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Home My WebLink About20090737.tiffSavage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 970 674 8080 telephone 970 674 8088 facsimile savageanclsavage@earthlink.net Weld County Clerk and Recorder 1402 N. 17th Avenue Greeley, CO 80631 Re: Phase III Bond Release Application for the Coors Energy Company Keenesburg Mine (CDRMS file C-1981-028) Dear Weld County Clerk: Please retain the enclosed bond release application for the Keenesburg Mine on file for public review in accordance with your normal procedures. If you have any questions, please contact me at the above number. Thank you. Sincerely, Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4586 RETURN RECEIPT REQUESTED Enclosure: Keenesburg Mine Phase III Final bond release application (2009) cc w/out enclosure: Janet Binns, CDRMS Don MacDonald, Coors Energy Company -PAL.C?tV/61,0 C8/V 0(1 %C) 2009-0737 Phase III Bond Release Application Coors Energy Company Keenesburg Mine Weld County, Colorado Prepared by: Savage and Savage, Inc. 4610 Haystack Drive Windsor, Colorado 80550 970.674.8080 March 2009 • • • Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 970 674 8080 telephone 970 674 8088 facsimile savageancisavage@earthlink.net Ms. Janet Binns, Environmental Protection Specialist Colorado Division of Reclamation, Mining & Safety 1313 Sherman Street, Room 215 Denver, Colorado 80203 Re: Application for Phase III Bond Release, Keenesburg Mine (CDRMS file C-1981-028) Dear Janet: Attached is the Phase III bond and liability release application for the Coors Energy Company Keenesburg Mine (CDRMS file C-1981-028) north of Keenesburg in Weld County, Colorado. This application seeks release for successful final reclamation at Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 within the mine site under CRS 34-33-125(9)(c) and Rule 3.03.1(2)(c). Copies of the required notifications, application information, certification, and public notice are attached for review. If any additional materials are required, or if there are any questions regarding the information presented, please contact me or Don MacDonald at Coors Energy. Sincerely, Ailss-Ar-- Michael S. Savage Principal enclosure: Keenesburg Mine Phase III bond release application C: Don MacDonald, Coors Energy Company Weld County Clerk and Recorder • • • March 2009 Phase III Bond Release Application Coors Energy Company Keenesburg Mine Weld County, Colorado Prepared by: Savage and Savage, Inc. 4610 Haystack Drive Windsor, Colorado 80550 970.674.8080 COORS ENERGY COMPANY KEENESBURG MINE CDRMS FILE C-1981-028 PHASE III BOND RELEASE APPLICATION Date of Request: March 13, 2009 Permittee: Coors Energy Company Permit Number: C-1981-028 Permit Approval Date: November 3, 1981 Mine Name: Keenesburg Mine Bond Release Phase Requested: Phase III Acreage: Current Permit Area: Maximum Area Disturbed: Area Sought for Release: 610.86 acres + 437.69 acres + 165.29 acres Bonding Company: Travelers Casualty and Surety Company of America Bond Number: 103799990 Proposed Bond Amount (after release): $2,077,712.00 Original Bond Amount: $9,077,000.00 (November 10, 1983 permit issuance) Applicable Bond Amount (for bond release calculation purposes): $4,402,022.00 Current Bond Amount: $2,327,437.00 Bond Amount Requested for Release: $249,331.00 The amount requested for release is based on the methodology employed by the Division during the SL -03 bond release process. In that bond release for the Keenesburg Mine, the Division first established the applicable original reclamation bond amount. Then, the allowable amount of bond that could be released under the regulations was calculated. Third, the acreage for which bond release was being sought was determined, and the percentage of the bond release area was calculated relative to the permit area. The percentage of bond release area was multiplied by the reclamation bond amount eligible for release to obtain the calculated bond release amount. Coors Energy Company Keenesburg Mine Page 1 Phase III Bond Release: 1985/1986/1987/1995/1997 Areas In this Phase III bond release, the applicable bond amount determined by the Division was $4,402,022.00. The percentage of reclamation bond retained between the approved Phase II bond release and Phase III bond release is 15 percent of the total reclamation bond. Multiplying the applicable reclamation bond amount by 15 percent yields the total bond amount eligible for release for the permit area for all Phase III bond release actions, or, $660,303.30. The acreage proposed for Phase III bond release under this application is 165.29 acres. The permitted acreage is 610.86 acres, and the total acreage disturbed over the life of the mine is 437.69 acres. From this point in our calculation, we propose to use the actual area disturbed (437.69 acres) rather than the permit area (as the Division did in SL03) for the reason that there was, and is, no reclamation liability for areas within the permit area that have not been disturbed, therefore the reclamation bond does not apply to those undisturbed areas, and undisturbed areas should not be used in any bond release calculations. The percentage of area requested for Phase III bond release in this application is 37.76 percent (165.29 acres/ 437.69 acres). This percentage, multiplied by the reclamation bond amount eligible for Phase III bond release amounts to $249,330.52 ($660,303.30 x 0.3776). Therefore, the reclamation bond amount requested for release in this Phase III application is $249,331.00. Leval Description of the Area Requested for Bond Release: The Phase III bond release application requests release of bond and liability for successfully completing all required reclamation tasks at Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 within the mine site, located in portions of Sections 25 and 36, T3N, R64W, Sixth Principal Meridian, Weld County, Colorado. This area comprises approximately 165.29 acres. Map: The enclosed map titled, Coors Energy Company Vegetation/Re-Vegetation Map identifies the areas requested for Phase III final bond and liability release. Dates of Reclamation Work: Reclamation work was undertaken in the areas requested for release between 1985 and 1997 by Coors Energy Company. Description of Bond Release Amount Request: This bond release request seeks final bond and liability release at Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 totaling approximately 165.29 acres in size. The areas reclaimed have been demonstrated to meet the requirements for erosion control (SL03), and meet the final bond release vegetation standard for cover, total herbaceous production, and species composition (enclosed vegetation studies for 2007 and 2008). The areas requested for release are in conformance with the approved post -mining land use which has been implemented. Remaining reclamation obligations at the mine site include the final reclamation of the remaining area of the "B" Pit, the long term spoil area, topsand piles A-1, A-3, and B-1, the facilities area, and additional miscellaneous ancillary areas. Protection of the Hydrologic Balance: Annual Hydrologic Reports have been submitted annually for the mine and the information within the AHR's has demonstrated the continued protection of the hydrologic balance at the mine site and off -site. Self - monitoring of the sediment control system has been continual, and where regular Coors Energy Company Keenesburg Mine Page 2 Phase III Bond Release: 1985/1986/1987/1995/1997 Areas inspections have revealed concerns with protection of the hydrologic balance, protection measures have been implemented and maintained. Notice to Parties Identified in Rule 3.03.2(1): Please see attached copies of letters and certified receipts sent to specified parties. A copy of the letter to the Weld County Clerk and Recorder, requesting retention of the public copy of the bond release application is enclosed in this section. Newspaper Advertisement: A copy of the newspaper advertisement to be published in the Fort Lupton Press is attached. A copy of the proof of publication will be forwarded for inclusion when received. Achievement of Revegetation Success The reports, 2007 Quantitative Vegetation Study, Phase III Bond Release [Year 11, Coors Energy Company Keenesburg Mine, Keenesburg, Colorado, and 2008 Quantitative Vegetation Study, Phase III Bond Release [Year 21, Coors Energy Company Keenesburg Mine, Keenesburg, Colorado that document achievement of the applicable final revegetation bond release criteria are appended to this application. A summary of the applicable revegetation success criteria and sampled values for 2007 and 2008 for the Keenesburg Mine follows. Vegetation Cover The revegetation success criterion for vegetation cover for the Keenesburg Mine is a predictive equation based on cumulative precipitation amounts during the period from September -July. The predictive equation for total vegetation cover is y=0.0173x3- 0.8592x2+14.562x-47.015, where xis the cumulative amount of precipitation and y is the total percentage of live vegetation cover. The vegetation cover success criterion value for 2007 was calculated to be 36.45% total vegetation cover (based on 15.00" precipitation value). Total Vegetation Cover (2007) 1985/1986/1987 Rec. Areas 1995/1997 Rec. Areas Xbar S N Nmin 60.80 % 7.40 20 4 61.40 % 8.20 20 5 The vegetation cover success criterion value for 2008 was calculated to be 23.13% total vegetation cover (based on 7.95" precipitation value). Total Vegetation Cover (2008) Coors Energy Company Keenesburg Mine Page 3 Phase III Bond Release: 1985/1986/1987/1995/1997 Areas 1985/1986/1987 Rec. Areas 1995/1997 Rec. Areas • • • Xbar S N Nmin Total Herbaceous Production 63.20 % 6.36 15 2 59.20 % 5.65 15 2 The revegetation success criterion for total herbaceous production for the Keenesburg Mine is a predictive equation based on cumulative precipitation amounts during the period from September -July. The predictive equation for total herbaceous production is y=0.3749xz.zaes where x is the cumulative amount of precipitation and y is the total herbaceous production (in g/m2). The total herbaceous production success criterion value for 2007 was calculated to be 165.33 g/m2 (based on 15.00" precipitation value). Total Herbaceous Production (2007) 1985/1986/1987 Rec. Areas 1995/1997 Rec. Areas Xbar S N Nmin 239.46 g/m2 57.21 25 10 229.27 g/m2 59.10 35 11 The total herbaceous production success criterion value for 2008 was calculated to be 39.66 g/m2 (based on 7.95" precipitation value). Total Herbaceous Production (2008) 1985/1986/1987 Rec. Areas 1995/1997 Rec. Areas Xbar S N Nmin 144.68 32.08 15 9 174.86 52.44 25 16 Coors Energy Company Keenesburg Mine Page 4 Phase III Bond Release: 1985/1986/1987/1995/1997 Areas Species Composition The species composition success criterion requires that there be at least four perennial species, of which three are warm season grasses and one a cool season grass. No one component of the above four species should comprise greater than 40% relative importance nor less than 3% relative importance. Relative importance will be measured by calculating relative cover of the revegetation species. Vegetation species which may be used in the calculation of species composition may be any plant species not defined as a noxious or prohibited plant species, and may be native or introduced. Species Composition (2007) Success Standard 1985/1986/1987 Rec. Areas 1995/1997 Rec. Areas Total Perennial Species* Warm Season Grasses* Cool Season Grasses* Relative Importance (3%<x<40%) 4 3 All Species Species Composition (2008) Success Standard 7 3 3 All Species 8 4 3 All Species 1985/1986/1987 Rec. Areas 1995/1997 Rec. Areas Total Perennial Species* Warm Season Grasses* Cool Season Grasses* Relative Importance (3%<x<40%) 4 3 All Species 7 4 2 All Species 7 4 2 All Species * Numbers reflect only those species meeting the relative importance percentage limitation From the summary information above, the 1985, 1986, and 1987 reclamation areas and the 1995 and 1997 reclamation areas exceeded the final revegetation success criteria values for total vegetation cover, total herbaceous production, and species composition in 2007 and 2008, thereby demonstrating that the permittee has established a diverse, effective, and permanent vegetative cover of the same seasonal variety as the original vegetation. The revegetated area is capable of self -regeneration and plant succession. The data shows development of a stable, self-sustaining vegetation community, with seasonality and diversity sufficient to demonstrate successful reestablishment of vegetation on the reclaimed area. Coors Energy Company Keenesburg Mine Page 5 Phase III Bond Release: 1985/1986/1987/1995/1997 Areas NOTARIZED STATEMENT OF COMPLIANCE In accordance in Colorado Division of Reclamation, Mining and Safety Rule 3.03.2(e), I hereby certify that to the best of my knowledge and belief, all applicable reclamation activities for which Phase III bond release is being sought at the Coors Energy Company Keenesburg Mine (CDRMS Permit # C-1981-028, Bond Release Application SL -04) have been accomplished in accordance with the requirements of the Act (CRS 34-33-101 et seq), the applicable rules pursuant to the Act and the approved reclamation program as detailed and approved in the mining and reclamation permit, C-1981-028. Signed Date O3- o1-aZSJ5 