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• • -III IIIIIIIIIIIIIIII <br />YVCC 999 <br />Yampa Valley Coal Corporation ~ 29588 Routt County Road #27, Oak Creek, CO 80467 • (303) 879-3800 <br />May 14, 1987 ~~~~~~~® <br />Mr. Dan Mathews tdAY 1 g 1987 <br />Colorado Mined Land Reclamation Division MINED LAND <br />1313 Sherman Street, Room 423 i~ECLAMATION DIVISION <br />Denver, Colorado 80203-2273 <br />Dear Mr. Mathews: <br />RE: Technical Revision 87-11, Permit C-81-071, <br />Soil Testing Plan. <br />Colorado Yampa Coal Company (CYCC) requests a technical revision to <br />eliminate the soil sampling program for respread topsoil. Based upon the <br />favorable pre-mine soil information and over 11 years of reclamation <br />experience, a post disturbance mine soil testing program to meet the topsoil <br />standards of Rule 4.06 is no longer necessary. In support of this request, <br />CYCC has summarized the data from 127 samples collected on replaced topsoil <br />(see page 2.05 - 71 of the Little hliddle Creek Tract Permit Revision). <br />Neither nitrogen or phosphorus, which CYCC committed to monitor, shows <br />significant deficiency. CYCC believes that the vegetation monitoring <br />program is more appropriate for identifying any future nutrient defeciencies. <br />Discussions with individuals from the Colorado State University Soil <br />Testing Laboratory (STL) indicate typical soil fertility analysis may not be <br />directly applicable to the reclamation work done at the mine. Specifically, <br />guidelines published in Guide to Fertilizer Recommendations in <br />Colorado indicate "a profitable response to fertilization can be expected <br />only when soil moisture is favorable and the medium and tall grass species <br />dominate the pasture". Given the precipitation patterns in the mine area <br />and also the desire to establish fortis and shrubs as well as grasses, <br />fertilization likely would not be profitable. Robert Jump at the STL <br />suggested plant response is often the best indicator of fertility problems. <br />Also, the concern of using chemical analysis to predict fertility <br />requirements has been noted in other literature, as in articles published by <br />Dr. k'illiam Berg (formerly of Colorado State University Agronomy <br />Department). An example of this concern is the problem associated with <br />predicting soil nitrogen availability. <br />Two facts often are not considered during the fertility analysis. <br />First, the presence of nitrogen in the overburden is not used, and secondly, <br />the nitrogen mineralization rate of exposed sedimentary rock is not the same <br />as typical soils. Both of the above cast doubt on the prudence of using <br />predictive tests to determine fertility requirements of topsoil <br />redistributed over regraded spoil. <br />