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III IIIIIIIIIIIIIIII <br />999 <br />C c~RUs <br />"~ Yampavau®y <br />Cyprus Yampa Valley Coal Corporation <br />29587 Routt County Road #27 <br />Oak Creek, Colorado 80467 <br />303-879-3800 <br />RECEIVED <br />November 20, 1998 <br />~Ipu 25 1SS8 <br />Janet Binns <br />Environmental Protection Specialist • , ,:;n of tvlinerals 8 Geology <br />Division of Minerals and Geology <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />RE: Technical Revision 98-09, Diversity Standard Modification <br />Permit No. C-84-062 <br />Dear Ms. Binns: <br />Colorado Yampa Coal Company (CYCC) is requesting a technical revision to the above <br />referenced permit for the purpose of modifying the diversity standard. During the prior <br />mid-term review it was recommended CYCC review the existing standard to determine if <br />it is applicable for use on pastureland. <br />A strong comparison for modifying the diversity standard can be made by looking at the <br />standard approved in permit C-81-071. The postmining land use for this permit is <br />pastureland, the same as in permit C-84-062. This standard states that "alfalfa shall not <br />exceed 75% of relative production, and perennial grasses provide at least 25 percent <br />relative production, and no single species shall exceed 75 percent relative cover". The <br />postmining land use for Mine 3 is the same as in permit C-81-071. This demonstrates <br />that utilizing this type of standard for Mine 3 falls within the accepted practices for the <br />area. <br />The literature indicates that application of a diversity index, such as the Shannon-Weiner, <br />may not be the best approach for determining if this parameter has been successfully met <br />at a reclaimed mine site. For example, see Chambers, 1983, "Measuring Species <br />Diversity on Revegetated Surface Mines: An Evaluation of Techniques". The Shannon- <br />Weiner index was proposed during the initial permitting of the mine under the new coal <br />regulations dictated by the enactment of SMCRA. At that point in time it was thought <br />that the application of this index could be used for addressing the diversity requirement <br />presented in the regulations. As with all new programs there is a learning process <br />associated with application of the regulations. The lesson learned from this one is that <br />the index is not applicable to assessing diversity standards on sites returned to a <br />pastureland land use. The sites are managed to produce forage for cattle and having a <br />diverse community equal to a sage brush or mountain shrub community does not <br />facilitate the postmining land-use. <br />