2011-05-17_REVISION - C1981008 ‎(2)‎

• Permit No: C1981008
• IBM Index Class Name: REVISION
• Doc Date: 5/17/2011
• Doc Name: Phase 3 Irrigated Pasture Area - Use of Reference Area for Standard
• From: Greg Lewicki & Associates
• To: DRMS
• Type & Sequence: SL12
• Email Name: SB1
• Email Name: DAB
• Email Name: MLT
• Media Type: D
• Archive: No

Greg is i n associates
11.541 Warrington Court Phone: [phone] Fax [phone]
Parker, CO USA 80138 E-Mail: iuf'oQ6,lewicki.biz
May 16, 2011 J a
V:e?
Sandra Brown
Colo. Division of Reclamation, Mining, and Safety
1313 Sherman Street, Rm 215
Denver, CO 80308
RE: SL-12 Phase 3 Irrigated Pasture Area - Use of Reference Area for Standard
In our meeting with, you, WFC, Dave Berry and Ben Langenfeld of my office, it was stated that all
other coal mines conduct their vegetation studies after any revisions to the vegetation standard have
been made.
I researched the Meeker Mines, where I actually worked on the permit, actually did the reclamation in
1986, monitored the site for 10 years, coordinated the vegetation studies in 1995 and 1996 and obtained
full bond release in 1997. We got an award from CMA for this reclamation.
Prior to the first year's vegetation study in 1995, the site had a cover standard, a production standard, a
woody plant density standard and a species diversity standard. The results of the 1995 vegetation study
are included as Exhibit A, which was actually dated March 1996. On Page 2 of this Exhibit, the
standards in place at that time are presented. On page 3, it states near the top "The operator anticipates
submitting a technical revision requesting the elimination of the woody plant density standard that
presently applies to the site. Because of this, woody plants were not sampled". At that time, it was
required that woody plants be 1000 stems per acre. The 1995 sampling was done by Matt Hayes of
Hayes Environmental Services during July, August and September of that year.
The second year sampling was done by Matt Hayes in the summer of 1996 and no woody plants were
measured, although, at the time, the standard was still 1000 stems per acre. See Exhibit B, an invoice
from Matt Hayes, describing the dates of the sampling.
In August of 1996, TR-11 was submitted to DRMS which proposed eliminating the woody plant
density standard. The pages for this revision are included in the attached Exhibit C. This was approved
by the Division.
In February of 1997, the second year vegetation report was provided by Matt Hayes and is included as
Exhibit D. This report states on Page 1 that Larry Routten of DRMS and OSM were consulted prior to
15` year sampling in 1995. Page 2 of this report shows that the woody plant density requirement is zero
stems per acre. Page 3 states "The operator recently submitted a technical revision (TR-11) that
requested, among other things, the elimination of the woody plant density standard that formerly