REV101662

• Permit No: C1981033
• IBM Index Class Name: Revision
• Doc Date: 12/3/1997
• Doc Name: REVIEW OF VEGETATION MONITORING DATA
• From: DMG
• To: BEAR 1 & 2 MINES BOND RELEASE FILE SL-01 BEAR MINES PN C-81-033
• Type & Sequence: SL1
• Media Type: D
• Archive: No

III IIIIIIIIIIIII III
999
STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Depanmenl of Natural Resources
131 3 Sherman 51., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: 13031 ri32 8106
DATE: December 3, 1997
TO: Bear No. 1 and No. 2 Mines Bond Release File (SL-O1)
Bear Mines Permit (C-81-033)
FROM: Susan Burgmaier O-
RE: Review of Vegetatio0000n "~~M~~~-onitoring Data
~~~~~ -
DEPARTME[NT OF
NATURAL
RESOURCES
Roy Romer
Guve nor
lames S Luchhead
E~eculrve Director
Michael B. long
Division DireUOr
Bear Coal Company submitted 1991 and 1992 vegetation monitoring data with TR-]0, requesting
approval to remove the sedimentation pond, and asking the Division to find that the vegetation data
indicated that the revegetation success standards had been met. The Division granted the approval for
pond removal, and found that the vegetation standards had been met.
Bear Coal Company applied for bond release in 1994, and submitted vegetation data from 1993 (in
addition to the previously submitted 1991 and 1992 data) to support their contention that the vegetation
success standards had been met.
When Bear Coal Company applied for Phases I, II, and 111 bond release in 1994, the vegetation
monitoringdata was reviewed by Tony Waldron, and found to be adequate. At the time, Tony was the
lead specialist for the site. For various reasons, review and approval of the bond release was delayed,
during which time Tony lefr the Coal Program. When I finished reviewing the application in 1997, I did
not locate a memo from Tony's review of the vegetation data. In the absence of a memo, [again
reviewed the 1991, 1992, and 1993 data top determine whether or not the vegetation meets the
reclamation success standards.
The Division, at Bear Coal Company's request, set the revegetation success standards for the Bear
Mines. The success standard for herbaceous cover is 40%. For herbaceous production, the standard
is 1600 pounds per acre. The species diversity standard requires that vegetation include at leas[ three
herbaceous species with relative coverequal to or greater than 3% two of which are to be grasses, ani
one a forb. The combined relative cover of these species shall not exceed 80%, and no one species
should comprise greater than 60% of the relative cover. There is no woody stem component in the
success standard.
A review of the monitoring methodology indicates [ha[ monitoring was conducted in accordance with
the approved plan and the Division's Bond Release Guidelines. In all three years' data, herbaceous
cover was estimated using an optical point frame, using only first hit data. Production was estimated
by clipping five quarter meter square quadrats along the length of 25 meter transects, as stipulated in
the 1987 Findings Document. Species diversity was determined using multiple hit data in 1991 and
1992, and first hit data in 1993. Matt Hayes (Bear consultant) included a comparison of first hit versta
multiple hit data for 1991 and 1992, and found that the difference between the two types of data was
negligible. I verified this with Larry Routten, and he agreed. Larry pointed out that differences in
first hit versus multiple hit data are most apparent in muhi-storied vegetation communities. Since the
vegetation at the Bear sites is of a fairly uniform height, first hit and multiple hit data are relatively
interchangeable. The operator's calculations of sample adequacy for 1993 were verified, and sample