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;->z.~ r <br />Savage and Savage ENVIRONMENTAL <br />• practical solutions for environme~af Issues <br />4610 Haystack DHve 970 674 8080 telephone <br />Windsor, Colorado 80550 970 674 8088 facsimile <br />savages nd savageCmearthl I n k.n et <br />December 20, 2005 <br />RECEIVED <br />DEC ? 0 2005 <br />Division ~f Miwerals and Geology <br />Ms. Janet Binns, Environmental Protection Specialist <br />Colorado Division of Minerals and Geology <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />Re: Application for Technical Revision to Modify Revegetation Success Standards at the <br />Keenesburg Mine (CDMG file C-1981-028) <br />Deaz Janet: <br />• Attached is background information, a CDMG revision application form, and proposed <br />public notice for a revision to modify the revegetation success criteria at the Coors <br />Energy Company Keenesburg Mine. As I mentioned in our October meeting, we propose <br />to use precipitation data from on-site to predict yearly growing season values for total <br />vegetation cover and total herbaceous production based on mathematical formulae <br />derived from vegetation sampling begun in 1994. The mathematically predicted values <br />would serve as the revegetation success criteria for total vegetation cover and total <br />herbaceous production at the Keenesburg Mine. Additionally, we undertook a review of <br />the relative cover data from 1994 to present to critically evaluate the currern species <br />composition revegetation success criterion for the Keenesburg Mine. We concluded that <br />the current species composition success criterion does not reflect species composition at <br />the Osgood Sand Reference Area or successfully revegetated azeas at the mine. Based on <br />the quantitative data collected from 1994 to present, we are proposing to revise the <br />species composition success criterion. With acceptance of these proposed revegetation <br />success criteria by the Division, Coors Energy Company proposes to discontinue use of <br />the Osgood Sand Reference Area at the Keenesburg Mine. <br />Given the unique nature of this proposed revision, and ow anticipation that significant <br />discussion will occw between Coors Energy, Savage and Savage, and the CDMG staff, <br />we have not provided replacement pages for the Keenesbwg mine permit document at <br />this time. We anticipate providing replacement pages prior to a decision by CDMG on <br />the technical revision application. <br />n <br />LJ <br />