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standards apply to elevations above 6700 feet and below 7200 feet, and range site A standards apply to <br />elevations greater than 7200 feet (permit section 4.4.1). Contiguous areas of range site A and range site <br />B seeded in the same year and receiving similar reclamation practices may be lumped together into one <br />range site AB parcel. When the bond release blocks are comprised of both A and B range site areas, <br />cover and production standards for range site A will be applied to the block relative to demonstrating <br />reclamation success. In some cases, when small range site C parcels exhibit characteristics and uses <br />consistent with adjoining AB parcels, they may be included in the range A/B bond release block. When <br />small isolated C parcels are included in a predominantly A/B block, the more stringent success standards <br />for range site A and /or B, as applicable, will be used on the entire block (Permit section 4.4.1.5). <br />Cover and Species Composition <br />Vegetative cover was sampled in 2014 for all the parcels included in the SL16 release application. <br />Vegetation cover was measured using systematically located transects using a point -hit technique with <br />an Optical Point Bar. The sampling method used, meets the criteria outlined in Rule 4.15.11 (1) and the <br />permit application. Based on the vegetation transect summary table submitted in Appendix 2 of the SL- <br />16 application, the required number of samples taken was adequate. The Operator sampled 66 points <br />throughout the release block. The total effective cover measured at the site was 60% (perennial cover <br />minus noxious perennials, plus up to 10% annualibiennial relative cover plus the allowable 19% litter <br />cover). The total effective cover exceeds the necessary effective cover standard for range site A. <br />Based on the perennial species of grasses, forbs and shrubs found at the site as indicated in the SL16 <br />application, it appears the species diversity and composition will support the post -mine land use. While <br />noxious weeds were encountered at the site, they consisted of a small percentage of the vegetative cover <br />(1.4 % cover). <br />The condition of the sediment ponds and any needed maintenance on the pond receiving runoff from the <br />bond release parcels was evaluated. Each of the ponds observed was functioning and no required <br />maintenance items were noted. Each of the ponds receiving run -off from the bond release parcels is also <br />receiving flow from affected lands not under consideration for bond release at this time. <br />Sedimentology <br />In accordance with Rule 3.03.1(3)(b) and with Section III.A.7.a. of the Division's 1995 "Guideline <br />Regarding Selected Coal Mine Bond Release Issues ", Trapper submitted two evaluations to demonstrate <br />that runoff from each Bond Release Block will result in equivalent or lesser sediment contribution as <br />compared to baseline conditions and similar undisturbed lands. <br />Trapper's bond release application compares pre- and post- mining sediment yields by calculating the <br />expected sediment yields for both conditions. Trapper used the USLE and SEDCAD4 calculation <br />methods. The USLE calculates expected average annual soil loss per acre of land and SEDCAD 4 <br />calculated the expected settleable solids concentration in runoff from a precipitation event. <br />USLE Comparison: Only the "C" factor is varied between the pre- mining and the post- mining <br />calculations; all other variables are constant for pre and post- mining. The pre- mining calculation <br />Page 8 of 10 <br />