Donald W. MacDonald Coors Energy Company State of Colorado Subsc�'nbedd and sworn to (or affirmed) before me at � �✓��(�, (city), by,�ilyral ,ry'�6 a(signer's name) on Q 3 -i? -07 (date). ary Public's Signature My Commission Expires: a y — • SEAL LIDUINA A. ARMIJO NOTARY PUBLIC STATE OF COLORADO • • a NOTICES TO AFFECTED PARTIES • • • Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 970 674 8080 telephone 970 674 8088 facsimile savageandsavage@earthlink.net Weld County Clerk and Recorder 1402 N. 17th Avenue Greeley, CO 80631 Re: Phase III Bond Release Application for the Coors Energy Company Keenesburg Mine (CDRMS file C-1981-028) Dear Weld County Clerk: Please retain the enclosed bond release application for the Keenesburg Mine on file for public review in accordance with your normal procedures. If you have any questions, please contact me at the above number. Thank you. Sincerely, Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4586 RETURN RECEIPT REQUESTED Enclosure: Keenesburg Mine Phase III Final bond release application (2009) cc w/out enclosure: Janet Binns, CDRMS Don MacDonald, Coors Energy Company • I Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 WJW Properties LLC 16350 Weld County Road 76 Eaton, CO 80615 970 674 8080 telephone 970 674 8088 facsimile savageandsavage@earthlink.net Re: Notice of Application for Phase III Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81-028) Dear Sir or Madam: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-181-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. • • • This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17`h Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for please contact the Colorado Division of Reclamation, Mining, and Safety, 1 Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me number. Sincerely, Aids% -re -- Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4593 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company bond release, 313 Sherman at the above • • • Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 970 674 8080 telephone 970 674 8088 facsimile savageandsavage@earthlink.net Waste Management Corporation c/o Marvin F. Poer & Company P.O. Box 802206 Dallas, TX 75380-2206 Re: Notice of Application for Phase III Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81-028) Dear Sir or Madam: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. • • • This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17`h Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4609 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company • • • Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 Guttersen Ranches LLC 13696 Weld County Road 74 Eaton, CO 80615 970 674 8080 telephone 970 674 8088 facsimile savageandsavage@earthlink.net Re: Notice of Application for Phase III Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81-028) Dear Sir or Madam: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17th Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4616 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company • • • Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 Frederick Heyde 8646 Cord Road Cord, AZ 72524 970 674 8080 telephone 970 674 8088 facsimile savageandsavage@earthlink.net Re: Notice of Application for Phase III Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81-028) Dear Mr. Heyde: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. • • • This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17`" Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4623 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company • • S Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 970 674 8080 telephone 970 674 8088 facsimile savageandsavage@earthlink.net Panenergy Field Services, Inc. do Panhandle Eastern Corporation P.O. Box 1642 Houston, TX 77251-1642 Re: Notice of Application for Phase III Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81-028) Dear Sir or Madam: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. • • • This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17th Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, taisor— Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4661 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company • • • Savage and Savage Environmental practical solutions for environmental issues 461O Haystack Drive Windsor, Colorado 80550 March 13, 2009 970 674 8080 telephone 970 674 8088 facsimile savageandsavage@earthlink.net District Conservationist Natural Resource Conservation Service 57 W. Bromley Lane Brighton, CO 80601 Re: Notice of Application for Phase III Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81-028) Dear District Conservationist: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. • • • This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17`h Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4678 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company • • • Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 970 674 8080 telephone 970 674 8088 facsimile savageandsavage@earthlink.net SW Weld Conservation District 57 W. Bromley Lane Brighton, CO 80601 Re: Notice of Application for Phase III Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81-028) Dear Sir or Madam: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. • • • This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17th Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4685 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company • • • Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 970 674 8080 telephone 9706748088 facsimile savagea ndsavagepearthlink.net State Board of Land Commissioners 1313 Sherman, Room 620 Denver, CO 80203 Re: Notice of Application for Phase III Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81-028) Dear Sir or Madam: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. • • • This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17th Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4692 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 970 674 8080 telephone 970 674 8088 facsimile savageandsavage@earthlink.net Colorado Division of Wildlife Department of Natural Resources 6060 Broadway Denver, CO 80216 Re: Notice of Application for Phase III Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81 -028) Dear CDOW: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. • • S • This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17`h Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4708 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company • • S Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 970 674 8080 telephone 970 674 8088 facsimile savageandsavage@earthlink.net Doug Ikenberry Colorado Department of Public Health and Environment Hazardous Materials & Waste Management Division 4300 Cherry Creek Drive South Denver, CO 80246-1530 Re: Notice of Application for Phase III Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81-028) Dear Ms. Watson: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. • • • This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17`h Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4715 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company • Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 970 674 8080 telephone 970 674 8088 facsimile savageandsavage@earthlink.net Weld County Commissioners 915 10th Street Greeley, CO 80632 Re: Notice of Application for Phase III Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81-028) Dear County Commissioners: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. • • • This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17th Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4722 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company • • • Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 970 674 8080 telephone 970 674 8088 facsimile savageandsavage@earthlink.net Weld County Planning Department 915 10th Street Greeley, CO 80632 Re: Notice of Application for Phase III Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81-028) Dear Weld County Planning Department: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. • • • This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17`h Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, Aalsevre-- Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4739 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company • • • Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 970 674 8080 telephone 970 674 8088 facsimile savageandsavage@earthlink.net Central Colorado Water Conservancy District 3209 W. 28th Street Greeley, CO 80631 Re: Notice of Application for Phase Ill Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81-028) Dear Sir or Madam: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17th Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, • Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4746 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company • S • Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 Central Weld County Water 2235 2nd Avenue Greeley, CO 80631 970 674 8080 telephone 970 674 8088 facsimile savageanclsavage@earthlink.net Re: Notice of Application for Phase III Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81-028) Dear Sir or Madam: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. • • • This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 176' Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4753 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company S • • Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 970 674 8080 telephone 970 674 8088 facsimile savageandsavage@earthlink.net Groundwater Appropriations of S. Platte 219 E. Railroad Avenue Fort Morgan, CO 80701 Re: Notice of Application for Phase III Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C -8I-028) Dear Sir or Madam: Coors Energy Company is applying for a Phase 111 final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. • • i This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17`h Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, Aidsovr-- Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4760 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company • • • Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 City of Keenesburg P.O. Box 312 Keenesburg, CO 80643 970 674 8080 telephone 970 674 8088 facsimile savagea ndsavagepearthlink.net Re: Notice of Application for Phase 111 Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81-028) Dear Sir or Madam: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 1 I, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. • • • This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17`h Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, Aldser Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4777 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company • • • Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive Windsor, Colorado 80550 March 13, 2009 City of Keenesburg P.O. Box 312 Keenesburg, CO 80643 970 674 8080 telephone 970 674 8088 facsimile savagea ndsavage@earthlink.net Re: Notice of Application for Phase III Bond Release for the Coors Energy Company Keenesburg Mine (CDRMS file C-81-028) Dear Sir or Madam: Coors Energy Company is applying for a Phase III final liability and bond release for portions of the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-81-028) in accordance with the approved reclamation plan. The subject of the bond release is a release from liability and reclamation bond for those areas where final reclamation has been completed and successful establishment of vegetation has been demonstrated under the approved reclamation plan. This includes Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 encompassing approximately 165.29 acres. The current permit area is located within Sections 25 and 36 of Township 3 North, Range 64 West of the 6th Principal Meridian, Weld County, Colorado. