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ENERGY COMPANY <br />P.O. BOX 467 GOLDEN, COLORADO 80402 <br />November 9, 2012 <br />Jared Ebert, Environmental Protection Specialist <br />Colorado Division of Reclamation, Mining and Safety <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />Re: Technical Revision No. 43 <br />Revision of Vegetation Cover and Herbaceous Production Revegetation <br />Success Criteria to Remove Prohibited Species <br />Permit No. C- 1981 -028 [Keenesburg Mine] <br />Dear Mr. Ebert: <br />RECEIVED <br />Nov 142012 <br />Division of Reclamation, <br />Mining & Safety <br />Coors Energy Company (CEC) is submitting a technical revision (TR -43) application to the <br />Keenesburg Mine permit to revise the vegetation cover and herbaceous production final <br />revegetation success criteria by modifying the predictive equations. The modifications provide <br />for the removal of prohibited species identified by CDRMS during a review of the 2011 Annual <br />Reclamation Report. <br />The contents of the TR -43 application include an explanation of the measures that were <br />undertaken to revise the final revegetation success criteria, as well as the applicable revised <br />permit page. <br />In correspondence dated October 16, 2012, you noted an apparent discrepancy in the cumulative <br />precipitation record for ,1995. At CEC's request Michael Savage revisited the precipitation <br />records and reconfirmed the values he had presented (Table 6, attached). If the CDRMS records <br />reflect different data, please contact him to compare and confirm the data sets. <br />With regard to the request for "documentation and rationale that the correlation coefficients <br />yielded by the new equations are adequate ", it can be stated that the equations provide the best <br />mathematical correlations available that represent the biologic environment, based on the <br />CDRMS requirement to remove ineligible plant species. <br />