2012-06-20_GENERAL DOCUMENTS - C1981028

• Permit No: C1981028
• IBM Index Class Name: General Documents
• Doc Date: 6/20/2012
• Doc Name: Annual Biennial Plant Evaluation & Response Letter ‎(Emailed)‎
• From: DRMS
• To: Savage & Savage
• Permit Index Doc Type: General Correspondence
• Email Name: JLE
• Email Name: SB1
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
20 June 2012
Mike Savage
Savage and Savage Environmental
4610 Haystack Drive
Windsor, Colorado 80550
RE: Keenesburg Mine; C- 1992 -081
Annual/Biennial Plant List and Revegetation Success Criteria
Dear Mr. Savage,
COLORADO
D I V I S I ON OF
RECLAMATION
MINING
SAFETY
John W. Hickenlooper
Governor
Mike King
Executive Director
Loretta Pineda
Director
During our meeting on May 16 we discussed the possibility of revising the prediction equations used to
determine revegetation success standards at the Keenesburg Mine. It was agreed that the Division
would review a list of annual /biennial species at the site to determine which species we would accept to
count toward revegetation success standards for production and cover. After receiving the plant list you
provided we reconsidered how we would like to approach this issue. We agree the prediction equations
for cover and production should be modified given the guidelines the Division uses to evaluate
revegetation success so comparisons can be evaluated evenly. Instead of picking and choosing which
annual /biennial species to be counted toward revegetation success the Division believes the prediction
equations already account for a varied amount of annual /biennial species contribution. After reviewing
TR37, it appears the predictive equations were based on vegetation monitoring data of the Osgood Sand
Reference Area from 1995, 1996, 1997, 1998, 2000, 2001 and 2002. I looked at this data and evaluated
the relative cover and mean production values of annual and biennial species for these years. A table of
this information is below:
Year
Relative Cover of
Annuals %
Annual Production
mean /m ^2
Sep -July
Precipitation
1995
22.2
44.7
16.77
1996
6.92
3.86
10.29
1997
3.32
3.36
9.71
1998
3.7
7.17
11.38
2000
2.56
0.51
9.7
2001
18.39
33.73
15.68
2002
9.77
3.88
6.46
Average
9.55
13.89
11.43
After looking at this data, it appears the predictive equation is based on data with fluctuation of the
contributions of annual /biennial species and State listed noxious weeds (Cheatgrass and Puncture Vine).
As you know the Division cannot allow State listed noxious weeds to count toward revegetation success.
Given this, the predictive equations should be modified by the removal of noxious weeds from the data
used to generate the equations. In regards to annual/biennial species, the equation is based on a varied
amount of contribution of these species with an average relative cover contribution of 9.5% for the
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Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines