal Company's reclaimed sites received multiple iterations of the best metrics <br />reclamation science has to offer given the current state-of-the-art for solving the various <br />issues and challenges this location offers. There is no currently known or viable <br />procedure that wasn't tried, or was deemed to have any chance for success. This <br />opinion is shared by several entities with superior expertise in reclamation science who <br />are also familiar with the ecological and systemic circumstances of the Snowcap site. <br />The Colorado Division of Reclamation, Mining and Safety (CDRMS) is first on this list, <br />and concurrence with this opinion is given by your March 4, 2011 cover letter statement, <br />"Despite repeated attempts, it appears at this time there is not sufficient technology to <br />control the persistent invasion of cheatgrass." Second on this list is Dr. George Beck, <br />Extension Weed Specialist, Colorado State University. Dr. Beck reviewed the Snowcap <br />site, offered his opinions on the control methods for cheatgrass that had been employed <br />(and failed), and could provide no other suggestions at that time. Third on this list is Dr. <br />Ed Redente, Professor Emeritus, Colorado State University, and former Dean of the <br />School and Head of the Rangeland Science Department. Dr. Redente, also familiar with <br />the site, was apprised of the circumstances, the metrics that were employed, the results, <br />and was unable to offer any additional procedures that could have been attempted that <br />had even a remote chance for success. And finally, is Snowcap's consultant, Cedar <br />Creek Associates, Inc., who have been working at this site since revegetation efforts <br />began, have provided a multitude of suggestions to correct manifest issues, and have <br />been measuring results of problem resolution attempts over the past decade. For <br />informational purposes, Cedar Creek has been designing revegetation efforts, <br />monitoring the results of those efforts, and providing solutions to reclamation issues for <br />over 35 years in the mining industry. A large portion of that experience has been gained <br />in some of the most difficult reclamation circumstances around the world (Basin and <br />Range country of Nevada; North of the Artic Circle - Alaska; Mojave Desert; Death <br />Valley; Outback of Australia). Therefore, if CDRMS, two distinguished faculty members <br />of Colorado State University, and a very experience consultant cannot resolve a