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. As required by Colorado law, whenever bond release is requested, all interested or affected parties with a valid legal interest must be notified and afforded the opportunity to comment or request an informal conference on the bond release in accordance with Rule 3.03.3 of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining. • • • This letter will serve to notify you that Coors Energy Company is requesting Phase III liability and bond release in the amount of $249,331.00 of the total calculated current reclamation bond amount of $2,327,437.00. A copy of the entire bond release application submitted to the Colorado Division of Reclamation, Mining, and Safety will be on file with the Division in Denver, Colorado at 1313 Sherman Street, Room 215 (telephone 303.866.3567), and the Weld County Clerk and Recorder's Office, 1402 N. 17t1' Avenue, Greeley, Colorado 80631, during the review period. All information pertinent to the bond release request is presented within this application. If you have any questions, comments, or concerns regarding the request for bond release, please contact the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, CO 80203 (telephone 303.866.3567). Additionally, if I can answer any questions or concerns, please call me at the above number. Sincerely, Addesar-- Michael S. Savage Principal CERTIFIED MAIL # 7007 0220 0001 6527 4777 RETURN RECEIPT REQUESTED c: CDRMS, Denver Don MacDonald, Coors Energy Company • • • NEWSPAPER PUBLIC NOTICE • • • PUBLIC NOTICE Coors Energy Company, P.O. Box 467, Golden, Colorado 80402 (telephone (303) 277- 3455) has filed an application for a Phase III bond release for final reclamation work completed at the Keenesburg Mine with the Colorado Division of Reclamation, Mining and Safety (permit C-1981-028, approved November 3, 1981). The Phase III bond release application requests release of bond and liability for successfully completing all required reclamation tasks at Areas 1, 3, 4, 8, 11, 12, 13, 14, 17, 18, 20, 21, 22, 24, 26, 27, and 28 within the mine site. The bond release is sought for approximately 165.29 acres at the site. The current bond is a corporate surety. The current CDRMS calculated bond amount prior to the proposed release is $2,327,437.00, and the amount requested for release is $249,331.00. The legal description of the permit area is: a tract of land located within Sections 25 and 36, Township 3 North, Range 64 West of the Sixth Principal Meridian, Weld County, Colorado. The surface owner of the property for which bond release in being requested is Coors Energy Company. The U.S.G.S. 7.5 minute quadrangles titled "Klug Ranch" and "Tampa" contain the permit area of the mine. The permit area is located seven miles north of Keenesburg, Colorado, and is accessed by Weld County Road 59. A copy of the bond release request application is available for public review at the Weld County Clerk and Recorder's Office, 1402 N. 17th Avenue, Greeley, Colorado 80631, and at the Colorado Division of Reclamation, Mining, and Safety, 1313 Sherman St., Room 215, Denver, Colorado 80203, phone (303) 866-3567. In accordance with Rule 3.03.2(3) any person with a valid legal interest which might be adversely affected by release of the bond, or any federal, state, or local governmental agency with jurisdiction over regulated activities at the mine shall have the right to file written objections to or comments upon the requested release and/or file a request for an informal conference with the Division within thirty (30) days of the last publication of this notice, or within thirty (30) days of the completed bond release inspection to be conducted by the Division, whichever is later. All comments, objections, and requests must be submitted in writing to the Colorado Division of Reclamation, Mining, and Safety at the above address. Published in the Fort Lupton Press, , 2009. • • • RE VEGETATION STUDIES • • • December 2007 2007 Quantitative Vegetation Study Phase III Bond Release [Year 11 Coors Energy Company Keenesburg Mine Keenesburg, Colorado Prepared by: Savage and Savage, Inc. 4610 Haystack Drive Windsor, Colorado 80550 970.674.8080 TABLE OF CONTENTS Page EXECUTIVE SUMMARY 1.0 INTRODUCTION 2.0 METHODS 2.1 Sampling Design 2.2 Field Sampling 2.2.1 Timing 2.2.2 Vegetation Cover 2.2.3 Herbaceous Production 2.2.4 Species Composition 2.3 Sample Numbers/Sample Adequacy 2.4 Statistical Analysis 2.5 Species Identification and Verification 3.0 RESULTS 3.1 Quantitative Evaluation: Reclamation Areas 3.1.1 1985, 1986, and 1987 Reclamation Areas 3.1.1.1 Vegetation Cover 3.1.1.2 Herbaceous Production 3.1.1.3 Species Composition 3.1.2 1995 and 1997 Reclamation Areas 3.1.2.1 Vegetation Cover 3.1.2.2 Herbaceous Production 3.1.2.3 Species Composition 3.3 Comparison of Reclamation Areas with Final Revegetation Success Criteria 4.0 DISCUSSION AND CONCLUSIONS 4.1 Vegetation Cover 4.2 Herbaceous Production 4.3 Species Composition 5.0 SUMMARY 6.0 LITERATURE CITED 7.0 TABLES 8.0 APPENDIX Page ii 4. 5. 5. 6. 6. 7. 7. 7. 7. 8. 8. 8. 8. 8. 9. 10. 10. 10. 11. 11. 12. 12. 14. 14. 14. 14. 15. 16. 17. 24. LIST OF TABLES 2007 Plant Species List: Keenesburg Mine 1985, 1986, 1987, 1995 and 1997 Reclamation Areas Page 18. 2. Vegetation Cover: 1985, 1986, and 1987 Reclamation Areas (2007) 20. 3. Vegetation Cover: 1995 and 1997 Reclamation Areas (2007) 21. Herbaceous Production: Keenesburg Mine 1985, 1986, and 1987 4. 22. Reclamation Areas (2007) Herbaceous Production: Keenesburg Mine 1995 and 1997 5' 23. Reclamation Areas (2007) APPENDIX Page 2007 Coors Energy Company Vegetation/Revegetation Map Appendix Page iii EXECUTIVE SUMMARY • • • As required by Colorado Division of Reclamation, Mining and Safety (CDRMS) regulations, coal mining operations must demonstrate that the vegetation established on reclaimed areas of coal mines support the approved post -mining land use and meet the approved success standard for vegetation cover prior to final Phase III bond release. This year's vegetation sampling represents the first of two years of sampling required prior to final liability and reclamation bond release for selected areas at the Coors Energy Company Keenesburg Mine. Quantitative vegetation sampling of 1985, 1986, 1987, 1995, and 1997 revegetation areas was conducted in August 2007. Vegetation cover, total herbaceous production, and species composition were sampled. Comparisons were made between total vegetation cover and total herbaceous production means from the reclamation areas and predicted values calculated from the approved equations based on on -site precipitation from September 2006 to July 2007. All sampled reclamation areas exceeded the predicted value of 36.45 percent total vegetation cover in this years sampling. All sampled reclamation areas exceeded the predicted total herbaceous production criterion of 165.33 grams/square meter. Species composition of the reclamation areas was also evaluated from a final success criterion perspective. Results from this year's vegetation sampling at the Keenesburg Mine revealed that the vegetation of the reclaimed areas exceeded the final species composition revegetation success for the mine. Further, the state of development of vegetation at the mine shows that the permittee has established a diverse, effective, and permanent vegetative cover of the same seasonal variety as the original vegetation. 1.0 INTRODUCTION This vegetation report represents the first of two vegetation sampling events prior to application for final Phase III bond and liability release for selected parcels at the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-1991-028) owned by Coors Energy Company. Information in this report addresses the vegetative condition of selected reclaimed areas eligible for Phase III bond release at the mine. The Colorado Division of Reclamation, Mining, and Safety (CDRMS) requires quantitative vegetation sampling and reporting as a demonstration of successful revegetation establishment prior to Phase III bond release. Quantitative information in this report addresses the vegetative condition of the 1985, 1986, and 1987 reclamation areas, and the 1995 and 1997 reclamation areas at the mine. Vegetation sampling was performed in compliance with Colorado Mined Land Reclamation Board Surface Coal Mining Rules 2.04.10 and 4.15 and current botanical and plant ecological methods. Field sampling was conducted between August 28 and 31, 2007 by Michael and Edith Savage of Savage and Savage, Inc. The Keenesburg Mine is located in Weld County, Colorado, approximately seven (7) miles north of Keenesburg, Colorado and is accessed by Weld County Road 59. Coors Energy Company operated the Keenesburg Mine for coal extraction from 1980 to 1988. Reclaimed areas sampled in 2007 were backfilled, graded, topsoiled and revegetated in accordance with Coors Energy Company Keenesburg Mine Page 4 2007 Phase III Vegetation Study the approved mining and reclamation plan. The revegetation standards used to evaluate these areas are those currently in effect under the Colorado Surface Coal Mining Reclamation Act (CRS 34-33-101 et seq) and the Keenesburg Mining and Reclamation Permit (C-81-028). 2.0 METHODS 2.1 SAMPLING DESIGN Discussions with revegetation specialists at CDRMS in February 2007 formalized the sampling design for the Phase III vegetation sampling at the Keenesburg Mine. Areas revegetated in 1985, 1986, and 1987 would be treated as one sampling unit as would areas revegetated in 1995 and 1997 as parcels within the sampling units were contiguous (or nearly so), received the same seed mixes and reclamation management. Prior to initiation of fieldwork, the permit document and applicable maps were reviewed to evaluate topography, reclamation timing, seed mixes, revegetation methods, management, and applicable revegetation standards. A map of the mine site at 1:2400 scale (1 "=200') was used to delineate the revegetated areas (Coors Site Plan; Vegetation Sampling Locations). On a gridded overlay of the revegetation map, a Cartesian coordinate grid (50x50 feet) was established. Computer generated random numbers were used to establish a pool of x,y coordinates. Since the reclaimed parcels for the years and areas to be evaluated were non-contiguous (e.g., separated by road corridors or reclamation years), each revegetated area was gridded separately. The acreage of each revegetated area was established. Random sample locations were established for each revegetated area. Within each year's revegetation parcels, sufficient samples were established to represent each area by proportional acreage. The following table identifies the location of each parcel quantitatively sampled, the acreage, and the number of cover and herbaceous production samples taken. Location Cover (# of samples) Herb. Prod. (# of samples) 1985, 1986, 1987 Reclamation Areas Area 4 (15.76 ac.) 3 4 Areas 11 (66.41 ac. total for 11, 12, & 13) 4 5 Area 12 4 4 Area 13 4 5 Area 17 (13.01 ac.) 2 3 Area 20 (16.57 ac. total for Areas 20 & 22) 2 3 Area 22 1 1 Total Samples 1985, 1986 & 1987 Areas 20 25 Coors Energy Company Keenesburg Mine 2007 Phase III Vegetation Study Page 5 Location Cover (# of samples) Herb. Prod. (# of samples) 1995 and 1997 Reclamation Areas Area 1 (7.4 ac.) 3 5 Area 3 (4.5 ac.) 1 2 Area 8 (8.1 ac.) 3 6 Area 14 (1.4 ac.) 1 1 Area 18 (8.6 ac.) 3 6 Area 21 (3.3 ac.) I 2 Area 24 (10.5 ac.) 4 6 Area 26 (5.6 ac.) 2 4 Area 27 (3.1 ac.) I 2 Area 28 (1.4 ac.) 1 1 Total Samples 20 35 Sample sites were located in the field through compass triangulation and pacing from known landmarks. Figure 1 illustrates the location of the reclaimed areas and sample point locations within each area sampled. The 1985, 1986, and 1987 areas were previously monitored (1994-1998) and after successfully meeting revegetation success criteria, were released from Phase II liability requirements by CDRMS August 11, 1998. The 1995 and 1997 areas were previously monitored (1998-2004) and after successfully meeting revegetation success standards a Phase II bond release was approved on June 15, 2006 by CDRMS. This year, as a precursor for application for Phase III bond release, the 1985, 1986, 1987, 1995 and 1997 areas were quantitatively sampled for vegetation cover, total herbaceous production, and species composition. 2.2 FIELD SAMPLING 2.2.1 Timing Field investigation was undertaken during the period August 28 through August 31, 2007. This time period coincided with anthesis and maximum development of the majority of plant species found in the reclaimed areas at the mine site to be evaluated. Total annual precipitation at the mine in calendar year 2007 was above normal, attributable in part to 4.47 inches of precipitation received in May thundershowers. While precipitation at the mine was 55 percent below average in September 2006, October and December 2006 precipitation was 154 and 814 percent above average, largely due to the heavy snow pack from the December blizzard. Precipitation from January to April 2007 fluctuated above and below the average, while heavy precipitation in May was 198 percent above average. June precipitation was significantly lower than average, with July 2007 amounts slightly above average. Cumulative precipitation between September 2006 and July 2007 was significantly greater than average with a 34.8 percent deviation above the average. Heavy precipitation late in 2006 provided soil moisture through the late winter while heavy precipitation in May encouraged significant growth in both the annual grass and forb components at the mine. Significant annual sunflower growth was apparent in August 2007, with the native range and reclamation areas visually dominated by the yellow flowers. Coors Energy Company Keenesburg Mine Page 6 2007 Phase III Vegetation Study 2.2.2 Vegetation Cover • • • Vegetation cover was estimated by the use of the point -intercept method. An ocular point frame (ESCO Associates) was used to minimize instrument error and maximize precision and observer accuracy. Cover transects were 25 meters in length, with two sample data points collected at 1.0 meter intervals along the transect on opposite sides of the transect centerline, 1.5m apart. Transect direction was established randomly through the use of computer generated random directions (0-360°). In no event were transects allowed to extend within ten feet of reference or revegetated area boundaries to minimize impacts from "edge effect." For statistical purposes, each cover transect (comprising 50 data points) served as a sample unit. Data points recorded the first vertical "hit" on vegetation (above or below the instrument), soil (bare ground), rock, litter, or cryptogamic crust. Subsequent "hits" on vegetation were also recorded. Cover data were recorded and reported by individual plant species. The first interception was used to calculate total vegetation cover values. Additional interceptions were used to calculate relative cover of individual plant species and lifeforms. The quantitative cover data also provided the basis for calculation of species composition and relative importance. 