REV13360

• Permit No: C1983059
• IBM Index Class Name: Revision
• Doc Date: 7/6/1988
• Doc Name: TERROR CREEK LOADOUT REFERENCE AREA PN C-83-059
• From: MLRD
• To: SUSAN MOWRY
• Type & Sequence: RN1
• Media Type: D
• Archive: No

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STATE OF COLORADO
Roy Romer, Governor
DEPARTMENT OFNATURALRESOURCES
MINED LAND RECLAMATION DIVISION
FRED R. BANTA, Director
DATE: July 6, 1988
T0: Susan Mowry
FROM: Peter O'Connor~~~
RE: Terror Creek Loadout Reference Area; Permit C-83-059
As requested, I have reviewed the May 24, 1988 letter from Terror Creek
Company (TCC) regarding their reference area. As previously discussed, TCC is
unable to use the existing reference area since the area is not being managed
as a hayfield and TCC has not obtained any production data for quite some
time. To resolve this problem, we identified two alternatives: establishment
of a production standard since the acreage is less than 40 acres; or,
establishment of a new reference area. In the May 24, 1988 letter, TCC is
requesting the establishment of a new reference area.
The recent draft guidelines for vegetation, dated March, 1988, specifies a
minimum reference area size of three acres. The Division has found that a
minimum of three acres allows for sufficient area to provide for adequate
sampling and ameliorates unnatural influences (e. g. fencing). The submittal
from TCC addresses a new reference area encompassing only one acre. This is
too small of a size.
The other problem I have noted is that TCC did not provide any data to allow
for our review to determine the adequacy of this new area. We cannot accept
this new area as the reference area until TCC can prove that species
composition and production are comparable to the data from the current
reference area. Only after proving its comparablity can we accept this area
as the new reference area.
PVOC/yjb
8583E
215 Centennial Building, 1313 Sherman Street Denver, Colorado 80203.2273 Tel. [phone]