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~ III IIIIIIIIIIIII III PEABODY ; ~ ~ ~ =` ,WESTERN ,~~~: n ~gg3 Peabody Western Coal Company 1 vu ~„ ~_~~- December 9, 1993 Mr. Jim Morris Colorado Division of Wildlife 711 Independent Avenue Grand Junction, CO 81505 RE: Seneca II Mine Permit C-80-005, TR27 - Postmininq Land IIse Plan Dear Mr. Morris: Per my conversation yesterday with Susan Burgmaier of CDMG, enclosed please find one copy of the revised Postmininq Land Use Plan, Tab 13, for Seneca II Mine. The Postmininq Vegetation Map, Exhibit 13-1, is also enclosed. Please review the enclosed plan as required by Colorado Regulation 4.15.8(7). This plan, as revised, will meet the intended postmine land use objectives for grazing and wildlife habitat. The following discussion supports the plan. Concerns regarding your March 18, 1993 letter to Janet Binns are also identified. Peabody Western Coal Company (PWCC) is concerned that the CDOW has provided no technical basis for requirement of a 1000 stem/acre woody standard. The CDOW did not address PWCC's proposed woody standard and establishment plan in relation to information presented on Page 22, Pages 38 to 40, and Exhibit 13-1 of revised Tab 13. In the March 18, 1993 CDOW letter to CDMG, CDOW states "restoring woody plant densities on a moderate scale is feasible" and that the succession of shrubs can be accelerated. PWCC can agree with this up to a point, but it appears CDOW believes restoration on a moderate scale (1000 stems/acre?) on extensive reclaimed areas is quite achievable. When one considers the level and extent of surface mine disturbance; successional time frames, processes, and patterns unique to reclaimed lands and disturbed premine communities; and the requirement to meet other regulatory requirements and parameters such as erosion protection and vegetative cover and production; the feasibility of this moderate scale quickly dwindles. Monitoring and ongoing observations in reclaimed areas show some areas can have densities of 1000 stems/acre or more; however, many of the areas have lower densities or no shrubs. To illustrate this, copies of Tables 19 to 26 from the 1992 Seneca Mine Revegetation Monitoring Report are enclosed. Problems related to woody plant establishment have been discussed on Pages 39 and 40 in revised Tab 13. Ecological and successional processes were considered in the discussion. Peabody Wastem Coal Company • 1 S00 SaWh Tale 5lreef • Fkgsla/f, Ali:ona 86001 • Telephone (604) 774.3433 • Fas (604) 775.43%