2.2.3 Herbaceous Production Herbaceous production was estimated by the harvest method. One herbaceous production plot was located and randomly oriented at the origin of each cover transect. Additional production plots were randomly located. Herbaceous production plots were 0.50 square meters in area. All current year above ground live herbaceous plant biomass was clipped within the 0.50 square meter quadrat. Production material was air dried until weights varied by no more than 0.1g. 2.2.4 Species Composition Species composition information was derived from quantitative vegetation cover data. Relative cover information provided a basis for evaluation of the importance of each encountered plant species and lifeform and for comparison to the final revegetation success criterion. The tables presenting data summaries for total vegetation cover for each area sampled also contain the relative cover by species, and a column depicting the numerical ranking of each species by relative cover within the area. 2.3 SAMPLE NUMBERS/SAMPLE ADEQUACY For the purposes of this study, total vegetation cover and total herbaceous production sampling were undertaken to sample adequacy for each sampling unit. Parameter testing occurred at the one-sided 90% confidence level. Comparisons between sample mean parameter values and the revegetation success standard assume that the sample mean value accurately represents the population mean in all cases. Coors Energy Company Keenesburg Mine Page 7 2007 Phase III Vegetation Study The following formula was used for sample adequacy calculations: • • • where: umin (02 (s)2 (d Xbar)2 nmin = minimum sample size s = sample standard deviation t = the Student's t distribution value at the 90% level (one-sided) d = percent acceptable deviation from the mean (10%) Xbar = sample mean 2.4 STATISTICAL ANALYSIS Statistical analysis for the revegetation success criterion of total vegetation cover is required if the value of the sample mean from the reclaimed area is less than 90 percent of the value of the final revegetation success criteria for total vegetation cover or total herbaceous production. Sampling revealed that the mean total vegetation cover for both of the sampling units was greater than that of the final revegetation cover success standard value, therefore no statistical analysis was required. Similarly, total herbaceous production means for the 1985/1986/1987 and 1995/1997 sampling units significantly exceeded the final herbaceous production criterion value, therefore no statistical analysis was necessary. 2.5 SPECIES IDENTIFICATION AND VERIFICATION Species identification was accomplished in the field through the use of plant identification keys (Harrington, 1954, Weber, 1990; Whitson, 1987; Zimdahl, 1990, Stubbendieck, et al, 1995). In cases where plant identification was inconclusive in the field, voucher specimens were pressed for lab identification. 3.0 RESULTS 3.1 QUANTITATIVE EVALUATION: RECLAMATION AREAS 3.1.1 1985, 1986, and 1987 RECLAMATION AREAS The 1985 reclamation areas encompass approximately 22 acres of reclaimed pit in the north central area of the Keenesburg Mine permit area. The 1985 reclamation area is composed of two parcels (Areas 13 and 22) separated by a north -south haul road corridor. This area is nearly flat with a gentle slope (<2°) to the north and east. Reclamation and coincident revegetation within this area took place in 1985. Replaced soils were sandy in texture. The revegetation seed mix differed slightly in composition and representation of cool season Coors Energy Company Keenesburg Mine Page 8 2007 Phase III Vegetation Study grasses from the seed mix applied to the 1986 and 1987 reclaimed areas, yielding a slightly different species composition. The 1986 reclamation areas encompass approximately 51 acres of reclaimed pit in the central area of the Keenesburg Mine permit area. The 1986 reclamation area is composed of three parcels (Areas 4, 12, and 20) separated by north -south haul road corridors (Areas 3 and 19). The area is nearly flat with a gentle slope (<1°) to the north and east. Reclamation and coincident revegetation within this area took place in 1986. Replaced soils were sandy in texture. The 1987 reclamation areas encompass approximately 39 acres of reclaimed pit and adjacent areas in the south central area of the Keenesburg Mine permit area. The 1987 reclamation area is composed of two parcels (Areas 11 and 17) separated by a north -south haul road corridor and three narrow reclamation parcels (Areas 9, 10, and 16). The entire 1987 reclamation area is nearly flat with a gentle slope (<1°) to the south and east. Reclamation and subsequent revegetation within this area took place in 1987. Replaced soils were generally sandy in texture. Specific sampling information for the 1985, 1986, and 1987 reclamation areas is contained in Tables 1, 2, and 4. 3.1.1.1 Vegetation Cover Total vegetation cover of the 1985, 1986, and 1987 reclamation areas was 60.80 percent. Graminoids provided 39.80 percent mean cover (67.60% relative cover) and forbs accounted for 18.20 percent mean cover (26.10% relative cover). Succulents and shrubs each accounted for 1.40 percent total cover (2.81 and 3.48% relative cover, respectively). The lowest total vegetation cover of the parcels sampled was found in Area 4 (42%) and the highest cover (74%) was found in Area 11. No single species was encountered in all the cover transects, though Calamovilfa longifolia (prairie sandreed) was encountered in 90 percent of the transects, Bromus marginatus (mountain brome), Helianthus annuus (sunflower), and Kochia scoparia (kochia) in 85 percent of all transects, Bouteloua gracilis (blue grama) was found in 80 percent of all transects, and Andropogon hallii (sand bluestem) and Sporobolus cryptandrus (sand dropseed) were present in 70 percent of all cover transects. Calamovilfa longifolia, a warm season native prairie grass, accounted for the highest overall vegetation cover with 13.30 percent mean cover and 24.10 percent relative cover in the 1985, 1986, and 1987 reclamation areas. Eight additional species contributed significantly to vegetation cover (greater than 3% relative cover); the cool season native perennial grass Bromus marginatus with 10.20 percent mean cover and 15.53 percent relative cover, the native warm season annual forb Helianthus annuus contributed 9.70 percent mean cover (14.06% relative cover), the warm season native Bouteloua gracilis provided 5.00 percent total vegetation cover and 9.37 percent relative cover, warm season native graminoid Andropogon hallii accounted for 4.40 percent mean cover (7.50% relative cover), Kochia scoparia, the introduced annual forb, contributed 5.00 percent total cover (6.83% relative cover), the warm season native grass Sporobolus cryptandrus provided 2.50 percent mean total cover (3.88 percent relative cover), the native shrub Artemisia filifolia (sand sage) Coors Energy Company Keeneshurg Mine Page 9 2007 Phase III Vegetation Study contributed 1.40 percent mean and 3.48 percent relative cover, and Agropyron smithii (western wheatgrass), the cool season native graminoid, accounted for 1.80 percent mean cover (3.35% relative cover). Vegetative litter (prior years growth, dead wood, and other biologic organic material) comprised 27.10 percent ground cover overall within the 1985, 1986, and 1987 reclamation areas. Bare soil comprised 12.10 percent of the ground cover. No rock or cryptogams were encountered during the cover sampling in the reclamation areas. 3.1.1.2 Herbaceous Production Total herbaceous production within the 1985, 1986, and 1987 reclamation areas (Table 4) was 239.46 g/m2 (2134 lb/ac). 3.1.1.3 Species Composition Cover sampling identified four lifeforms and twenty-two species within the 1985, 1986, and 1987 reclamation areas. The lifeforms included ten species of perennial grass, one annual grass, three perennial forbs, five annual forbs, two succulents, and one shrub. Of the species encountered on the 1985, 1986, and 1987 reclamation areas, sixteen were native and six were introduced. Perennial species outnumbered annual species by sixteen to six. Both warm and cool season species contributed to the seasonality of the 1985, 1986, and 1987 reclamation areas. Warm season graminoids outnumbered cool season graminoids by six to five. Cool season forbs prevailed by six to two. The two succulents were evergreen and the shrub was deciduous. The 1985, 1986, and 1987 reclamation areas had nine species contributing greater than three percent relative cover this year. The species contributing greater than three percent relative cover included six perennial grasses, two annual forbs, and one perennial shrub. These species included Calamovilfa longifolia (24.10 percent relative cover), Bromus marginatus (15.53%), Helianthus annuus (14.06%), Bouteloua gracilis (9.37%), Andropogon hallii (7.50%), Kochia scoparia (6.83%), Sporobolus cryptandrus (3.88%), Artemisia falifolia (3.48%), and Agropyron smithii (3.35%). 3.1.2 1995 AND 1997 RECLAMATION AREAS The 1995 reclamation areas encompass a total of approximately 36 acres of reclamation in six distinct areas within the Keenesburg Mine permit area. The areas are found throughout the disturbance area of the mine and include; Area 1 (the former tipple area north of the shop building), Area 8 comprising the east third of A pit, Area 24 (a road corridor from the northwest corner of the long term spoil storage area to the northwest boundary of the permit area), Area 26 (located south of the sediment pond), Area 27 (an area between the sediment pond and the 1985 reclamation area which was used for spoil storage), and Area 28, an area west of the sediment pond. The 1995 reclamation areas are nearly flat with a gentle slope (<1°) to the north and east. Coors Energy Company Keenesburg Mine Page 10 2007 Phase III Vegetation Study The 1997 reclamation areas sampled encompass approximately 18 acres of reclamation in four distinct areas within the Keenesburg Mine permit area. The areas are found throughout the disturbance area of the mine and include Area 3 that is a road corridor between the 1985/1986 central reclamation areas and the 1986 east area, Area 14 (an area to the west of A pit), and Areas 18 and 21, two areas adjacent to B pit. The 1997 reclamation areas are nearly flat overall with a gentle slope (1-3°) to the north. Reclamation and coincident revegetation with the permanent seed mix took place during the autumn of 1997 within these areas. Replaced soils were sandy in texture. Specific sampling information for the 1995 and 1997 reclamation areas is contained in Tables 1,3,and 5. 3.1.2.1 Vegetation Cover Total vegetation cover of the 1995 and 1997 reclamation areas was 61.40 percent (Table 3). Graminoids provided 46.30 percent mean cover (77.62% relative cover), forbs accounted for 13.90 percent mean cover (19.60% relative cover), succulents provided 0.20 percent mean cover and 0.40 percent relative cover, while one shrub contributed 1.00 percent mean and 2.38 percent relative cover. The lowest total vegetation cover of the 1995 and 1997 reclamation areas sampled was found in Area 1 (44%) and the highest was in Area 3 (74%). No single species was encountered in all the cover transects, though Sporobolus cryptandrus was encountered in 95 percent of the transects. Calamovilfa longifolia was present in 85 percent of all transects and Bouteloua gracilis was found in 80 percent of all transects. Bromus marginatus accounted for the highest overall vegetation cover in the 1995 and 1997 reclamation areas with 12.30 percent mean cover and 17.35 percent relative cover. Nine additional species contributed significantly to vegetation cover (greater than 3% relative cover); Sporobolus cryptandrus with 7.80 percent mean cover and 12.98 percent relative cover, Bouteloua gracilis contributed 5.40 percent mean cover (11.66% relative cover), Calamovilfa longifolia provided 6.00 percent total vegetation cover and 9.27 percent relative cover, Helianthus annuus accounted for 6.30 percent mean cover (8.87% relative cover), Agropyron smithii contributed 4.40 percent total cover (7.68% relative cover), Bouteloua curtipendula (sideoats grama) provided 2.50 percent mean total cover (5.43 percent relative cover), Ambrosia psilostachya (ragweed) contributed 2.60 percent mean and 3.84 percent relative cover, Bromus tectorum (cheatgrass), a cool season introduced graminoid, accounted for 2.70 percent mean cover (3.58% relative cover), and Andropogon hallii contributed 1.60 percent mean total cover and 3.18 percent relative cover. Vegetative litter (prior years growth, dead wood, and other biologic organic material) comprised 21.30 percent ground cover overall within the 1995 and 1997 reclamation areas. Bare soil comprised 17.30 percent of the ground cover. No rock or cryptogams were encountered during the cover sampling in the 1995 and 1997 reclamation areas. 