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J. E. STOVER & ASSOCIATES, INC. <br />2352 NORTH 7" SREET, UNIT B <br />GRAND JUNCTION, COLORADO 81501 <br />PHONE: (970) 245-4101, FAX 242-7908 <br />MINE ENGINEERING <br />MINE RECLAMATION <br />CIVIL ENGINEERING <br />CONST. MANAGEMENT <br />April 19, 2011 <br />Mike Boulay <br />Division of Reclamation, Mining & Safety <br />101 South Td, Suite 301 <br />Grand Junction, CO 81501 <br />RECEIVED <br />APR 212011 <br />Division of Reclamation, <br />Mining and Safely <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 />The DRMS' second adequacy review letter dated April 12, 2011 transmitted additional <br />comments regarding TR-60. Following are Snowcap Coal Company's (SCC) responses <br />to the DRMS' comments and concerns: <br />5. DRMS: Page 14-22, Vegetation Cover - The text states "Achieve 90% of the <br />perennial vegetation cover of the approved reference area." To ensure better accuracy, <br />the text should state the success criteria as "Achieve 90% of the perennial vegetation <br />cover of the approved reference area sample mean at the 90% confidence level". <br />Please amend the text for Vegetation Cover and Herbaceous Production on page 14-23. <br />SCC: The DRMS' requested changes to Vegetation Cover and Herbaceous <br />Production on permit pages 14-22 and 14-23 were made and revised pages are <br />enclosed. <br />6. DRMS: Page 14-22, Species Diversity, last sentence - The Division questions if <br />a 5% of relative cover buffer is needed in the event the annual grass cover is greater <br />than 70%. The data provided with the 2010 Annual Reclamation Report suggests that <br />the annual grass cover is greatest in the reference plots and is significantly less on the <br />reclaimed areas. Please justify why this provision is needed or remove from the permit <br />revision. <br />SCC: The DRMS has requested a change or deletion to permit page 14-22, <br />Species Diversity. We believe the page in question is actually permit page 14-24. The <br />text that DRMS is questioning has been an approved part of Snowcap's permit for more <br />than five years. This stipulation was included in SCC's permit with the Division's <br />approval of TR-46 on December 13, 2005, and we believe could still be a relevant issue <br />to the species diversity of SCC's reclaimed lands. Although the 2010 Annual