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To : GorhamK@COAL@DNRML 'll'I"~~'I"""II <br />From: BinnsJ@COAL@DNRML 999 <br />Cc: HernandD@COAL@DNRML <br />Subject: re: TR-02 Lorencito Canyon, Shrub Reveg Plan <br />Attachment: <br />Date: 6/8/98 3:28 PM <br />TR-02 adequately addressed my concerns stated in original permit application adequacy letter (March 3, 1997), <br />with regards to #191, <br />#190 was mostly resolved with proposal of a standard instead of a reference area, then providing methods for <br />measurement which addresses Rule 4,015.7(211b) and (cl. However, no discussion or explanation of where the <br />500 stems per acre value originated from was included. The operator needs to review Rule 4.15.7(21(d) and <br />explain what information the 500 stems per acre is based upon. It is not representitive of the pre-mine condition or <br />historic record. <br />Is DOW is agreement with the 500 stems per acre in the "concentrated" shrub clumps? 1 do not have a specific <br />disagreement with LCC's proposal, but how did they come up with the value? Other than validating what Cheir 500 <br />stems per acre is based upon, LCC has responded to the original #190, 191, and Stip 11. <br />---------- Original Text ---------- <br />From: GorhamK@COAL@DNRML, on 6/3/98 3:32 PM: <br />I have gone forward with the approval of TR-02. Greystone responded to your lastest concerns for TR-02 and <br />corrected those items indicated in your last adequacy review. However, it was not clear to me whether or not they <br />adequately responded to your original adequacy questions which led to Stipulation #11. Your question #190 <br />originally asked them to establish reference areas for the oak/pinyon community to comply with Rule 4.15.713). <br />They responded by proposing a standard of 500 stems/acre. You responded that they have provided no <br />rationale for lowering the standard from 1000 stems/acre to 500 stems/acre and that they have not provided an <br />explanation of how the standard will comply with Rule 4.15.7(3). Greystone then asked for additional time to <br />respond. As noted in your memo dated July 25, 1997, you indicated they did not respond to your questions #190 <br />and 191 and that the Division would attach a stipulation to the permit. Did they, through TR-02, adequately <br />respond to your original questions? Please let me know ASAP. <br />