3.1.2.2 Herbaceous Production Overall mean total herbaceous production within the 1995 and 1997 reclamation areas was 229.27 g/m2 (2043 lb/ac). Coors Energy Company Keenesburg Mine Page 11 2007 Phase 111 Vegetation Study 3.1.2.3 Species Composition Cover sampling identified four lifeforms and 30 species within the 1995 and 1997 reclamation areas. The lifeforms included fourteen species of perennial graminoids, one annual grass, four perennial forbs, one biennial forb, seven annual forbs, two succulents, and one shrub. Of the species encountered on the 1995 and 1997 reclamation areas, eighteen were native and twelve were introduced. Perennial species outnumbered annual species by twenty-one to eight, with one biennial species. Cool season graminoid and forb species were more prevalent than warm season species (17 cool season to 10 warm season) in the 1995 and 1997 reclamation areas. Warm season graminoid species accounted for eight species and cool season species included seven species. Ten forb species were identified as cool season and two were warm season. The succulents were evergreen and the shrub deciduous. The 1995 and 1997 reclamation areas had ten species contributing greater than three percent relative cover this year. These species included Bromus marginatus 17.35 percent relative cover, Sporobolus cryptandrus (12.98%), Bouteloua gracilis (11.66%), Calamovilfa longifolia (9.27%), Helianthus annuus (8.87%), Agropyron smithii (7.68%), Bouteloua curtipendula (5.43%), Ambrosia psilostachya (3.84%), Bromus tectorum (3.58%), and Andropogon hallii (3.18%). 3.3 COMPARISON OF RECLAMATION AREAS WITH FINAL REVEGETATION SUCCESS CRITERIA Comparison of the reclaimed area values for vegetation cover, herbaceous production, and species composition with the final revegetation success criteria, indicates whether revegetation has been successful, or whether additional measures need to be initiated to enhance vegetation community development. The tables below allow the comparison of the parameter values with the standard to be achieved, either from the predictive equations in the case of total vegetation cover (y=0.0173x3-0.8592x2+14.562x-47.015) and total herbaceous production (y=0.3749x2,2485) or the established standard for species composition. Total Vegetation Cover (2007) Predictive Equation Value for 2007: 36.45% total vegetation cover (based on 15.00" precipitation value) 1985/1986/1987 Rec. Areas 1995/1997 Rec. Areas Xbar S N Nmin 60.80 % 7.40 20 4 61.40 % 8.20 20 5 Based on the results of the 2007 quantitative sampling, the 1985, 1986, and 1987 reclamation areas and 1995 and 1997 reclamation areas significantly exceeded the predicted total cover vegetation value of 36.45 percent, meeting the final revegetation success criterion for vegetation cover. Coors Energy Company Keenesburg Mine Page 12 2007 Phase III Vegetation Study Total Herbaceous Production (2007) Predictive Equation Value for 2007: 165.33 g/m2 total herbaceous production (based on 15.00" precipitation value) 1985/1986/1987 Rec. Areas 1995/1997 Rec. Areas Xbar S N Nmin 239.46 g/m2 57.21 25 10 229.27 g/m2 59.10 35 11 With regard to total herbaceous production, the 1985, 1986, and 1987 reclamation areas and 1995 and 1997 reclamation areas significantly exceeded the predicted value for total herbaceous production thereby meeting the final revegetation success criterion. Species Composition (2007) Success Standard 1985/1986/1987 Rec. Areas 1995/1997 Rec. Areas Total Perennial Species* Warm Season Grasses* Cool Season Grasses* Relative Importance (3%<x<40%) 4 3 All Species 7 3 3 All Species 8 4 3 All Species * Numbers reflect only those species meeting the relative importance percentage limitation Both the 1985, 1986, and 1987 reclamation areas and the 1995 and 1997 reclamation areas satisfied the final species composition revegetation criteria. In the 1985, 1986, and 1987 reclamation areas, the seven perennial species were; Calamovilfa longifolia with 24.10 percent relative cover, Bromus marginatus (15.53% relative cover), Bouteloua gracilis (9.37% relative cover), Andropogon hallii (7.50% relative cover), Sporobolus cryptandrus (3.88% relative cover), Artemisia flifolia (3.48% relative cover), and Agropyron smithii (3.35% relative cover). Of these species, Calamovilfa longifolia, Bouteloua gracilis, and Andropogon hallii are qualifying warm season graminoids and Bromus marginatus, Sporobolus cryptandrus, and Agropyron smithii are qualifying cool season graminoids. In the 1995 and 1997 reclamation areas, the eight qualifying perennial species were; Bromus marginatus with 17.35 percent relative cover, Sporobolus cryptandrus (12.98% relative cover), Bouteloua gracilis (11.66% relative cover, Calamovilfa longifolia (9.27% relative cover), Agropyron smithii (7.68% relative cover), Bouteloua curtipendula (5.43% relative cover), Ambrosia psilostachya (3.84% relative cover), and Andropogon hallii (3.18% relative cover). Coors Energy Company Keenesburg Mine Page 13 2007 Phase Ill Vegetation Study Of these species, Bouteloua gracilis, Calamovilfa longifolia, Bouteloua curtipendula, and Andropogon hallii are qualifying warm season graminoids and Bromus marginatus, Sporobolus cryptandrus, and Agropyron smithii are qualifying cool season graminoids. 4.0 DISCUSSION AND CONCLUSIONS 4.1 VEGETATION COVER Both the 1985, 1986, and 1987 reclamation areas and the 1995 and 1997 reclamation areas exceeded the final revegetation success criterion value (36.45%) for total vegetation cover. The 1985, 1986, and 1987 reclamation areas had a mean total vegetation cover of 60.80 percent and the 1995 and 1997 reclamation areas had a mean total vegetation cover of 61.40 percent. The first year of quantitative vegetation cover sampling for Phase III bond and liability release reveals that the requirement for vegetation cover has been met. 4.2 HERBACEOUS PRODUCTION The 1985, 1986, and 1987 reclamation areas and the 1995 and 1997 reclamation areas exceeded the final revegetation success criterion value (165.33 g/m2) for total herbaceous production. The 1985, 1986, and 1987 reclamation areas had a mean total herbaceous production of 239.46 g/m2 and the 1995 and 1997 reclamation areas had a mean total herbaceous production of 229.27 g/m2. The first year of quantitative vegetation cover sampling for Phase III bond and liability release reveals that the requirement for total herbaceous production has been met. 4.3 SPECIES COMPOSITION The species composition standard requires that there be at least four perennial species, of which three are warm season grasses and one a cool season grass. No one component of the above four species should comprise greater than 40% relative importance nor less than 3% relative importance. Relative importance will be measured by calculating relative cover of the revegetation species. Vegetation species which may be used in the calculation of species composition may be any plant species not defined as a noxious or prohibited plant species, and may be native or introduced. Both the 1985, 1986, and 1987 reclamation areas and the 1995 and 1997 reclamation areas satisfied the final species composition revegetation criteria. The 1985, 1986, and 1987 reclamation areas had seven qualifying perennial species, three qualifying warm season graminoids and three qualifying cool season graminoids. The 1995 and 1997 reclamation areas had eight qualifying perennial species, four qualifying warm season graminoids and three qualifying cool season graminoids. The first year of quantitative vegetation cover sampling for Phase III bond and liability release reveals that the reclamation areas have exceeded the final revegetation success requirements for species composition. Coors Energy Company Keenesburg Mine Page 14 2007 Phase III Vegetation Study 5.0 SUMMARY The quantitative vegetative cover and species composition data indicate that the permittee has established a diverse, effective, and permanent vegetative cover of the same seasonal variety as the original vegetation. The revegetated area is capable of self -regeneration and plant succession. The data shows development of a stable, self-sustaining vegetation community, with seasonality and diversity sufficient to demonstrate successful reestablishment of vegetation on the reclaimed area. Coors Energy Company Keenesburg Mine Page 15 2007 Phase III Vegetation Study 6.0 LITERATURE CITED Harrington, H.D. 1954 Manual of the Plants of Colorado. Sage Books. Denver Stubbendieck, J., G.Y. Friisoe, and M.R. Bolick. 1995. Weeds of Nebraska and the Great Plains. Nebraska Department of Agriculture. Weber, William A. 1990. Colorado Flora: Eastern Slope. University of Colorado Press Whitson, Tom D. Editor. 1987. Weeds and Poisonous Plants of Wyoming and Utah. Cooperative Extension Service, College of Agriculture, The University of Wyoming Zimdahl, Robert L. 1990. Weeds of Colorado. Cooperative Extension, Colorado State University Bulletin 521A Coors Energy Company Keenesburg Mine Page 16 2007 Phase III Vegetation Study 7.0 TABLES Coors Energy Company Keenesburg Mine Page 17 2007 Phase III Vegetation Study Table 1. 2007 Plant Species List: Keenesburg Mine 1985, 1986, 1987, 1995 and 1997 Reclamation Areas Species Name Common Name Lifeform 1985/1986/1987 1995/1997 Areas Areas Graminoids Agropyron cristatum Crested Wheatgrass P,C,I X X Agropyron intermedium Intermediate Wheatgrass P,C,I X Agropyron smithii Western Wheatgrass P,C,N X X Andropogon gerardii Andropogon hallii Big Bluestem P,W,N X Sand Bluestem P,W,N X X Bouteloua curtipendula Sideoats Grama P,W,N Bouteloua gracilis Blue Grama P,W,N Bromus marginatus Mountain Brome P,C,N Bromus tectorum Cheatgrass A,C,1 Calamovilfa longifolia Prairie Sandreed P,W,N Oryzopsis hymenoides Indian Ricegrass P,C,N X Panicum virgatum Switchgrass P,W,N Poa compresses Canada Bluegrass Schizachyrium scoparium Little Bluestem P,C,I X P,W,N Sporobolus cryptandrus Sand Dropseed P,W,N Total Number of Grasses Total Number Perennial Grasses Total Number Annual Grasses Total Number Native Grasses Total Number Introduced Grasses Total Number Cool Season Grasses Total Number Warm Season Grasses Coors Energy Company Keenesburg Mine 2007 Phase III Vegetation Study 11 10 1 9 2 5 6 15 14 1 11 4 7 8 Page 18 Table 1. 2007 Plant Species List: Keenesburg Mine 1985, 1986, 1987, 1995 and 1997 Reclamation Areas continued Species Name Common Name Lifeform 1985/1986/1987 1995/1997 Areas Areas Forbs Ambrosia psilostachya Ragweed Argemone polyacantha Prickly Poppy Chenopodium album Lambsquarters Eriogonum annuum Buckwheat Helianthus annuus Sunflower P,C,N P,W,N A,C,I A,C,N X X X X X X A,W,N Kochia scoparia Kochia A,C,I Lactuca serriola Prickly Lettuce A,C,I X Lepidium densorum Pepperweed Medicago lupulina Black Medic Medicago sativa Alfalfa Melilotus officinally A,C,I A,C,I P,C,I X X X Yellow Sweetclover B,C,I Nuttallia nuda Blazing Star P,W,N X X Psoralidium tennuorum Psoralidium P,C,N X Sisymbrium altissimum Tumble Mustard Tragopogon dubius Salsify A,C,I P,C,I X Total Number of Forbs Total Number Perennial Forbs Total Number Biennial Forbs Total Number Annual Forbs Total Number Native Forbs Total Number Introduced Forbs Total Number Cool Season Forbs Total Number Warm Season Forbs Succulents 8 3 12 4 0 1 5 4 4 6 2 7 4 8 10 2 Opuntia polyacantha Prickly Pear Yucca glauca Yucca Total Number of Succulents P,E,N P,E,N 2 2 Shrubs Artemisia filifblia Sand Sage P,D,N Total Number of Shrubs TOTAL NUMBER OF SPECIES Lifeform abbreviations: A annual C cool season B biennial W warm season P perennial D deciduous E evergreen Note: Only plant species encountered during cover sampling are represented on this list 22 30 N native I introduced L legume Coors Energy Company Keenesburg Mine Page 19 2OO7 Phase III Vegetation Study Transect Location Table 2. Vegetation Cover: 1985, 1986, and 1987 Reclamation Areas (2007) O' �'W 1O IIN,O• N,.O O�CO O li W L y E m N o N ph " v ¢` w r N N Q en Cr m N N O a) Q P co G U; O M ki Q ry O'V rM b.mo N' — r 0 m' 0 ,ro'M an � .Mly v r' t m 0 m r 0''0\! N H. O ',O m O O— M O N b W M r 0 e o o O o M 4 en O.O IIIO 0I,O O O O - NIr O m oie VI -10 0,N O 10 or N cc n Id c 0 N d 4 b.� e N' b N C I N N b O i0 N tile? c IIm IN N N R N HI It O SIN. b O O < 00 01 NI " N N N ON N I b N'I 00 ^I N CI E E E U E z b b N N CC N b b.i b1 Ia N N N 00 N N CIINI N NIN, 00 b b e0 M N W N N NIW NIB N IN C c N 00; I N N 0 N O N N O C I I,N I00 bI M L43.4 N. Oi 'O 0 O 00 d o O O O O N O v a m m E a a E 8 a E EL a "°I i01. J.V my 9 O �I3 y _ o m 0 m Ai!" 9 I O t V• A m m mIF v v =,�,Thn tlI al i m Q C ['I y w ~I ≥ E r m F0I tl ££ Z' U a s e T¢Co,o v ='E oo''.o E C7 ¢ 0 e w0 IW m C.c!c% c0 V a C6 m tto u E c s E 3. `o l 6 ' Ot. O L+ Q U o e 'eo $ _Oa_ LoI£ (tO. 'LH-7 m'.n re. k en C, 1 L> 0 o co 0 N N II > C CE z D O O 00 0 00 0 N _ O O N O D N O MN O N - 0 0e00 O O ry - 0 ry 000 O N O N N o 0 00 N 0 're, 0 0 O W O O O m 0 0 0 O N O N d m O 5 m L T 3 tr.:111 a 0 a C N e COO a 12 4.5 a c N u N 4) a.m a E > 0 a O E e T y o u° S L. A o m L' v_ L c o W �. V m a Z L O °p 0 ON • • Table 3. Vegetation Cover: 1995 and 1997 Reclamation Areas (2007) • U = N cs PIV ) 'tIv .IM IP en_ Plc; VI�W P O e rt.' 1, OW (V O ; P O a O o O Ni [V OQ E,4;Ric.IIW° 10O0lO - coo O 1r Q 000 .-. - -t rv,Et HZ 01 VD GO CO -In!,a ro NGOrve of` NJ e e r2 rve eV VD oo e Species Name W 9 LIE n' °II m, E Ie2OU m 3 4, © E.me ° m c,08 , m a a o, A v o eO —1 a'... Is II 3'I S = V c, - r m V) v) c1i ci 5. 