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DIVISION OF RECLAMATION, MINING AND SAFETY Department of Natural Resources 1313 Sherman St., Room 215 Denver, Colorado 80203 Phone: (303) 866 -3567 FAX: (303) 832 -8106 September 30, 2011 James M. Haskins Division of Wildlife 6060 Broadway Denver, Colorado 80216 RE: Seneca II -W (Permit No. C- 1982 -057) and Yoast Mine (Permit No. C- 1994 -082) Comments for Technical Revisions No.70 (TR -70) and No.48 (TR -48) Aspen/Woody Plant Density Standards Dear Mr. Haskins: Office of Mined Land Reclamation STATE OF COLORADO COLORADO D I V I S I O N O F RECLAMATION MINING —&— SAFETY John W. Hickenlooper Governor Mike King Executive Director Loretta E. Pineda Director Thank you for taking the time to submit comments on the Seneca II -W Technical Revision Application No. 70 (TR -70) and Yoast Mine Technical Revision Application No. 48 (TR -48). The Division received your letters on March 11, 2011 and forwarded them to Seneca Coal Company on March 16, 2011. Seneca responded on August 30, 2011. Please see attached copies of Seneca's responses. The Division concurs with Seneca's response as discussed below. It was suggested in your letter to ban domestic livestock grazing in reclamation areas "to encourage woody plant growth." The Division understands the concerns raised and recognizes that certain grazing practices can be detrimental to the natural regeneration of woody plants. However, it has been our experience that if grazing by domestic livestock is managed correctly, it can be beneficial to woody plant regeneration. The approved grazing plan at both Seneca II -W and Yoast Mine is designed to reduce the herbaceous component, which can actually impede the development of the slower growing woody plants. Livestock grazing is time limited from mid -July to October 1 when the herbaceous density is greatest, thereby reducing its competitive advantage. This technique has been used for many years at both mines and has demonstrated success. The current stem density standard approved in the permit has proven to be optimistic within the bond liability period even with best management practices implemented. Five years of monitoring data indicate that shrubs are well established, but progressing at a slower pace than originally anticipated. The Division feels that the new standards proposed are both achievable and reasonable with the current understanding of reclamation ecology and that the change in standards is warranted. Office of Denver • Grand junction • Durango Active and Inactive Mines