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STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1373 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8706 <br />DATE: December 6, 2005 <br />TO: Jim Stark <br />FROM: Dan Mathews I <br />RE: Colowyo Mine TR-62 (Decrease Topsoil Replacement Depths) <br />Permit C-1981-019 <br />COLORADO <br />DIVISION OF <br />MINERALS <br />GEOLOGY <br />AEGEAN ATION•MINING <br />SAf ETY•SUENCE <br />Bill Owens <br />Governor <br />Russell George <br />Executive Director <br />Ronald W. Cottony <br />Division Director <br />Natural Resource Trustee <br />I have reviewed the referenced revision application per your request, and my itemized comments <br />are listed below. <br />Also, you requested that I review the plan to see if I had any recommendations in regard to their <br />revegetation plan. Back in October, I reviewed the revegetation monitoring report that was <br />included in the 2004 Annual Reclamation Report. If you do not have a copy of my October 24, <br />memo, here are the salient points. <br />The data, evaluations, and recommendations [included in the vegetation report] provide a good <br />foundation for a thorough reassessment of Colowyo's revegetation plan and success standards, <br />and I believe it would be appropriate to request that the operator submit a technical revision <br />application addressing various issues addressed in the report, including: <br />• Heavy grass dominance and low potential for achievement of woody plant success standard <br />in older reclaimed areas (need for establishment of a reasonable standard for these areas, <br />with possible need for certain remedial efforts); <br />• Alternative approaches to be applied in future reclamation efforts to enhance woody plant <br />establishment and vegetative diversity; <br />• Re-assessment of woody plant density and species diversity standard targets for recent and <br />future reclamation, to more closely reflect current reclamation objectives and state of <br />knowledge; <br />• A plan for management of annual brome, which has become established in significant <br />densities in some areas, and could significantly impact revegetation efforts. <br />I don't know whether you want to include these concerns within the TR-62 PAR letter, or as a <br />separate, stand alone letter based on my review of the 2004 revegetation report. But I do think <br />that we need to formally request that they address these issues at this time. <br />Let me know if you have any questions regarding either the revegetation concerns, or the <br />itemized TR-62 comments below. <br />TR-62 Review Comments <br />During initial permitting of the Colowyo Mine in the early 1980's, the Division had <br />questioned whether the intensity of baseline soil sampling and mapping was adequate to <br />Office of Office of Colorado <br />Mined Land Reclamation Active and Inactive Mines Geological Su <br />