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DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866 -3567 <br />FAX: (303) 832 -8106 <br />December 9, 2011 <br />Mr. Donald MacDonald <br />Coors Energy Company (CEC) <br />P.O. Box 467 <br />Golden, CO 80402 <br />Re: Keenesburg Mine, Permit No. C -1981 -028, SL -06 adequacy <br />Dear Mr. MacDonald: <br />The Division of Reclamation, Mining and Safety (Division) has reviewed the SL -06 Phase III Bond Release Application <br />and has identified an issue in the vegetation monitoring results. The data for the vegetation monitoring in year 2010 <br />indicate that the cover standard was not met for the following reasons: <br />• CEC included cover attributed to Cheatgrass in the total cover values. If this species were not included, the 2010 <br />data would not meet the cover standard. <br />• Division guidelines on the management of noxious weeds, which are incorporated into the rules (Rule <br />4.15.7(5)(b)), indicate that noxious weeds cannot be included in the calculation for total cover. <br />• Cheatgrass is on the noxious weed lists of Weld County and the State of Colorado. <br />Cover, productivity, and diversity standards were met in the 2009 data, and productivity and diversity standards were met <br />in the 2010 data. <br />Per our meeting at the mine site on 8 December 2011, internal discussions with Division management, and further research <br />by Division staff on the subject, we have decided that a solution is for CEC to provide 2011 data that meets the cover <br />standard. (In the meeting of 8 December 2011, CEC informed the Division that this data was collected.) It would also be <br />helpful if CEC provided information on species diversity for 2011, because this parameter is closely linked to cover. <br />Rule 4.15.7(5) requires success criteria be met for a minimum of two years out of the last four years of reclamation liability. <br />The Division prefers that all success parameters be sampled during each sampling event; this includes cover, productivity, <br />and diversity. Based upon discussions between CEC and the Division, the Division is able to accept productivity data from <br />2009 and 2010, and cover and diversity data from 2009 and 2011. Please assure the Division that in future bond release <br />submittals, all reclamation success parameters will be collected within a single sampling event. <br />If CEC chooses to propose other solutions, the Division will certainly consider them. Please contact me (ext. 8113) or <br />Jared Ebert (ext. 8120) if you have any comments or questions. <br />Robert Zuber, P.E. <br />Environmental Protection Specialist <br />Cc: Sandy Brown and Dan Hernandez, DRMS <br />Office of <br />Mined Land Reclamation <br />STATE OF COLORADO <br />COLORADO <br />D I V I S I O N O F <br />RECLAMATION <br />MINING <br />— &— <br />SAFETY <br />John W. Hickenlooper <br />Governor <br />Mike King <br />Executive Director <br />Loretta E. Pineda <br />Director <br />Office of <br />Denver • Grand Junction • Durango Active and Inactive Mines <br />