10 -D I I all f ?It e all ow p? 9 y O K.GO O 2 °;.t @ q ,b ` ` °G. CJC'. a ¢ o o Ce Cop -3l R ¢ly rL fL mroid o a 0 $Ic 3 ' 3 l` • al • n o. � a - c.5 p C e a c,- ¢ a wl Ia O 1.0 00 e 00 0.1 0000 0000 e e rvr� C. 0 0 ,,� 00 0 000 0,° o 0 CD 0 0 GO r, 0000 NN a a d r N 4)css c m _a .a a N y� E01 Y 71 c 4 C0 111 Cri C O 1 To z N A c d w g_ O O O• O N • • • Herbaceous Production: Keenesburg Mine 1985, 1986, and 1987 Reclamation Areas (2007) PC Area Number N v .M. N O 00 N r V N Q b In N E a N 00 N v N V M 7 M N N O N Pt N Pt N N 7 00 N N V 0 Cl N_ N 1/40 N oo N Herbaceous Production N 22 25 mean 247.2 1239.46 N N O N et en a) N N N N N m N M a) d L Q O1/4 00 00 r; M 00 Do 00 N N N N en en N oc N P 7 b 1/40 O M N N W O M N C en N Herbaceous Production N O r In I, I� Q. E Z b rip note: all data presented in grams per square meter • • • Table 5. Herbaceous Production: Keenesburg Mine 1995 and 1997 Reclamation Areas (2007) Area Number 00 — M N P 00 In R es aa> M N N N N N N 00 345.6 215.4 C N p v OA E N In 00 p II IL a w E - Q Z N z NN M N N N R I- L Q 0 N N M N M M O M Cr, N 00 N N 'C N N R a) L Q V7 N N N M en M N o N. N N N N R N 00 Q ut N 7 0 'A m o In N v O M C' Q 209.0 222.2 240.4 217.4 O 00 b 00 N 274.4 210.2 218.4 N O a' 357.4 325.0 O N N CO N N note: all data presented in grams per square meter m N 0 6 01 t N Y;is C R R t b I, E > U = m O (13 C W N L 01- o N U N 8.0 APPENDIX Coors Energy Company Keenesburg Mine Page 24 2007 Phase III Vegetation Study LARGE MAPS AVAILABLE FOR VIEWING AT THE CLERK TO THE BOARD'S OFFICE, IN THE PUBLIC REVIEW FILE. • • • 2008 Quantitative Vegetation Study Phase III Bond Release [Year 2] Coors Energy Company Keenesburg Mine Keenesburg, Colorado November 2008 Prepared by: Savage and Savage, Inc. 4610 Haystack Drive Windsor, Colorado 80550 970.674.8080 TABLE OF CONTENTS EXECUTIVE SUMMARY 1.0 INTRODUCTION 2.0 METHODS 2.1 Sampling Design 2.2 Field Sampling 2.2.1 Timing 2.2.2 Vegetation Cover 2.2.3 Herbaceous Production 2.2.4 Species Composition 2.3 Sample Numbers/Sample Adequacy 2.4 Statistical Analysis 2.5 Species Identification and Verification 3.0 RESULTS 3.1 Quantitative Evaluation: Reclamation Areas 3.1.1 1985, 1986, and 1987 Reclamation Areas 3.1.1.1 Vegetation Cover 3.1.1.2 Herbaceous Production 3.1.1.3 Species Composition 3.1.2 1995 and 1997 Reclamation Areas 3.1.2.1 Vegetation Cover 3.1.2.2 Herbaceous Production 3.1.2.3 Species Composition 3.3 Comparison of Reclamation Areas with Final Revegetation Success Criteria Page 4. 4. 5. 5. 6. 6. 7. 7. 7. 7. 8. 8. 8. 8. 8. 9. 10. 10. 10. 11. 11. 12. 12. 4.0 DISCUSSION AND CONCLUSIONS 14. 4.1 Vegetation Cover 14. 4.2 Herbaceous Production 14. 4.3 Species Composition 14. 5.0 SUMMARY 14. 6.0 LITERATURE CITED 16. 7.0 TABLES 17. 8.0 APPENDIX 24. Page ii LIST OF TABLES Page 2008 Plant Species List: Keenesburg Mine 1985, 1986, 1987, 1995 and 1 18. 1997 Reclamation Areas 2. Vegetation Cover: 1985, 1986, and 1987 Reclamation Areas (2008) 20. 3. Vegetation Cover: 1995 and 1997 Reclamation Areas (2008) 21. Herbaceous Production: Keenesburg Mine 1985, 1986, and 1987 4' 22. Reclamation Areas (2008) Herbaceous Production: Keenesburg Mine 1995 and 1997 5' 23. Reclamation Areas (2008) APPENDIX Page 2008 Coors Energy Company Vegetation/Revegetation Map Appendix Page iii EXECUTIVE SUMMARY • • • As required by Colorado Division of Reclamation, Mining and Safety (CDRMS) regulations, coal mining operations must demonstrate that the vegetation established on reclaimed areas of coal mines support the approved post -mining land use and meet the approved success standard for vegetation cover prior to final Phase III bond release. This year's vegetation sampling represents the second of two years of sampling required prior to final liability and reclamation bond release for selected areas at the Coors Energy Company Keenesburg Mine. Quantitative vegetation sampling of 1985, 1986, 1987, 1995, and 1997 revegetation areas was conducted in September and October 2008. Vegetation cover, total herbaceous production, and species composition were sampled. Comparisons were made between total vegetation cover and total herbaceous production means from the reclamation areas and predicted values calculated from the approved equations based on on -site precipitation from September 2007 to July 2008. All sampled reclamation areas exceeded the predicted value of 23.13 percent total vegetation cover in this years sampling. All sampled reclamation areas exceeded the predicted total herbaceous production criterion of 39.66 grams/square meter. Species composition of the reclamation areas was also evaluated from a final success criterion perspective. Results from this year's vegetation sampling at the Keenesburg Mine revealed that the vegetation of the reclaimed areas exceeded the final species composition revegetation success for the mine. Further, the state of development of vegetation at the mine shows that the permittee has established a diverse, effective, and permanent vegetative cover of the same seasonal variety as the original vegetation, meeting the final success criterion for species composition. 1.0 INTRODUCTION This vegetation report represents the second of two vegetation sampling events prior to application for final Phase III bond and liability release for selected parcels at the Keenesburg Mine (Colorado Division of Reclamation, Mining, and Safety permit C-1991-028) owned by Coors Energy Company. Information in this report addresses the vegetative condition of selected reclaimed areas eligible for Phase III bond release at the mine. The Colorado Division of Reclamation, Mining, and Safety (CDRMS) requires quantitative vegetation sampling and reporting as a demonstration of successful revegetation establishment prior to Phase III bond release. Quantitative information in this report addresses the vegetative condition of the 1985, 1986, and 1987 reclamation areas, and the 1995 and 1997 reclamation areas at the mine. Vegetation sampling was performed in compliance with Colorado Mined Land Reclamation Board Surface Coal Mining Rules 2.04.10 and 4.15 and current botanical and plant ecological methods. Field sampling was conducted between September 25 and October 1, 2008 by Michael and Edith Savage of Savage and Savage, Inc. The Keenesburg Mine is located in Weld County, Colorado, approximately seven (7) miles north of Keenesburg, Colorado and is accessed by Weld County Road 59. Coors Energy Company operated the Keenesburg Mine for coal extraction from 1980 to 1988. Reclaimed Coors Energy Company Keenesburg Mine Page 4 2008 Phase III Vegetation Study areas sampled in 2008 were backfilled, graded, topsoiled and revegetated in accordance with the approved mining and reclamation plan. The revegetation standards used to evaluate these areas are those currently in effect under the Colorado Surface Coal Mining Reclamation Act (CRS 34-33-101 et seq) and the Keenesburg Mining and Reclamation Permit (C-81-028). 2.0 METHODS 2.1 SAMPLING DESIGN Discussions with revegetation specialists at CDRMS in February 2007 formalized the sampling design for the Phase III vegetation sampling at the Keenesburg Mine. Areas revegetated in 1985, 1986, and 1987 would be treated as one sampling unit as would areas revegetated in 1995 and 1997 as parcels within the sampling units were contiguous (or nearly so), received the same seed mixes and reclamation management. Prior to initiation of fieldwork, the permit document and applicable maps were reviewed to evaluate topography, reclamation timing, seed mixes, revegetation methods, management, and applicable revegetation standards. A map of the mine site at 1:2400 scale (1 "=200') was used to delineate the revegetated areas (Coors Site Plan; Vegetation Sampling Locations). On a gridded overlay of the revegetation map, a Cartesian coordinate grid (50x50 feet) was established. Computer generated random numbers were used to establish a pool of x,y coordinates. Since the reclaimed parcels for the years and areas to be evaluated were non-contiguous (e.g., separated by road corridors or reclamation years), each revegetated area was gridded separately. The acreage of each revegetated area was established. Random sample locations were established for each revegetated area. Within each year's revegetation parcels, sufficient samples were established to represent each area by proportional acreage. The following table identifies the location of each parcel quantitatively sampled, the acreage, and the number of cover and herbaceous production samples taken. Location Cover (# of samples) Herb. Prod. (# of samples) 1985, 1986, 1987 Reclamation Areas Area 4 (15.76 ac.) 2 2 Areas I1 (66.41 ac. total for I I, 12, & 13) 3 3 Area 12 3 3 Area 13 3 3 Area 17 (13.01 ac.) 2 2 Area 20 (16.57 ac. total for Areas 20 & 22) 1 1 Area 22 1 1 Total Samples 1985, 1986 & 1987 Areas 15 r 15 Coors Energy Company Keenesburg Mine 2008 Phase III Vegetation Study Page 5 Location Cover (# of samples) Herb. Prod. (# of samples) 1995 and 1997 Reclamation Areas Area I (7.4 ac.) 2 4 Area 3 (4.5 ac.) I 2 Area 8 (8.1 ac.) 2 4 Area 14 (1.4 ac.) 0 1 Area 18 (8.6 ac.) 2 4 Area 21 (3.3 ac.) 1 2 Area 24 (10.5 ac.) 3 4 Area 26 (5.6 ac.) 2 2 Area 27 (3.1 ac.) 1 1 Area 28 (1.4 ac.) 1 1 Total Samples fl 15 25 Sample sites were located in the field through compass triangulation and pacing from known landmarks. Figure 1 illustrates the location of the reclaimed areas and sample point locations within each area sampled. The 1985, 1986, and 1987 areas were previously monitored (1994-1998) and after successfully meeting revegetation success criteria, were released from Phase II liability requirements by CDRMS on August 11, 1998. The 1995 and 1997 areas were previously monitored (1998-2004) and after successfully meeting revegetation success standards, a Phase II bond release was approved on June 15, 2006 by CDRMS. As a precursor for application for Phase Ill bond release, the 1985, 1986, 1987, 1995 and 1997 areas were quantitatively sampled for vegetation cover, total herbaceous production, and species composition as the second year of the required two years of quantitative sampling prior to seeking final bond release. 2.2 FIELD SAMPLING 2.2.1 Timing Field investigation was undertaken during the period September 25 through October 1, 2008. This time period coincided with anthesis and maximum development of the majority of plant species found in the reclaimed areas at the mine site to be evaluated. Total annual precipitation at the mine in calendar year 2008 was far below normal, totaling only 5.47 inches of precipitation (January to July 2008). All months in 2008 showed significantly less precipitation than normal. Of the months used to assess growing season precipitation, only September and December 2007 had precipitation levels above average (150% and 129% respectively), due to early autumn rains and heavy December snow pack. Precipitation from January to July 2008 ranged from two percent (June 2008) to 100 percent (January 2008) below average. Cumulative precipitation between September 2007 and July 2008 was significantly less than average with a 27.2 percent deviation below the September -July average, and 56.4 percent below the annual precipitation average. Heavy precipitation late in September and December 2007 did not provide adequate soil moisture through the late winter and into the 2008 growing season resulting in significantly lower growth from May through early August 2008. Coors Energy Company Keenesburg Mine Page 6 2008 Phase III Vegetation Study During early to mid -August 2008, significant thundershowers provided adequate soil moisture to promote growth in the warm season vegetation component in the reclaimed and native plant communities. 2.2.2 Vegetation Cover Vegetation cover was estimated by the use of the point -intercept method. An ocular point frame (ESCO Associates) was used to minimize instrument error and maximize precision and observer accuracy. Cover transects were 25 meters in length, with two sample data points collected at 1.0 meter intervals along the transect on opposite sides of the transect centerline, 1.5m apart. Transect direction was established randomly through the use of computer generated random directions (0-360°). In no event were transects allowed to extend within ten feet of reference or revegetated area boundaries to minimize impacts from "edge effect." For statistical purposes, each cover transect (comprising 50 data points) served as a sample unit. Data points recorded the first vertical "hit" on vegetation (above or below the instrument), soil (bare ground), rock, litter, or cryptogamic crust. Subsequent "hits" on vegetation were also recorded. Cover data were recorded and reported by individual plant species. The first interception was used to calculate total vegetation cover values. Additional interceptions were used to calculate relative cover of individual plant species and lifeforms. The quantitative cover data also provided the basis for calculation of species composition and relative importance. 