GENERAL38441

• Permit No: C1982057
• IBM Index Class Name: General Documents
• Doc Date: 2/26/1985
• Doc Name: Memo on PRELIMINARY ADEQUACY REVIEW COMMENTS
• From: MLRD
• To: ANNE BALDRIGE
• Permit Index Doc Type: VEGETATION
• Media Type: D
• Archive: No

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999
Richard D. Lamm
Governor
DEPARTMENT OF NATURAL RESOURCES
David H. Getches, Ezeculive Director
MINED LAND RECLAMATION DIVISION
DAVID C. SHELTO N, Director
DATE: February 26, 1985
T0: Anne Baldrige
FROM: Mike Savage ~ovA1.~__
RE: Preliminary Adequacy Review Comments for the Seneca II West Mine
File No. C-057-82
I have reviewed the assigned sections in the Seneca IIW permit application and
have the following comments.
V~etation and Revegetaion - Rule 2.04.10 and 2.05.4(2)(e)
1. All of the reference areas for the Seneca II Mine (aspen, mixed brush,
sage brush, low sage, and wheat) are located outside of the permit
boundary for the mine. The applicant needs to demonstrate to the
satisfaction of the Division that they have surface control for the
life-of-mine for areas within which the references areas are located.
This is to insure that the reference areas receive the same management
as they have in the past.
2. The applicant should supply a table of the total number of disturbed
acres for each vegetative community during this permit term and during
the life-of-mine.
3. It has been determined that the sagebrush, aspen, and meadow
communities; when compared with their respective reference areas are
not comparable. For all these communities reported cover and woody
plant densities of the reference areas are higher than those of the
affected area. The productivity of the reference areas is reported as
much lower. This presents a dilemma with regard to the productivity
parameter. The applicant and the Division will have to determine
whether new references areas need to be established or whether an
alternative solution can be agreed upon.
4. The applicant needs to further explain the use of cover crops on
reclaimed areas. The Division has reservations regarding the approval
of cover crops, since many areas in northwest Colorado have abandoned
cover cropping due to the inherent problems with natural reseeding of
the cover crop, competition from the cover crop with perennial
revegetation species, and moisture depletion by cover crops.
5. With regard to the proposed seed mixes, the applicant should remove
alfalfa and pubescent wheatgrass from the mixes and substitute other
preferred species in their place.
423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. [phone]