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III IIIIIIIIIIIII III STATE, OF COLOlZ~1~U +\~~~;:~ Roy Romer, Governor ~~ /P'!6 ~ _ r DEPARTMENT OF NATURAL RESOURCES ~ ~~ MINED LAND RECLAMATION DIVISION j;';~•~~ ~~2 FRED R. BANTA, Dlractor ~ ~. ~~ July 24, 1989 14r. David Gossett Kerr Coal Company C/0 ACZ Engineering and Analytical Services 1475 Pine Grove Road P.O. Box 774018 Steamboat Springs, Colorado 80477 RE: Kerr Coal Company 1988 Annual Reclamation Report, C-80-006 Dear Mr. Gossett: The Division has reviewed the 1988 Annual Reclamation Report submitted June 9, 1989. Comments under the heading of "I. General Review of Appendix A" involve adeD.uacy concerns relating to the Annual Report. Comments under the heading "II. Re viev+ of Kerr Recommendations to the Reclamation Plan" should be considered Drior to submittal of a revised reclamation plan. General Review of Appendix A In the first section of Appendix A, the authors address trends in cover, production, woody plant Density, species diversity, and the potential dominance of Darticular introduced species, over the three sampling periods (1984, 1986 and 1988)• They also consider whether revegetation success is being achieved. The conclusions reached are that diversity standards and production requirements have probably been met in all reclaimed areas. Cover is expected to be met if herbaceous layer rather than total plant cover comparisons are made between reference and reclaimed areas. However, reference areas were not sampled for comparison, and woody plant density is not close to the standard of 2,000 stems/acre on any site. This section is acceptable with the foliow.ino exceptions. The authors often casually explain negative trends since 1986 as being a function of 1988 being a dry year (which is not proven) or of 1988 samDlinD not being intensive enough to be a valid sample of the population. These are both weak arguments considering that otner possible explanations were not explored or ruled out. Furthermore, accordi,nD to the hlay, June, and July 1988 issues of "Colorado Climate", May, 1988, precipitation at Walden was 163.6x, June was 72.~~, and July was 106.5° of the normal amount o` precipitation that is typically expected for each of those months. This data indicates that the early summer of 1988 before the July 21 and 22 vegetation samplinD was not an exceptionally dry year. "Colorado Climate" does indicate that the 1988 water year precipitation average was lower than the 1986 water year average in Walden (127q vs. 151b of the 1961-1980 average, respectively) but that precipitation in 1988 was considerably above average. The issue of sampling intensity is addressed in Section I.B. 215 Centennial Building, 1313 Sherman Sireet Denver, Colorado 80203.2273 Tel. (303) 8663567