2.2.3 Herbaceous Production Herbaceous production was estimated by the harvest method. One herbaceous production plot was located and randomly oriented at the origin of each cover transect. Additional production plots were randomly located. Herbaceous production plots were 0.50 square meters in area. All current year above ground live herbaceous plant biomass was clipped within the 0.50 square meter quadrat. Production material was air dried until weights varied by no more than 0.1g. 2.2.4 Species Composition Species composition information was derived from quantitative vegetation cover data. Relative cover information provided a basis for evaluation of the importance of each encountered plant species and lifeform and for comparison to the final revegetation success criterion. The tables presenting data summaries for total vegetation cover for each area sampled also contain the relative cover by species, and a column depicting the numerical ranking of each species by relative cover within the area. 2.3 SAMPLE NUMBERS/SAMPLE ADEQUACY For the purposes of this study, total vegetation cover and total herbaceous production sampling were undertaken to sample adequacy for each sampling unit with a minimum of fifteen (15) samples. Parameter testing occurred at the one-sided 90% confidence level. Coors Energy Company Keenesburg Mine Page 7 2008 Phase III Vegetation Study Comparisons between sample mean parameter values and the revegetation success standard assume that the sample mean value accurately represents the population mean in all cases. The following formula was used for sample adequacy calculations: (02 (s)2 nmin (d Xbar)2 where: nmin = minimum sample size s = sample standard deviation t = the Student's t distribution value at the 90% level (one-sided) d = percent acceptable deviation from the mean (10%) Xbar = sample mean 2.4 STATISTICAL ANALYSIS Statistical analysis for the revegetation success criterion of total vegetation cover is required if the value of the sample mean from the reclaimed area is less than 90 percent of the value of the final revegetation success criteria for total vegetation cover or total herbaceous production. Sampling revealed that the mean total vegetation cover for both the 1985/1986/1987 and 1995/1997 sampling units was greater than that of the final revegetation cover success standard value, therefore no statistical analysis was required. Similarly, total herbaceous production means for the 1985/1986/1987 and 1995/1997 sampling units significantly exceeded the final herbaceous production criterion value, therefore no statistical analysis was necessary. 2.5 SPECIES IDENTIFICATION AND VERIFICATION Species identification was accomplished in the field through the use of plant identification keys (Harrington, 1954, Weber, 1990; Whitson, 1987; Zimdahl, 1990, Stubbendieck, et al, 1995). In cases where plant identification was inconclusive in the field, voucher specimens were pressed for lab identification. 3.0 RESULTS 3.1 QUANTITATIVE EVALUATION: RECLAMATION AREAS 3.1.1 1985, 1986, and 1987 RECLAMATION AREAS The 1985 reclamation areas encompass approximately 22 acres of reclaimed pit in the north central area of the Keenesburg Mine permit area. The 1985 reclamation area is composed of two parcels (Areas 13 and 22) separated by a north -south haul road corridor. This area is Coors Energy Company Keenesburg Mine Page 8 2008 Phase III Vegetation Study nearly flat with a gentle slope (<2°) to the north and east. Reclamation and coincident revegetation within this area took place in 1985. Replaced soils were sandy in texture. The revegetation seed mix differed slightly in composition and representation of cool season grasses from the seed mix applied to the 1986 and 1987 reclaimed areas, yielding a slightly different species composition. The 1986 reclamation areas encompass approximately 51 acres of reclaimed pit in the central area of the Keenesburg Mine permit area. The 1986 reclamation area is composed of three parcels (Areas 4, 12, and 20) separated by north -south haul road corridors (Areas 3 and 19). The area is nearly flat with a gentle slope (<1°) to the north and east. Reclamation and coincident revegetation within this area took place in 1986. Replaced soils were sandy in texture. The 1987 reclamation areas encompass approximately 39 acres of reclaimed pit and adjacent areas in the south central area of the Keenesburg Mine permit area. The 1987 reclamation area is composed of two parcels (Areas 11 and 17) separated by a north -south haul road corridor and three narrow reclamation parcels (Areas 9, 10, and 16). The entire 1987 reclamation area is nearly flat with a gentle slope (<1°) to the south and east. Reclamation and subsequent revegetation within this area took place in 1987. Replaced soils were generally sandy in texture. Specific sampling information for the 1985, 1986, and 1987 reclamation areas is contained in Tables 1, 2, and 4. 3.1.1.1 Vegetation Cover Total vegetation cover of the 1985, 1986, and 1987 reclamation areas was 63.20 percent. Graminoids provided 55.07 percent mean cover (87.19% relative cover) and forbs accounted for 5.87 percent mean cover (8.42% relative cover). Succulents accounted for 1.33 percent total cover (2.63% relative cover), while shrubs provided 0.93 percent vegetation cover (1.75% relative cover). The lowest total vegetation cover of the parcels sampled was found in Areas 12 and 17 (56%) and the highest cover (76%) was found in Area 11. No single species was encountered in all the cover transects, though Calamovilfa longifolia (prairie sandreed) and Bromus marginatus (mountain brome) were each encountered in 87 percent of the transects, Bouteloua gracilis (blue grama) in 80 percent of the transects, Sporobolus cryptandrus (sand dropseed) in 73 percent of transects, and Andropogon hallii (sand bluestem) in 53 percent of all transects. Bromus marginatus, a cool season native prairie grass, accounted for the highest overall vegetation cover with 21.20 percent mean cover and 32.11 percent relative cover in the 1985, 1986, and 1987 reclamation areas. Seven additional species contributed significantly to vegetation cover (greater than 3% relative cover); the warm season native perennial grass Bouteloua gracilis with 10.67 percent mean cover and 20.35 percent relative cover, the native warm season perennial grass Calamovilfa longifolia contributed 8.13 percent mean cover (11.40% relative cover), the warm season native Andropogon hallii provided 4.40 percent total vegetation cover and 7.19 percent relative cover, warm season native graminoid Sporobolus cryptandrus accounted for 4.00 percent mean cover (5.61% relative cover), Coors Energy Company Keenesburg Mine Page 9 2008 Phase III Vegetation Study Agropyron cristatum (crested wheatgrass), the introduced perennial range grass, contributed 1.73 percent total cover (3.68% relative cover), the cool season introduced annual grass Bromus tectorum (cheatgrass) provided 2.53 percent mean total cover (3.33 percent relative cover), and the perennial native forb Ambrosia psilostachya (ragweed) accounted for 2.13 percent mean cover (3.16% relative cover). Vegetative litter (prior years growth, dead wood, and other biologic organic material) comprised 29.73 percent ground cover overall within the 1985, 1986, and 1987 reclamation areas. Bare soil comprised 7.07 percent of the ground cover. No rock or cryptogams were encountered during the cover sampling in the reclamation areas. 3.1.1.2 Herbaceous Production Total herbaceous production within the 1985, 1986, and 1987 reclamation areas (Table 4) in 2008 was 144.68 g/m2 (1290 lb/ac). 3.1.1.3 Species Composition Cover sampling identified four lifeforms and twenty-one species within the 1985, 1986, and 1987 reclamation areas. The lifeforms included eleven species of perennial grass, one annual grass, one perennial forb, one biennial forb, five annual forbs, one succulent, and one shrub. Of the species encountered on the 1985, 1986, and 1987 reclamation areas, fifteen were native and six were introduced. Perennial species outnumbered annual species by fourteen to six. Both warm and cool season species contributed to the seasonality of the 1985, 1986, and 1987 reclamation areas. Warm season graminoids outnumbered cool season graminoids by seven to five. Cool season forbs prevailed by six to one. The succulent was evergreen and the shrub was deciduous. The 1985, 1986, and 1987 reclamation areas had eight species contributing greater than three percent relative cover this year. The species contributing greater than three percent relative cover included six perennial grasses, one annual grass, and one perennial forb. These species included Bromus marginatus (32.11%), Bouteloua gracilis (20.35%), Calamovilfa longifolia (11.40%), Andropogon hallii (7.19%), Sporobolus cryptandrus (5.61%), Agropyron cristatum (3.68%), Bromus tectorum (3.33%), and Ambrosia psilostachya (3.16%). 3.1.2 1995 AND 1997 RECLAMATION AREAS The 1995 reclamation areas encompass a total of approximately 36 acres of reclamation in six distinct areas within the Keenesburg Mine permit area. The areas are found throughout the disturbance area of the mine and include; Area 1 (the former tipple area north of the shop building), Area 8 comprising the east third of A pit, Area 24 (a road corridor from the northwest corner of the long term spoil storage area to the northwest boundary of the permit area), Area 26 (located south of the sediment pond), Area 27 (an area between the sediment pond and the 1985 reclamation area which was used for spoil storage), and Area 28, an area west of the sediment pond. The 1995 reclamation areas are nearly flat with a gentle slope (<1°) to the north and east. Coors Energy Company Keenesburg Mine Page 10 2008 Phase III Vegetation Study The 1997 reclamation areas sampled encompass approximately 18 acres of reclamation in four distinct areas within the Keenesburg Mine permit area. The areas are found throughout the disturbance area of the mine and include Area 3 that is a road corridor between the 1985/1986 central reclamation areas and the 1986 east area, Area 14 (an area to the west of A pit), and Areas 18 and 21, two areas adjacent to B pit. The 1997 reclamation areas are nearly flat overall with a gentle slope (1-3°) to the north. Reclamation and coincident revegetation with the permanent seed mix took place during the autumn of 1997 within these areas. Replaced soils were sandy in texture. Specific sampling information for the 1995 and 1997 reclamation areas is contained in Tables 1,3,and 5. 3.1.2.1 Vegetation Cover Total vegetation cover of the 1995 and 1997 reclamation areas was 59.20 percent (Table 3). Graminoids provided 52.40 percent mean cover (90.52% relative cover), forbs accounted for 6.67 percent mean cover (9.30% relative cover), and one succulent provided 0.13 percent mean cover and 0.18 percent relative cover. The lowest total vegetation cover of the 1995 and 1997 reclamation areas sampled was found in Areas 1, 24, and 26 (54%) and the highest was in Area 28 (70%). Calamovilfa longifolia was encountered in all the cover transects, Sporobolus cryptandrus was encountered in 93 percent of the transects, Bromus marginatus was present in 73 percent of all transects, and Agropyron smithii (western wheatgrass) and Bouteloua gracilis were found in 60 percent of all transects. Calamovilfa longifolia, Bromus marginatus and Sporobolus cryptandrus were co -dominant with regard to vegetation cover in the 1995 and 1997 reclamation areas. Bromus marginatus provided 13.33 percent vegetation cover and 18.60 percent relative cover while Calamovilfa longifolia contributed 11.60 percent mean cover and 19.14 percent relative cover and Sporobolus cryptandrus accounted for 11.07 percent total vegetation cover and 18.60 percent relative cover. Four additional species contributed significantly to vegetation cover (greater than 3% relative cover); Bouteloua gracilis contributed 4.53 percent mean cover (11.45% relative cover), Bouteloua cur/ipendula (sideoats grama) provided 3.07 percent total vegetation cover and 7.16 percent relative cover, Agropyron smithii accounted for 4.13 percent mean cover (6.44% relative cover), and Ambrosia psilostachya contributed 2.67 percent mean and 3.94 percent relative cover. Vegetative litter (prior years growth, dead wood, and other biologic organic material) comprised 25.33 percent ground cover overall within the 1995 and 1997 reclamation areas. Bare soil comprised 15.47 percent of the ground cover. No rock or cryptogams were encountered during the cover sampling in the 1995 and 1997 reclamation areas. 3.1.2.2 Herbaceous Production Overall mean total herbaceous production within the 1995 and 1997 reclamation areas this year was 174.86 g/m2 (1559 lb/ac). 3.1.2.3 Species Composition Coors Energy Company Keenesburg Mine Page 11 2008 Phase III Vegetation Study Cover sampling identified three lifeforms and 22 species within the 1995 and 1997 reclamation areas. The lifeforms included thirteen species of perennial graminoids, one annual grass, two perennial forbs, one biennial forb, four annual forbs, and one succulent. Of the species encountered on the 1995 and 1997 reclamation areas, sixteen were native and six were introduced. Perennial species outnumbered annual species by sixteen to five, with one biennial species. Warm season graminoid and forb species were more prevalent than cool season species (11 warm season to 10 cool season) in the 1995 and 1997 reclamation areas. Warm season graminoid species accounted for nine species and cool season grass species included five species. Five forb species were identified as cool season and two were warm season. The succulent was evergreen. The 1995 and 1997 reclamation areas had seven species contributing greater than three percent relative cover this year. These species included Calamovilfa longifolia (19.14% percent relative cover), Bromus marginatus and Sporobolus cryptandrus (18.60 percent relative cover each), Bouteloua gracilis (11.45%), Bouteloua curtipendula (7.16%), Agropyron smithii (6.44%), and Ambrosia psilostachya (3.94%). 