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Binns,Janet <br />From: Kent Crofts [kent@imeyampa.com] <br />Sent: Wednesday, August 03, 2005 5:03 PM <br />To: Janet.binns@state.co.us <br />Cc: efcoal@rmi.net; kent@imeyampa.com <br />Subject: Raton Creek Mine TR-22 Proposed Species Diversity Standard. <br />Dear Janet: <br />Based upon our discussions this afternoon of the grass cover values from the <br />2009 and 2005 reclamation monitoring efforts, along with the concerns you <br />expressed in your e-mail of today, Energy Fuels Coal Inc., is proposing the <br />following species diversity standard. <br />The discussion on Permit Page 522 relative to species diversity will be <br />modified to read: <br />Grasses: At least 60 percent of the total relative allowable vegetative <br />cover with no one grass species comprising more than 50 percent of the <br />total allowable cover. <br />Forbs: At least 10 percent of the total allowable vegetative cover. <br />Examination of the 2009 cover data, document that the total allowable cover <br />value was 30.50 percent, with grasses contributing 63.61 percent of the <br />total relative allowable cover and with the most dominant grass, <br />contributing only 33.39 percent of the total relative allowable cover. <br />In 2005, the total allowable cover was found to average 28.99 percent, with <br />grasses contributing 63.97 percent of the total relative allowable cover <br />with the most dominant grass contributing only 91.89 percent of the total <br />relative allowable cover. <br />It is our opinion that this proposed standard more accurately addresses the <br />Division's concerns of having a diverse plant community growing on the <br />relaimed areas, while at the same is a standard that Energy Fuels Coal can <br />comply with. <br />If you have any additional comments or questions regarding this issue, <br />please do not hesitate to contact me either in my office at 970-638-4962 or <br />via e-mail. <br />Thanks, <br />Kent A. Crofts <br />IME <br />P.O. Box 270 <br />Yampa, CO 80983 <br />1 <br />