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INTEROFFICE MEMORANDUM <br />TO: ZACH TRUJILLO <br />FROM: JANET BINNS <br />SUBJECT: MUNGER CANYON 2013 VEGETATION EVALUATION REPORT <br />DATE: 6/2/2014 <br />CC: ROB ZUBER <br />I have reviewed CAM Mining, Inc's submittal of the Munger Canyon Mine, Phase II <br />Bond Release Revegetation Evaluation Report. The Munger Canyon Mine is a reclaimed <br />undergropund mine. The surface disturbance was mostly limited to construction of an <br />access road in a steep canyon, and the associated portal bench and fan area, an access <br />road, and a coal waste pile. The site was reclaimed in 2007 and seeded with the approved <br />Big Sagebrush Shrubland Seed Mix in November 2007. The reclaimed area is compared <br />to a Sagebrush reference area for reclamation success. Vegetation sampling conducted <br />May 29, 2013 represents the beginning of the 6t' growing season following seeding. <br />The reclaimed parcel at the Munger Mine is predominately linear in nature, since a <br />portion of the reclaimed area represents reclamation of the access road to the portal <br />bench. Another portion of the reclaimed parcel consists of a reclaimed access road that <br />went northeasterly. Due to the configuration of the reclamation parcel, the operator used <br />a systematic approach to collect vegetation cover data. This approach is acceptable to the <br />Division. <br />Both the Sagebrush reference area and the reclaimed parcel were sampled to adequacy <br />using the Cochran statistical adequacy formula as shown in Rule 4.15.11(2)(a). The <br />vegetation consultant subtracted cover contributed by noxious weed species (as defined <br />by Garfield County) and cover contributed by annual and biennial species prior to <br />comparison of reclaimed parcel data to the reference area data. This is an acceptable <br />approach to the Division. Of note, several species included in the sample data are on the <br />Colorado Department of Agriculture Noxious Weed list; specifically Cheatgrass, <br />Halogeton, Field bindweed, and Redstem filaree, that are not included on Garfield <br />County's weed list. The Division allows for the respective County list for determination. <br />In this case, even if the minor contribution of the species on the state list, but not the <br />county list were subtracted out, the reclaimed parcel still exceeds the cover value <br />measured in the reference area. <br />The reclamation success standard requires the operator to establish perennial vegetation <br />with cover equal to or greater than 90% of the perennial cover measured in the reference <br />area (Rule 4.15.8(3)(a) and permit section 3.9). Perennial non - noxious vegetation cover <br />measured on the reclamation area in 2013 was 28.4 %. Non - noxious perennial vegetation <br />