2015-03-01_REVISION - C1981014

• Permit No: C1981014
• IBM Index Class Name: Revision
• Doc Date: 3/1/2015
• Doc Name: K2T LLC Objection to TR 45
• From: Linda Saunders
• To: DRMS
• Type & Sequence: TR45
• Email Name: JHB
• Email Name: MPB
• Media Type: D
• Archive: No

3/10/2015
State.co.us Executive Branch Mail - Fwd: K2T LLC Objection to TR 45
STATE, OF Hernandez - DNR Alysha <aysha- hernandez @state- co -us>
COL,ORAI,
Fwd: K2T LLC Objection to TR 45
1 message
Please scan the attached e-mail.
Southfield C1981014
TR45
doc name: K2T LLC Objection to TR 45
Janet Binns
Environmental Protection Specialist III
Coal Regulatory Program
,f
P 303.866.3567 ext 8107 F 303.832.8106
1313 Sherman St., Room 215, Denver, CO 80203
[e-mail] http : / /mining.state.co.us
---- - - - - -- Forwarded message ---- - - - - --
From: Linda Saunders <saunders615 @live.com>
Date: Sun, Mar 1, 2015 at 5:05 PM
Subject: K2T LLC Objection to TR 45
To: "mike.boulay @state.co.us" <[e-mail] >, "janet.binns @state. co. us"
<[e-mail] >, "dave. berry @state. co. us" <[e-mail]>
TO: Mike Boulay, Janet Binns, and Dave Berry
FROM: K2T LLC Linda Saunders
RE:Objection to TR 45- EFCI request to change revegetation standards
Energy Fuels Coal Inc (EFCI) needs to meet the Division of Reclamation, Mining, and Safety Standards for
revegetation not rewrite them or change the percentages or calculations for reference areas and grasses and
shrubs. TR 40 has already changed the portal reference area.
EFCI needs to meet the 50% warm season and 50 %cool season grass requirement. In 1987 two dominant warm
season grasses growing in the Refuse Pile Reference Area (the grass reference area) was 47.8 percent. In 2008,
Kent Crofts stated in his revegetation inventory that EFCI could not meet the warm season grass standards.
EFCI should have interseeded with warm season grasses then, not requested a standard change in 2015.
Other mining companies had the same standard. If EFCI does not have to meet it, then it is arbitrary.
If all mining companies cannot meet it, then change the standard for the State of Colorado, not for EFCI now.
Also the shrub density was an issue in 2008. m \More shrubs should have been planted then.
Since Colorado allows rabbit brush to be counted, the rabbit brush on our property can meet the requirements for
shrub stem count and shrub production. The only standard EFCI has had to meet was grass and shrub density
requirements for revegetation. If the revegetation standard for warm /cool season grasses and shrub density are
changed, EFCI will not have to meet any requirements for revegetation.
Again EFCI is using the Technical Revision process to change the rules when they canno meet the standard.
In January 2010 Paula Coulter, Tena and John Gallagher and I met with Janet Binns and Dan Hernandez and
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