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Mr. Robert Zuber <br />Division of Reclamation, Mining & Safety <br />Department of Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />Re: Response to Division Review <br />Annual Hydrology & Reclamation Report - 2010 <br />Keenesburg Mine, Permit C- 1981 -028 <br />Dear Mr. Zuber: <br />ENERGY COMPANY <br />P.O. BOX 467 GOLDEN, COLORADO 80402 <br />August 24, 2011 <br />This letter and the enclosed revision page constitute Coors Energy Company's (CEC's) response to the <br />Division of Reclamation, Mining & Safety's (Division's) review letter dated July 11, 2011. CEC's response <br />will endeavor to address the two concerns raised by the Division following its review of the 2010 Annual <br />Hydrology & Reclamation Report. <br />Response 1: (Acreage values) <br />Attached please find three (3) copies of a revised page 99 for the submitted AHR report. CEC asks that <br />these copies be inserted into the Division's three copies of the report document, replacing the existing <br />page. <br />Response 2: ( Cheatgrass) <br />While CEC understands and agrees that cheatgrass is not a "desirable" plant species, CEC has difficulty <br />with the statements advanced by the Division in its analysis of this concern. CEC would respectfully ask <br />that the Division provide the regulatory citation(s) that support its determination that cheatgrass, <br />"should not be counted in the percent cover value ", and the further statements that noxious weeds <br />cannot contribute to vegetation success, specifically with respect to vegetation cover. <br />House Report No. 95 -218 (1977) identifies and discusses the legislative thinking and basis for <br />establishment of the requirements of the Surface Mining Control and Reclamation Act (SMCRA), and <br />subsequently the Colorado Surface Coal Mining Reclamation Act (CRS 34 -33 101 et seq). The <br />revegetation section of the House Report specifically addresses the reasoning behind identifying certain <br />parameters for evaluating revegetation of mined lands. In part the report states: <br />