3.3 COMPARISON OF RECLAMATION AREAS WITH FINAL REVEGETATION SUCCESS CRITERIA Comparison of the reclaimed area values for vegetation cover, herbaceous production, and species composition with the final revegetation success criteria, indicates whether revegetation has been successful, or whether additional measures need to be initiated to enhance vegetation community development. The tables below allow the comparison of the parameter values with the standard to be achieved, either from the predictive equations in the case of total vegetation cover (y=0.0173x3-0.8592x2+14.562x-47.015) and total herbaceous production (y=0.3749x2 2485), or the established standard for species composition. Total Vegetation Cover (2008) Predictive Equation Value for 2008: 23.13% total vegetation cover (based on 7.95" precipitation value) 1985/1986/1987 Rec. Areas 1995/1997 Rec. Areas X bar S N Nmin 63.20 % 6.36 15 2 59.20 % 5.65 15 2 Based on the results of the 2008 quantitative sampling, the 1985, 1986, and 1987 reclamation areas and 1995 and 1997 reclamation areas significantly exceeded the predicted total cover vegetation value of 23.13 percent, meeting the final revegetation success criterion for vegetation cover. Total Herbaceous Production (2008) Coors Energy Company Keenesburg Mine 2008 Phase III Vegetation Study Page 12 Predictive Equation Value for 2008: 39.66 g/m2 total herbaceous production (based on 7.95" precipitation value) 1985/1986/1987 Rec. Areas 1995/1997 Rec. Areas xbar S N Nmin 144.68 32.08 15 9 174.86 52.44 25 16 With regard to total herbaceous production, the 1985, 1986, and 1987 reclamation areas and 1995 and 1997 reclamation areas significantly exceeded the predicted value for total herbaceous production thereby meeting the final revegetation success criterion. Species Composition (2008) Success Standard 1985/1986/1987 Rec. Areas 1995/1997 Rec. Areas Total Perennial Species* Warm Season Grasses* Cool Season Grasses* Relative Importance (3%<x<40%) 4 3 All Species 7 4 2 All Species 7 4 2 All Species * Numbers reflect only those species meeting the relative importance percentage limitation Both the 1985, 1986, and 1987 reclamation areas and the 1995 and 1997 reclamation areas satisfied the final species composition revegetation criteria. In the 1985, 1986, and 1987 reclamation areas, the seven qualifying perennial species were; Bromus marginatus (32.11%), Bouteloua gracilis (20.35%), Calamovilfa longifolia (11.40%), Andropogon hallii (7.19%), Sporobolus cryptandrus (5.61%), Agropyron cristatum (3.68%), and Ambrosia psilostachya (3.16%). Of these species, Bouteloua gracilis, Calamovilfa longifolia, Andropogon hallii, and Sporobolus cryptandrus are qualifying warm season graminoids and Bromus marginatus, and Agropyron cristatum are qualifying cool season graminoids. In the 1995 and 1997 reclamation areas, the seven qualifying perennial species were; Calamovilfa longifolia (19.14% percent relative cover), Bromus marginatus and Sporobolus cryptandrus (18.60 percent relative cover each), Bouteloua gracilis (11.45%), Bouteloua curtipendula (7.16%), Agropyron smithii (6.44%), and Ambrosia psilostachya (3.94%). Of these species, Calamovilfa longifolia, Sporobolus cryptandrus, Bouteloua gracilis, and Bouteloua curtipendula are qualifying warm season graminoids and Bromus marginatus and Agropyron smithii are qualifying cool season graminoids. Coors Energy Company Keenesburg Mine Page 13 2008 Phase III Vegetation Study 4.0 DISCUSSION AND CONCLUSIONS 4.1 VEGETATION COVER Both the 1985, 1986, and 1987 reclamation areas and the 1995 and 1997 reclamation areas exceeded the final revegetation success criterion value (23.13%) for total vegetation cover. The 1985, 1986, and 1987 reclamation areas had a mean total vegetation cover of 63.20 percent and the 1995 and 1997 reclamation areas had a mean total vegetation cover of 59.20 percent. The second year of quantitative vegetation cover sampling for Phase III bond and liability release reveals that the requirement for vegetation cover has been met. 4.2 HERBACEOUS PRODUCTION The 1985, 1986, and 1987 reclamation areas and the 1995 and 1997 reclamation areas exceeded the final revegetation success criterion value (39.66 g/m2) for total herbaceous production. The 1985, 1986, and 1987 reclamation areas had a mean total herbaceous production of 144.68 g/m2 and the 1995 and 1997 reclamation areas had a mean total herbaceous production of 174.86 g/m2. The second year of quantitative vegetation cover sampling for Phase III bond and liability release reveals that the requirement for total herbaceous production has been met. 4.3 SPECIES COMPOSITION The species composition standard requires that there be at least four perennial species, of which three are warm season grasses and one a cool season grass. No one component of the above four species should comprise greater than 40% relative importance nor less than 3% relative importance. Relative importance will be measured by calculating relative cover of the revegetation species. Vegetation species which may be used in the calculation of species composition may be any plant species not defined as a noxious or prohibited plant species, and may be native or introduced. Both the 1985, 1986, and 1987 reclamation areas and the 1995 and 1997 reclamation areas satisfied the final species composition revegetation criteria. The 1985, 1986, and 1987 reclamation areas had seven qualifying perennial species, four qualifying warm season graminoids and two qualifying cool season graminoids. The 1995 and 1997 reclamation areas had seven qualifying perennial species, four qualifying warm season graminoids and two qualifying cool season graminoids. The second year of quantitative vegetation cover sampling for Phase III bond and liability release reveals that the reclamation areas have exceeded the final revegetation success requirements for species composition. 5.0 SUMMARY The quantitative vegetative cover, herbaceous production, and species composition data indicate that the permittee has established a diverse, effective, and permanent vegetative cover of the same seasonal variety as the original vegetation. The revegetated area is capable Coors Energy Company Keenesburg Mine Page 14 2008 Phase III Vegetation Study of self -regeneration and plant succession. The data shows development of a stable, self- sustaining vegetation community, with seasonality and diversity sufficient to demonstrate successful reestablishment of vegetation on the reclaimed area. Coor5 Energy Company Keenesburg Mine Page 15 2008 Phase III Vegetation Study 6.0 LITERATURE CITED Harrington, H.D. 1954 Manual of the Plants of Colorado. Sage Books. Denver Stubbendieck, J., G.Y. Friisoe, and M.R. Bolick. 1995. Weeds of Nebraska and the Great Plains. Nebraska Department of Agriculture. Weber, William A. 1990. Colorado Flora: Eastern Slope. University of Colorado Press Whitson, Torn D. Editor. 1987. Weeds and Poisonous Plants of Wyoming and Utah. Cooperative Extension Service, College of Agriculture, The University of Wyoming Zimdahl, Robert L. 1990. Weeds of Colorado. Cooperative Extension, Colorado State University Bulletin 521A Coors Energy Company Keenesburg Mine Page 16 2008 Phase III Vegetation Study • • 7.0 TABLES • Coors Energy Company Keenesburg Mine Page 17 2008 Phase HI Vegetation Study Table 1. 2008 Plant Species List: Keenesburg Mine 1985, 1986, 1987, 1995 and 1997 Reclamation Areas Species Name Common Name Lifeform 1985/1986/1987 1995/1997 Areas Areas Graminoids Agropyron cristatum Crested Wheatgrass P,C,I X X Agropyron smithii Western Wheatgrass Andropogon gerardii Big Bluestem Andropogon hallii Sand Bluestem P,C,N X X P,W,N X P,W,N X X Aritida purpurea Three Awn P,W,N X Bouteloua curtipendula Sideoats Grama P,W,N Bouteloua gracilis Blue Grama P,W,N X X Brooms marginatus Mountain Brome P,C,N Bromus tectorum Cheatgrass A,C,I Calamovilfa longifolia Prairie Sandreed P,W,N Oryzopsis hymenoides Indian Ricegrass P,C,N Panicum virgatum Switchgrass P,W,N Schizachyrium scoparium Little Bluestem P,W,N Sporobolus cryptandrus Sand Dropseed P,W,N Total Number of Grasses Total Number Perennial Grasses Total Number Annual Grasses Total Number Native Grasses Total Number Introduced Grasses Total Number Cool Season Grasses Total Number Warm Season Grasses Coors Energy Company Keenesburg Mine 2008 Phase III Vegetation Study 12 11 1 10 2 5 7 14 13 12 2 5 9 Page 18 Table 1. 2008 Plant Species List: Keenesburg Mine 1985, 1986, 1987, 1995 and 1997 Reclamation Areas continued Species Name Common Name Lifeform 1985/1986/1987 1995/1997 Areas Areas Forbs Ambrosia psilostachya Ragweed P,C,N Aster fendleri Aster Chenopodium album Lambsquarters P,W,N X Eriogonum annuum Buckwheat A,C,1 A,C,N X X Helianthus annuus Sunflower A,W,N Kochia scoparia Kochia A,C,I Lactuca serriola Prickly Lettuce A,C,I X Medicago lupulina Black Medic Melilotus ocinalis Yellow Sweetclover A,C,1 X X B,C,I Total Number of Forbs Total Number Perennial Forbs Total Number Biennial Forbs Total Number Annual Forbs Total Number Native Forbs Total Number Introduced Forbs Total Number Cool Season Forbs Total Number Warm Season Fortis Succulents 7 7 1 2 1 1 5 4 3 3 4 4 6 5 1 2 Opuntia polyacantha Prickly Pear P,E,N X Yucca glauca Yucca P,E,N X Total Number of Succulents Shrubs Artemisia ftlifolia Sand Sage Total Number of Shrubs P,D,N TOTAL NUMBER OF SPECIES Lifeform abbreviations: A annual B biennial P perennial C cool season W warm season D deciduous E evergreen 0 21 22 N native I introduced L legume Note: Only plant species encountered during cover sampling are represented on this list Coors Energy Company Keenesburg Mine Page 19 2008 Phase Ill Vegetation Study • Transect Location able 2. Vegetation Cover: 1985, 1986, and 1987 Reclamation Areas (2008) 0 ao at OW L L O N Q N N v O N N_ A C) yF cover rank C E 00 N V N D M N N 4 E a z E E U Species Name 0. oc Lr a v, M 00 In o0 • r OIN M,.M ^O �. Otei r • MSS N N VI NwMilo .. -y 2 N N 0010 O OID 00 00 0 O en M O OIL N O0 en 0 • -)la 000 O N O'O In) N — O 00 en en N IM D\ N en P O O O O b N V I I N N IN IV N N 00 0O 00 I b Iy N O N I N en 00 'CI N N V N N t b 'O N 'N N I eel. O N N N V 51 EITi m W 0.. �'mIG L C '00 C. O L t LO.y m... E J 3 v� "v.� o] '. •• 3 a U L E rn ° � y ° ma'c`s y y c `n '�.. 4&,.I COI ply L. °• , E o v C U y C U 00 ° Ut0 0 N r ice, cs 3',m v' WU O O O E mes 0 O S t K°° 0. .3O. t U U N II, . y o o h m a o °'II p y i ° Q C y O 1` ,i S M `.3 0cdi l 09 ≤� V v! ul U Ed E L Q VW Z�C, !, LL 1,2 V�'I rLli',Q n a u C n h In O Vegetation Cover b bN 0 en N O O [N 0 0 OO N O N y E O p N O z N O O N 'C O M V) 0 O M 00 O O N 00 0 O N 'O O O M 00 CO 0 `NY N O O M et 0 O a O 0 N 0 0 0 M N 0 0 b O O O 00 O N Note: all data presented in percent (%) cover O N m ea 0- m C II.a a V c Y .471 • O c R Q • i O >° U 4 • OS E W CO o O O N • m C C > E 0 0) 00 En aN ea V N50 N 1.0 N N N • R F N O P 00 N V 00 C E E U E C W • V 0n t'I v 0 :p o a m o °.C E'', s z E V [ 0. U. 0Q C.`O 0 SII 0000 4 0 l 0. 0 °L CI 0 E„> y Cv 0�I 0 a ' O 1 2 CI 0' O t% w I I. E E'I C° 00 00 P O P Vl Q N.M - Q,,1' PIN CV 0 N ^ In Q aa'N.00 0 V' OIQ ^ T M.0 IIO - Q P - 't ,O• Vl W Q NI`0 N 1p0i.!0 N. �' O PO .. —I! el 01 a P M 0�O VI,M NIO r'1 co aIIQ a r-. MI VI — O OIIO O M P I00 O a - 0 MGM M P v.i I — OIM oO .. N O M CIO OLIN a .,. �p NIMIN 0 a a V N 0 NIN 00 N N O M — a- <0 N'!Q N 1O M M OIQ O OO i+1 Q!�0 I^ O OO r en N — O .-, O OIO 10 O O cIaIQ'. IN a N Q Q Q M N O- Q 0 O N . NN.QNI N O a N N 00 ' N N N', N 0 Q N N Q ^ p 0!O 0, Q. NL N 00 N N 1,N N NI I QN N N�0 0 • N N N olI,OI,N I°° Q N 'IN N N NI b 10 Iq E',, 10 z 03 E 7.• E I,EV. L 5u a. m C7 iIElm C'm n 113 a mIo L m4 �!� ?!E I'O LI❑ Q.I�'RIclJ• O 16 ejliaoliseee) WIU'IG L.cnIO I,r (0 i O O .I C Im ^� o � v U 3mti Fr V]ICi III IUId I� m,I -]�m o I;!» 3 n y o a U a a C) O N O 0 0 C O O en N O O M a O O v1 ^ O N o °O 3o O N b O N O 00 5 - co 00 0 O -- 0 a 0 0 O N O M - O Q 0 O N O Q 00 co N O Q N O N N Note: all data presented in percent (%) cover r N 0 0- a m C • 73 • y C c N 1 O 01C t CA- 00 O > O L N y R = d N • Q O N Table 4. Herbaceous Production: Keenesburg Mine 1985, 1986, and 1987 Reclamation Areas (2008) Area Number co v Cl WI er N e1 N N_ ro N O Cr, CO N V N M 0 M CO M N W N R N or CO N b r b C N C W r In Cl N N O N N N r b O (1i N C' N O M Herbaceous Production note: all data presented in grams per square meter N N 0 d • • • Table 5. Herbaceous Production: Keenesburg Mine 1995 and 1997 Reclamation Areas (2008) Area Number 00 ✓ 00 tv. 0 N O C' 00 N 0 MI N N O N V N M N M d N N m O N N N 00 N N N M N 00 00 co cc rn O O O h Herbaceous Production C N EI e N ra- CO ln N N Ct N N R N N N 00 N N CO L b 00 C N E F 00 oo M 0 N N O N O r rr h O 00 00 cm M N N O Cr: In O In Herbaceous Production note: all data presented in grams per square meter C 6 L Ta a • 13 N V • N • c Y 0 T as C y N N 10. E O U is m L in • N C C d W oa tO L O 0 U N • • 8.0 APPENDIX • Coors Energy Company Keenesburg Mine Page 24 2008 Phase III Vegetation Study LARGE MAPS AVAILABLE FOR VIEWING AT THE CLERK TO THE BOARD'S OFFICE, IN THE PUBLIC REVIEW FILE. • • • PHASE III BOND RELEASE MAP LARGE MAPS AVAILABLE FOR VIEWING AT THE CLERK TO THE BOARD'S OFFICE, IN THE PUBLIC REVIEW FILE. Hello