2011-06-02_GENERAL DOCUMENTS - C1980007 (2)

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Binns, Janet From: Binns, Janet Sent: Thursday, June 02, 2011 12:31 PM To: 'savageandsavage@earthlink.net' Cc: KWelt@archcoal.com; RSweetwood@archcoal.com; Hernandez, Daniel Subject: RE! West-Etk7waCMAntun-date Good Morning Mike, I asked about the precipitation level since Denver reported over 4" of precipitation in the month of May. Since the Snotel reports show most of the river basins in the state have over 200% of average snowfall, I wanted to verify that October 2010-May 2011 did not meet the definition of a "wet" year as defined in the West Elk findings and your HRSA reports. My concern was, if indeed 2011 did meet the wet year definition, and the HRSA was not sampled, there could be questions in the future regarding why it was not sampled. I just wanted to document that we closed that potential concern. I will follow up with a memo regarding what DRMS, Savage & Savage, and MCC discussed in our meeting on 5/23, and provide you all with a copy. I have reviewed your sampling plan for the reclaimed drill sites and roads. A couple of questions that I did not see clearly defined when I looked at it; 1) How will the sample locations for the topsoil verifications be chosen? What frequency will topsoil verification be conducted? This description can be general, i.e. One topsoil verification hole will be hand dug per each reclaimed pad, or one every 3 acres (I just picked a number-this frequency is not defined in the rules). Topsoil holes will be dug until color or texture change is apparent. (Please use your own language, this is just a sample of what I think we should be clear on prior to you digging holes) 2) In the description of Herbaceous Production sampling you include the statement "Additional herbaceous quadrats will be located randomly as described above." From the text, I am not clear on what "as described above" is referring to. This statement may need a little more definition so all readers get to the same conclusion. 3) Please remember that Rule 4.15.8(6) states that, "the vegetation on the reclaimed area consists of a mixture of species of the same seasonal variety native to the area of disturbed land, or of species that support the approved postmining land use. The vegetation on the reclaimed surface must be of equal or superior utility for the approved postmining land use." Even though you do report noxious weeds that are measured on the reclaimed lands, by definition noxious weeds are not native and do not support the postmining land use of rangeland and wildlife habitat. 4) The last question I have, Although I haven't been up to the North Fork area this Spring, it seems like spring is late throughout much of the state. Will the vegetation be growing enough to conduct appropriate sampling? Thanks J2mt H. 7R?Lwws Environmental Protection Specialist II Colorado Division of Reclamation Mining and Safety phone: (303) 866-3567 ext. 8107 fax: (303) 832-8106