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7/10/13 State.co.us Executive Branch Mail - Southfield vegetation sampling plan <br />Binns - DNR, Janet <janet.binns @state.co.us> Tue, Jul 9, 2013 at 3:07 PM <br />To: George Patterson <efcoal @gmail.com> <br />Cc: Alysha Hernandez - DNR <alysha.hernandez @ state.co.us>, Mary Rodriguez - DNR <br /><mary.rodriguez @state.co.us> <br />Hello George, <br />have read EFCI's scope of work for Reclamation success sampling at the Southfield mine and loadout. <br />" SOUTHFIELD- 2012REVEGETATIONMONITORING.doc" Dated 7/19/2012. <br />The scope of work appears to follow the approved sampling methods described in the Southfield Permit, p. <br />2.05.4 -26- 2.05.4 -27a. <br />The Division concurs that shorter transect lengths may be preferred in certain instances. If the operator conducts <br />the sampling consistently, with random transect locations and direction, and the data are collected to sample <br />adequacy as defined in Rules 4.15.11(2) and (3), a shorter transect length is acceptable. (Rule 4.15.11(1)(a)(i) <br />allows for cover transects to be a minimum of 5 meters in length) <br />The Division reminds EFCI that "under no condition will noxious weeds count toward the success standard." <br />(Guideline Regarding Selected Coal Mine Bond Release Issues: CDMG, April 18, 1995, 4.14.8(2), 4.15.8(6)) <br />Noxious species are defined by the Colorado Department of Agriculture "Colorado Weed Management Act" and <br />includes all species on the A, B and C lists. (Cheatgrass is on the C list) <br />Permit Page 2.05.4 -27a states that "woody plant density for seeded areas and the reference area will be <br />measured using 50m x 1M belt transects along the same transect lines." The Division concurs that a shorter belt <br />transect may be necessary (with a minimum of 30 transects if sample adequacy is not met). "this data will be <br />combined with direct count woody plant density data for the shrub clumps using a weighted average approach. <br />EFCI needs to assure with this approach that "double sampling " does not occur. <br />The Division wishes to clarify a comment made on the first page of the 2012 "scope of work" with regards to <br />woody plants density. EFCI states that page 2.05 -27 "woody plant density for the refuse pile reclaimed areas will <br />be determined to be successful when, when [sic] they are within 90 percent of the revised woody plant density <br />counts." The approved page 2.05.4 -27 (revised March 2003) speaks to comparison of the loadout area to the <br />revised woody plant count for the loadout area. <br />Permit page 2.05.4 -27a (revised 8/02) provides detail regarding comparison of woody plant densities on reclaimed <br />areas with in the mine area. The t -test will be used to evaluate the woody plant densities between the weighted <br />average reclaimed area and the corresponding reference area... <br />Permit page 2.04.5 -28 (revised December 2001) does not speak to vegetation comparison. The Division wishes <br />to be sure that we are both looking at the same approved permit text. The Division is referencing the Approved <br />permit text found on the Division's Lasefiche system. <br />The Division has made a proposed decision to approved TR39 which proposed to use a different Pinyon /Juniper <br />reference area than the original Plot B. The Division's proposed decision has been challenged in accordance with <br />Rule 2.08.4(6)(b)(iii). This item is scheduled to be heard at the August 14, 2013 MLRB meeting. As such, the <br />Division's proposed decision in not yet final. If vegetation sampling occurs prior to the Determination by the Mine <br />Land Reclamation Board, the currently approved reference areas, Plot A, and Plot B, and Loadout, will need to be <br />https:llmail.g oog le.conVmai I /u /0 / ?ui =2 &i Ire29129fcb5 &viev�-- pt &search =i nbox&th= 13fc543125ef4Ofa 1/2 <br />